CFI teaching Instrument

[shdw]

While this is true, at some point it becomes a mockery when you can look at the record of training and see a steady progression though the 61.65 requirements, only to be finished up by a -II. It looks to be a deliberate end-run around the intent of the regulations.

My issue with this, and why I agree with midlife, is that you say issues are covered by a CFI then finished by a II. When in reality it could be joe the currently being trained instrument pilot providing training as a safety pilot. At least in the case of a CFI it is an instructor.

That said, 61.65 needs to be covered in it's entirety to be able to sign off the student as a II. So the 15 hours has to cover all of it. The other 25 hours can be done with anyone and if you want to do it while logging instruction (not towards a rating) then more power to you.

Consider this, 25 hours with a safety pilot. Or 25 hours with a CFI doing all of the 61.65 stuff. Completion with 15 hours with a II doing all of 61.65 for the final sign off. The guy who went with the CFI got more than double the training and they both met the regulation.


Edit: I don't agree with a CFI charging to give instrument training at an "instrument rate" if there is a difference. The charge should be whatever you charge a typical private pilot. I know some places charge 10-15 more for instrument training.

 

[tgrayson]

Or 25 hours with a CFI doing all of the 61.65 stuff.

The CFI isn't qualified for that, according to the FAA. With the safety pilot, the student is presumably practicing the stuff that his qualified instructor taught him.

The FAA LOIs said that CFIs cannot provide "instrument training". Regardless of whether or not you agree with that decision, they said it. Trying to pull a fast one by calling it "Flight by Reference to Instruments" is deception. Everyone involved knows what's really going on.

 

[PA44-LUV]

(I just noticed juskl's post - apparently Scottsdale agrees with you - a CFI-A can't ever put a pilot under the hood after he gets his private.)

That would imply a CFI-A can't act as safety pilot, if I read that with the most literal interpretation....

So as a CFI-A only instructor, would you be okay teaching out of the Instrument Rating PTS or would you limit yourself to the Private PTS only? And if so, why? No sarcasm at all here, honest question seeking honest response.

I've followed this thread all day and it has been quite interesting to say the least. I think we're getting hung up on semantics then going along with the spirit of the regulations. The regulations say "a flight instructor who provides instrument training for the issuance of an instrument rating..." must hold an instrument rating on his instructor certificate. Well, if I'm technically training for an instrument rating, even though I'm not calling it those "15 hours that have to be with a CFII," is it still not instrument training for an instrument rating?

During private training a student has to have 40 hours flight time with a min. of 20 hours instruction and the rest could technically be solo. Can't we do the same analogy to the instrument rating with the 40 hr instrument time with the 15 hr min with CFII and 25 hr with safety pilot or another CFI. Would you solo without learning the maneuvers right from the an appropriately rated instructor (I'm obviously neglecting the endorsement stuff for sake of argument). No of course not. So why would you go get "instruction" from "joe the 'i'm training for an instrument rating myself' safety pilot or a CFI-A when they haven't demonstrated to the FAA that they can teach instruments before you actually started "real" instrument training? In effect the same thing midlife said a few posts above:

But the situations I've heard of where both one-Is and double-Is have been used effectively involve the CFII doing th primary instruction with the one-I taking the role of assisting in practicing what's already been learned.

You can probably tell I read this month's AOPA Flight Training magazine article on fulfilling the spirit of the flight review, not just the 1 hr ground/1 hr air.

Being conservative, I side with tgrayson on the spirit and intent of the regulations until I hear the Chief Counsel's LOI response when he poses the question to them. Or put another way, if I didn't hold an CFII, I would not want to be CFI-A that had a complaint filed against them to the FSDO that they were potentially operating outside of their flight instructor limitations.

 

[shdw]

The FAA LOIs said that CFIs cannot provide "instrument training". Regardless of whether or not you agree with that decision, they said it. Trying to pull a fast one by calling it "Flight by Reference to Instruments" is deception. Everyone involved knows what's really going on.

No LOI has addressed this question specifically

Your trying to make a square box fit in a round hole IMO. You need 15 hours by a II towards the rating. If the CFI wants to teach it "not towards a rating" I don't see a problem with that. Technically a regular private pilot working on his instrument rating can do that.

We will have to agree to disagree here too I think bud. Unless you have something more specific.

FWIW I am not saying the CFI should log teaching parts of 61.65 in the students logbook, just like the private pilot in the above example can't. Instead, I would log it as instrument work. Logging it as otherwise could confuse the II when they go for the rating.

 

[tgrayson]

Unless you have something more specific.

Actually, I have quoted supporting material from LOIs, but those with opposing views have no support at all; your blanket assertion that this is okay ought to be presented with more caution. You're expecting a higher level of evidence from me than you do from yourself.

 

[PA44-LUV]

How about the FAA comments to the changes to 61.195(c) as described in the Federal Register?

74 FR 42535, August 21, 2009, change 73: "One commenter recommended an instrument instructor rating be required to administer instrument instruction in any context and this IS FAA's past interpretation." (emphasis mine)

Now the issue they specifically address in their comments is about a CFII doing the training for commercial, but since one can say the training for the instrument rating is advanced as compared to the required "basic instrument maneuvers" required for the private ticket, the logic should follow along the same lines.

"The FAA disagrees that a non-instrument rated flight instructor should be able to teach the instrument training required for commercial pilot certification. The FAA expects the instrument training required for commercial pilot certification to be more advanced and requires that the flight instructor who teaches instrument training at the commercial pilot certification level hold an instrument rating on their flight instructor certificate."

Or in another section, "The FAA has made a distinction between the instructor qualifications for flight instructors who provide private pilot training of maneuvering an aircraft "solely by reference to instruments including ... " as opposed to more advanced instrument training.

And if an IAP is no more than "use of navigation systems" why would the FAA go through the trouble of specifying "the use of navigation systems" for private and then "intercepting and tracking navigation system" for the commercial.

I found the FOI tgrayson cited on the FAA's website. Reading through it's apparent that the FAA did not intend non-II instructors to teach beyond that required for private pilot certification. and if the quote at the front doesn't say it, I don't what does.

 

[escapepilot]

I've read the Jan. 4, 2010 FOI and its pretty clear that a CFI cannot teach any instrument for commercial or instrument ratings.

So glad I posted this question before I started working w/ any of my prospective instrument students. Looks like the II is getting pushed up to ASAP instead of sometime this summer.