CFII required for hood work?

[zx6rrider]

I have a friend that is working on his instrument rating with an instructor who's schedule doesn't allow then to fly very often. I understand he will need the 15 hours instruction from the CFII for the rating but would it be acceptable to go out with him and work on figuring out power/speed settings for his aircraft and work on constant airspeed/rate climbs and descents while he is under the hood and log it as dual instruction with only a CFI? Reading the regs it seems like that is the case but curious what is normal in the industry. Thanks

 

[USMCmech]

For "hood work" any safety pilot can "help" your buddy work on basic attitude flying, no CFI at all needed.

Can't count any of it toward the training requirements for the instrument rating, but you both can log it as dual.

 

[zx6rrider]

I figured I could log it at as safety pilot time but didn't know if it would look funny if I logged it as dual given, knowing that it wouldn't count towards the 15 hours with and "authorized" instructor for the rating.

 

[killbilly]

I figured I could log it at as safety pilot time but didn't know if it would look funny if I logged it as dual given, knowing that it wouldn't count towards the 15 hours with and "authorized" instructor for the rating.

As I understand it, and I think this is what @USMCmech was getting at - you can log it as dual given, but not toward the rating. He can log it as dual-received, but not toward the rating. I *think* that's right.

 

[zx6rrider]

Thanks, now that i re-read it I see what he was saying. That was my interpretation but wanted to verify

 

[USMCmech]

I figured I could log it at as safety pilot time but didn't know if it would look funny if I logged it as dual given, knowing that it wouldn't count towards the 15 hours with and "authorized" instructor for the rating.

I'm sure others will disagree, but if I'm in an airplane with a CFI and we are doing any sort of training/practicing/coaching then I log it as dual received, even if they didn't sign my logbook. If I signed their logbook, then I log it as dual given.

 

[MidlifeFlyer]

I'm sure others will disagree, but if I'm in an airplane with a CFI and we are doing any sort of training/practicing/coaching then I log it as dual received, even if they didn't sign my logbook. If I signed their logbook, then I log it as dual given.

It's not dual received unless the CFI signs. Whether it makes sense or not, it is the clearly stated rule.

IOW, I don't disagree. The FAA disagrees.

 

[MidlifeFlyer]

I figured I could log it at as safety pilot time but didn't know if it would look funny if I logged it as dual given, knowing that it wouldn't count towards the 15 hours with and "authorized" instructor for the rating.

It would not only look funny, it would be technically wrong. In the extreme a false entry as ridiculous as that seems.

There was a common practice for years of using CFIs, not CFIIs, to work with instrument students beyond the 15 required hours. Definitely valuable for both instructor and trainee, although Everyone knew it didn't count as "instrument traininfpg" Unfortunately, someone who used to post here didn't like it and asked the FAA Chief Counsel one of "those" questions, generating this sad answer.
2010 Grayson Letter.

This was one of the few I followed up with an email to the attorney who wrote it, trying to point out what a bad idea it was if read literally. We spoke on the phone. No dice.

 

[killbilly]

It would not only look funny, it would be technically wrong. In the extreme a false entry as ridiculous as that seems.

There was a common practice for years of using CFIs, not CFIIs, to work with instrument students beyond the 15 required hours. Definitely valuable for both instructor and trainee, although Everyone knew it didn't count as "instrument traininfpg" Unfortunately, someone who used to post here didn't like it and asked the FAA Chief Counsel one of "those" questions, generating this sad answer.
2010 Grayson Letter.

This was one of the few I followed up with an email to the attorney who wrote it, trying to point out what a bad idea it was if read literally. We spoke on the phone. No dice.

I just read through the letter (hadn't thought about Grayson in years. wonder what he's up to?) and I'm struggling to understand what you mean by "bad idea to read it literally." As written, it's congruent with my understanding of the reg - the relevant bits being the last paragraph on page 1 and the attorney's conclusion on page 2.

Not knowing what Grayson's intent/position/original letter said, I'm a bit confused. Can you elaborate? This seems extremely important and I'd like to make sure I'm understanding it correctly.

 

[milleR]

I just read through the letter (hadn't thought about Grayson in years. wonder what he's up to?) and I'm struggling to understand what you mean by "bad idea to read it literally." As written, it's congruent with my understanding of the reg - the relevant bits being the last paragraph on page 1 and the attorney's conclusion on page 2.

Not knowing what Grayson's intent/position/original letter said, I'm a bit confused. Can you elaborate? This seems extremely important and I'd like to make sure I'm understanding it correctly.

Taken directly at face value, the first paragraph on the second page would mean that any dual received would have to be provided by a CFII since the instrument student presumably already has a PPL, therefore the instrument training exception provided for a CFI giving dual for a PPL would not be applicable.

The FAA has distinguished instrument training from training in "basic instrument maneuvers" under § 61.107 and training in the "control and maneuvering of an airplane solely by reference to the instruments" under § 61.109 necessary for private pilot certificate. See Grayson Interpretation. However, those exceptions are inapplicable in the context of training for an instrument rating because generally the pilot seeking an instrument rating already has a private pilot certificate. Accordingly, any training provided to a pilot seeking an instrument rating (including instrument training in addition to the minimum training required under 61.65(d)(2)) would be instrument training, and the CFI providing that training must have an instrument rating on the flight instructor and pilot certificates.

You could log the time outside of the required 15 hours with a CFI as part of the 40 simulated/actual instrument requirement, but you can't log it as dual received and the CFI can't log it as dual given. At least that's how I'm reading it.

 

[killbilly]

Taken directly at face value, the first paragraph on the second page would mean that any dual received would have to be provided by a CFII since the instrument student presumable already has a PPL, therefore the instrument training exception provided for a CFI giving dual for a PPL would not be applicable.

Okay. I think I understand the issue with the quoted text in the letter. It's the "in addition to the minimum training" which threw me off.

You could log the time outside of the required 15 hours with a CFI as part of the 40 simulated/actual instrument requirement, but you can't log it as dual received and the CFI can't log it as dual given. At least that's how I'm reading it.

This is where I have the issue. You can't log it as dual received/given toward the instrument rating itself but the training is still loggable as dual-received/given. It just can't be applied to that specific rating. Right?

I agree that it might not be terribly useful...let me state it another way: If the student holds a PPL and needs to log a bunch of XC time anyway, for example, the CFI (not a -II) can instruct on XC procedures, the student can fly it under the hood and log it as simulated instrument time, it can be logged as instruction given/received, it just can't be applied to the totals when the student applies for the IR on the 8710.

Right? Or am I out of my mind?

(edits made for clarity)

 

[MidlifeFlyer]

I just read through the letter (hadn't thought about Grayson in years. wonder what he's up to?) and I'm struggling to understand what you mean by "bad idea to read it literally." As written, it's congruent with my understanding of the reg - the relevant bits being the last paragraph on page 1 and the attorney's conclusion on page 2.

Not knowing what Grayson's intent/position/original letter said, I'm a bit confused. Can you elaborate? This seems extremely important and I'd like to make sure I'm understanding it correctly.

When I spoke with the attorney, I said that read literally, a CFI might hesitate teaching a VFR pilot how to fly an instrument approach for situational awareness. He conceded that would be a fair read and not what was intended but, "we don't want CFIs without an instrument rating on their CFI certificate giving instrument training."

Taylor's letter to the FAA was a follow up to a discussion here in about whether a "one eye" could give instrument training beyond the 15 hour requirements and treat it as dual. Many, including me, argued it was ok so long as it was clear in the log entry that it did not count toward instrument training requirements. Taylor's position was it could not be done at all. You can probably find the thread by searching.

 

[milleR]

Okay. I think I understand the issue with the quoted text in the letter. It's the "in addition to the minimum training" which threw me off.




This is where I have the issue. You can't log it as dual received/given toward the instrument rating itself but the training is still loggable as dual-received/given. It just can't be applied to that specific rating.

I agree that it might not be terribly useful, but if the pilot needs to log a bunch of XC time anyway, for example, the CFI can instruct on XC procedures, the student can fly it under the hood and log it as simulated instrument time, it can be logged as instruction, it just can't be applied to the totals when the student applies for the IR on the 8710.

Right? Or am I splitting hairs?

I think that's where a literal interpretation get's ugly. How you would differentiate between instruction given towards the rating and just plain old dual given would be pretty murky and an examiner could point to that letter and say "nope!". Taken directly at face value, this letter would indicate that all dual instruction would have to be from a CFII until the instrument checkride had been successfully passed.

 

[killbilly]

I think that's where a literal interpretation get's ugly. How you would differentiate between instruction given towards the rating and just plain old dual given would be pretty murky and an examiner could point to that letter and say "nope!". Taken directly at face value, this letter would indicate that all dual instruction would have to be from a CFII until the instrument checkride had been successfully passed.

As long as it was clearly marked in the logbook, and the "Double-Eye" instruction met or exceeded the requirement for the rating, I wouldn't think the examiner would care much, but I definitely see your point.

Makes a lot of sense to get that double-i ticket...but I need the CMEL first.

 

[MidlifeFlyer]

I think that's where a literal interpretation get's ugly. How you would differentiate between instruction given towards the rating and just plain old dual given would be pretty murky and an examiner could point to that letter and say "nope!". Taken directly at face value, this letter would indicate that all dual instruction would have to be from a CFII until the instrument checkride had been successfully passed.

It's certainly possible. It's already done in a number of areas. For example, many career-oriented pilots have separate tallies for "Part 61 PIC" which is what the FAA is interested in and "Part 1 PIC" for potential employers, because the two can be mutually exclusive. The "point to point" cross countries which meet Part 135 experience requirements are separated from the >50 MM cross country required for most certificates and ratings. Pilots who don't bother with a "solo" column still manage identify solo flights for the commercial certificate.

Separating "dual received" from "instrument dual received" is at least as easy as any of those. With electronic logbooks gaining a foothold, it doesn't' even "waste" a column.

 

[USMCmech]

It's not dual received unless the CFI signs. Whether it makes sense or not, it is the clearly stated rule.

IOW, I don't disagree. The FAA disagrees.

I stand corrected.

However, for my personal log book I still log it as dual received if the flight was any kind of training. This reflects my logbook's other role of a personal diary of my flying career, not just a legal record for the FAA. For example, last week I flew a homebuilt helicopter that a broker was selling for a client. The broker was a helo CFI and obviously I was learning something during the flight. I didn't have my log book with me, and I will probably never cross paths with this guy ever again, but when I got home I logged .3 PIC and .3 dual received.

This approach can be problematic for low time pilots who will need to untangle flight times that meet the requirements of pt 61.whatever when they are applying for a new certificate or rating.

 

[MidlifeFlyer]

I stand corrected.

However, for my personal log book I still log it as dual received if the flight was any kind of training. This reflects my logbook's other role of a personal diary of my flying career, not just a legal record for the FAA. For example, last week I flew a homebuilt helicopter that a broker was selling for a client. The broker was a helo CFI and obviously I was learning something during the flight. I didn't have my log book with me, and I will probably never cross paths with this guy ever again, but when I got home I logged .3 PIC and .3 dual received.

This approach can be problematic for low time pilots who will need to untangle flight times that meet the requirements of pt 61.whatever when they are applying for a new certificate or rating.

True. The pilot who accidentally includes them on an 8710 tally or presents them as evidence of training is providing evidence of logbook falsification. In the bad cases (which is the reason the FAA asks to see a logbook) it can be a real problem.

Obviously less of an issue when you have no dual received requirements - if you need to log nothing, I guess it doesn't matter what you log or where. But that's not what I think most folks are asking when they ask how to log something. If I do log a scrapbook flight, I prefer to keep the unoffical scrapbook items out of columns used for 61.51 entries. But I don't have the hours where it's meaningless - even insurers want to know how much dual I have received in certain makes and models, particularly those in which I have low time..

I had a friend ask me to do a FR for him some years ago in a type I never flew, so I told him he's have to teach me how to fly it first. It's recorded - maneuvers, landings, PIC time since I was rated, but the only entries in the "official" columns are the official ones. the references to my training or learning something is exclusively in the comments.

 

[USMCmech]

I guess I should add,

I would only log dual received if the other person was a CFI and actively teaching me something, and I would ask that that CFI sign my logbook. If you were just along for the ride, or not a CFI but "showing me the ropes" on a new piece of equipment then I would log it as regular PIC.

The key is to never misrepresent what was going on during any given flight. A few "dual received" entries in your log book which circumstances prevented the CFI in question from signing should be fine.



NEVER sign another person's name in any logbook under any circumstances! Missing signatures can be explained, forging someone's signature (even with their permission) will get you in serious trouble.

 

[Fly_Unity]

It would not only look funny, it would be technically wrong. In the extreme a false entry as ridiculous as that seems.

There was a common practice for years of using CFIs, not CFIIs, to work with instrument students beyond the 15 required hours. Definitely valuable for both instructor and trainee, although Everyone knew it didn't count as "instrument traininfpg" Unfortunately, someone who used to post here didn't like it and asked the FAA Chief Counsel one of "those" questions, generating this sad answer.
2010 Grayson Letter.

This was one of the few I followed up with an email to the attorney who wrote it, trying to point out what a bad idea it was if read literally. We spoke on the phone. No dice.

I know it does not change the Chief Counsel letter, but I just went through the DPE seminar in OKC, and the FAA instructors made it very clear to all the DPEs to accept applications with any dual recieved towards the instrument rating by any CFI (non CFII) as long as the CFII did the 15 required hours.

They said they received a lot of calls on this and they are telling all DPEs to accept the applications.

 

[MidlifeFlyer]

I know it does not change the Chief Counsel letter, but I just went through the DPE seminar in OKC, and the FAA instructors made it very clear to all the DPEs to accept applications with any dual recieved towards the instrument rating by any CFI (non CFII) as long as the CFII did the 15 required hours.

They said they received a lot of calls on this and they are telling all DPEs to accept the applications.

Makes sense. That 1-I are not allowed to give instrument training would not affect the fact that all the applicant's requirements were met.