Company Flight Instructor

moxiepilot

moxiepilot

Well-Known Member
I don't have my FARs over here in Afghanistan & I haven't found the answer on the online version, so if anyone can point me in the right direction I'd appreciate it.

Another instructor and I were discussing today the role of company designated flight instructors. If an instructor is designated as a company flight instructor (not part 121 or 135) in a multi engine aircraft that is single pilot type rated (King Air 350 for example) can that instructor:

1. Log that time as instructor if they are not an MEI?
2. Log that time as instructor if they hold ATP in that category, class & type?

The two sides of the discussion evolved:
- if an instructor is not certified as an MEI then they are not able to log the instruction as such - (61.193)
- if an instructor is an ATP, then 61.167 might apply depending on how you interpret "Air Transportation." But I think 61.167 A(2)(iii) overrules that anyhow if the instructor is only an ATP type rated but a CFI/CFII (not MEI)

Beyond that I haven't been able to locate and FARs which directly reference company flight instructors.

Any help?

@MidlifeFlyer
@jskibo
@mshunter
 
Hope this helps.

Sec. 61.167

Airline transport pilot privileges and limitations.

(a) Privileges.


  • (1) A person who holds an airline transport pilot certificate is entitled to the same privileges as a person who holds a commercial pilot certificate with an instrument rating.

    (2) A person who holds an airline transport pilot certificate and has met the aeronautical experience requirements of § 61.159 or § 61.161, and the age requirements of § 61.153(a)(1) of this part may instruct—


    • (i) Other pilots in air transportation service in aircraft of the category, class, and type, as applicable, for which the airline transport pilot is rated and endorse the logbook or other training record of the person to whom training has been given;
      (ii) In flight simulators, and flight training devices representing the aircraft referenced in paragraph (a)(2)(i) of this section, when instructing under the provisions of this section and endorse the logbook or other training record of the person to whom training has been given;

      (iii) Only as provided in this section, except that an airline transport pilot who also holds a flight instructor certificate can exercise the instructor privileges under subpart H of this part for which he or she is rated; and

      (iv) In an aircraft, only if the aircraft has functioning dual controls, when instructing under the provisions of this section.

    (3) Excluding briefings and debriefings, an airline transport pilot may not instruct in aircraft, flight simulators, and flight training devices under this section—


    • (i) For more than 8 hours in any 24-consecutive-hour period; or
      (ii) For more than 36 hours in any 7-consecutive-day period.

    (4) An airline transport pilot may not instruct in Category II or Category III operations unless he or she has been trained and successfully tested under Category II or Category III operations, as applicable.

(b) Limitations. A person who holds an airline transport pilot certificate and has not satisfied the age requirement of § 61.153(a)(1) and the aeronautical experience requirements of § 61.159 may not:


I believe the key words here are Category, Class and TYPE for which the ATP is rated. If the aircraft you are instructing in does not require a type rating, then an instructor certificate would be required. If you are instructing per this section, then logging instruction time would be appropriate.
 
Pretty sure if you have an ATP, you can log it. But I honestly never really thought about it. I have all my I'd, so it was never an issue for me.

But it's early, and I'm at the school house for the next few days, so I'd honestly have to look at the regs for a bit.
 
@moxiepilot, I am only aware of two situations in which the FAA considers an U.S. instructor to be an "authorized" instructor who may endorse training for another pilot and log it for themselves. If there is a third, I never heard of it.
  • The basic 61.193 authorization requiring a CFI with applicable aircraft and instrument ratings.
  • 61.167 which only authorizes an ATP who is a participant in an air carrier's approved training program to instruct pilots who are also participants in the air carrier's training program. That's how the FAA has interpreted the "in air transportation" language. IOW, bot the ATP and the "student" must be participants in a carrier's Part 135 or 121 training program. See the 2010 Creech interpretation.
 
Thanks, that's what I thought too. Because we are engaged in flight in Afghanistan for purposes other than "air transportation" (121/135 ops) then an ATP typed pilot cannot necessarily log instruction given as a company pilot if they don't hold an MEI. I think the reason some think they can is because the 350 is a single pilot type rated plane. So they can teach our mission to the new guy since the new guy is type rated. But it's not loggable instruction without the MEI.
 
moxiepilot said:
Thanks, that's what I thought too. Because we are engaged in flight in Afghanistan for purposes other than "air transportation" (121/135 ops) then an ATP typed pilot cannot necessarily log instruction given as a company pilot if they don't hold an MEI. I think the reason some think they can is because the 350 is a single pilot type rated plane. So they can teach our mission to the new guy since the new guy is type rated. But it's not loggable instruction without the MEI.
Click to expand...

Do all of your new pilots get the SIC required restriction removed? If they still have the restriction, you can't operate the 350 single pilot, so maybe the training pilot can log SIC while the other guy logs PIC.
 
The 350 is a Single pilot typed aircraft, but company op specs require two pilots. So both pilots are qualified to act as PIC. The "training" aspect is to teach a new hire the mission flight and other associated stuff, not what I consider "flight training" (although some of them need flight training...)

I suppose the follow up question is:

Can an instructor (CFI/CFII) log dual given in a multi engine aircraft to a pilot rated in the aircraft?
 
Last edited:
moxiepilot said:
The 350 is a Single pilot typed aircraft, but company op specs require two pilots. So both pilots are qualified to act as PIC. The "training" aspect is to teach a new hire the mission flight and other associated stuff, not what I consider "flight training" (although some of them need flight training...)

I suppose the follow up question is:

Can an instructor (CFI/CFII) log dual given in a multi engine aircraft to a pilot rated in the aircraft?
Click to expand...
I'm not sure what you are asking. It sounds like you are asking whether flight instruction is not flight instruction when the student is a rated pilot. That would mean a flight review is not flight instruction, recurrent training is not flight instruction, instrument training is not flight instruction, transition training is not flight instruction...
 
MidlifeFlyer said:
I'm not sure what you are asking. It sounds like you are asking whether flight instruction is not flight instruction when the student is a rated pilot. That would mean a flight review is not flight instruction, recurrent training is not flight instruction, instrument training is not flight instruction, transition training is not flight instruction...
Click to expand...
In a way I guess that's exactly what I'm asking. When you have a non-MEI in a multi-engine aircraft that is single pilot rated, no matter what it's called I believe the time cannot be logged as dual given; the company instructor is not multi-engine instructor rated - therefore 61.167 A(2)(iii) and the Creech interpretation apply.

Is the logic sound?
 
moxiepilot said:
In a way I guess that's exactly what I'm asking. When you have a non-MEI in a multi-engine aircraft that is single pilot rated, no matter what it's called I believe the time cannot be logged as dual given; the company instructor is not multi-engine instructor rated - therefore 61.167 A(2)(iii) and the Creech interpretation apply.

Is the logic sound?
Click to expand...
If the other pilot is not an MEI, it is not dual given from an FAR standpoint if it is in a multi. At one time, it was possible for a CFII with a commercial AME to give instrument training in a multi but that went away in, as I recall, 2009.
 
moxiepilot said:
I don't have my FARs over here in Afghanistan & I haven't found the answer on the online version, so if anyone can point me in the right direction I'd appreciate it.

Another instructor and I were discussing today the role of company designated flight instructors. If an instructor is designated as a company flight instructor (not part 121 or 135) in a multi engine aircraft that is single pilot type rated (King Air 350 for example) can that instructor:

1. Log that time as instructor if they are not an MEI?
2. Log that time as instructor if they hold ATP in that category, class & type?

The two sides of the discussion evolved:
- if an instructor is not certified as an MEI then they are not able to log the instruction as such - (61.193)
- if an instructor is an ATP, then 61.167 might apply depending on how you interpret "Air Transportation." But I think 61.167 A(2)(iii) overrules that anyhow if the instructor is only an ATP type rated but a CFI/CFII (not MEI)

Beyond that I haven't been able to locate and FARs which directly reference company flight instructors.

Any help?

@MidlifeFlyer
@jskibo
@mshunter
Click to expand...

As a side note, I would not rely on paper versions of the FAR/AIM unless you have a subscription, such as the Jepp version (if they still make it). Any hard bound paper version you have is out of date the day you purchase it. As an example, if you look at any hard bound 2016 FAR/AIM it was probably printed in August 2015. Do you really want to rely on it in December 2016?
 
Okay, so I dug in, and asked a DPE I used to use as a flight instructor. From what he told me, as long as it's not a revenue flight, the instructor holds the appropriate certificates, in this case an MEI and a type, they can log it.

If they aren't an MEI, they would have to be designated under the company as an approved instructor. I can see that this stuff has pretty much already been answered, so it's just water under the bridge now. But in simple terms, you'd have to be a designated IP.
 
A KA350 is a two pilot airplane if

The PIC has a limitation that says SIC required.

Or

The airplane is operated without the required equipment for single pilot ops listed in the KOEL in the POH.

That's all I'll add to this
 
mshunter said:
If they aren't an MEI, they would have to be designated under the company as an approved instructor. I can see that this stuff has pretty much already been answered, so it's just water under the bridge now. But in simple terms, you'd have to be a designated IP.
Click to expand...

And this is the exact question I'm trying to get answered, so thank you for adding to the discussion. The non-MEI, type rated pilots are company approved instructors/IP. However in Afghanistan, we aren't doing 121/135 ops. Would you mind going back to your DPE to ask for the reference of his interpretation?
 
moxiepilot said:
And this is the exact question I'm trying to get answered, so thank you for adding to the discussion. The non-MEI, type rated pilots are company approved instructors/IP. However in Afghanistan, we aren't doing 121/135 ops. Would you mind going back to your DPE to ask for the reference of his interpretation?
Click to expand...

I'll ask. It's going to be a few days. I start a trip tomorrow. But from the sounds of it, if it's some kind of FAA approved OpSpec, you can log it. Thing is, someone has to be the PIC. Do these guys already have the type, and your just doing some kind of familiarization flight?
 
No rush, since there's nothing to do out here but create drama and stir the pot. >:)

Both pilots are type rated and current. And yes it's familiarization flight of the mission over about 10 flights.
 
moxiepilot said:
No rush, since there's nothing to do out here but create drama and stir the pot. >:)

Both pilots are type rated and current. And yes it's familiarization flight of the mission over about 10 flights.
Click to expand...

To clarify- it's a part 135 company, but you're not flying part 135 Ops during these training flights? If not part 135, what part does it fall under?
 
moxiepilot said:
No it's not 135 company, refer to post #14 for clarification.
Click to expand...

It looks like some of the companies doing that flying advertise they're part 135 on their websites hence the confusion. Thanks for the clarification. Are all of the companies non-135 or is it company dependent?
 
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