Question about time in aircraft before you can instruct.

Out of curiosity, I checked the explanatory material. As far as I can tell, just about every change in this part of the rule is a "clarification" due to the number of questions asked about the requirements rather than a substantve change.
 
MidlifeFlyer said:
Out of curiosity, I checked the explanatory material. As far as I can tell, just about every change in this part of the rule is a "clarification" due to the number of questions asked about the requirements rather than a substantve change.
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Well, yes, but what they call it is irrelevant. They often use the word "clarification" as a euphemism for "let's fix a screw up", or "let's change something".

If there were a regulatory basis that only -II's can do "instrument instruction", there would have been no need for 61.195(c). If they want to forbid non -II's from providing instrument instruction, that's what the regulation should say. The "authorized instructor" is way too vague. It basically says "Only instructors who can do this sort of training are allowed to do this sort of training." Very helpful. :rolleyes:
 
Katzenjammer said:
Are people still citing Lynch?
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They are. To be fair, not everything that Lynch states is just Lynch's opinion; some of it is based on General Counsel's opinions and other stuff comes as a consensus from AFS-800. But it's not always easy to tell the difference. For the "instrument training" issues, there is some support from letters of interpretation, but it could certainly be clearer.
 
tgrayson said:
If there were a regulatory basis that only -II's can do "instrument instruction", there would have been no need for 61.195(c).
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Funny, I always thought that 61.195(c) =was= the regulatory basis for saying that only instrument instructors can do instrument instruction that counts. Keep in mind that I also accept as completely normal the idea that the FAR like laws, rule and regulations ranging from municipal codes to the US Constitution pick up interpretive glosses along the way that are just as valid as the words on the page.

I'm not focusing only the word "clarify," but am inviting a look at the whole explanation. And sometimes that "screw up" is just failing to say more clearly what they meant all the time anyway. I guess we might disagree on how to read new rules and the explanatory material that goes with them. No matter. It is what it is.
 
tgrayson said:
Since the FAA has never defined what exactly it means by "requirements", we don't have any definitive information on this. Arguably, the requirements for a rating are whatever is needed to prepare a student for checkride.

Interestingly, in the latest proposed revisions of the Part 61 regulations, the FAA wants to add the requirement that an instructor be a -II in order to provide the instrument instruction required for a Commercial Certificate. This has already been the interpretation by the FAA, but they seem to have a need to put it in the regs. This also casts doubt on the FAA interpretation that any "instrument instruction" requires a -II; otherwise, why the need for a regulation change. Anyway, I made a comment on the NPRM website that they officially define instrument instruction as something that requires a -II, since that would be in accord with the attitude of the FAA.
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i haven't looked this up yet..has this requirement been added?
 
In order not to stray too far away from the original question;
the FAR's state the minimum requirements.
You might be legal to fly any single but if you are not comfortable, don't.
As far as the 5 hrs is concerned for the MEI; I always assume the worst interpretation of the regulation.Since regs are open to interpretation by the FAA you are taking a chance if you do otherwise.
It specifically states that you need 5 hrs PIC before instructing for a rating or license.
Since you cannot guarantee that who ever you are flying with is NOT going to use this time towards training requirements you simply cannot fly with a student in a multi if you don't have 5 hrs in type.
Better yet, these 5 hrs should be used for training you in the specific make and model to prepare you for instructing.
As far as a BFR in a twin that I haven't flown before, I don't.
I feel I have no business evaluating somebody in an aircraft that I know nothing about, nothing about the systems, nothing about how it handles with an engine out.
 
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