Required 5 hours of instrument training

minds_warped

minds_warped

New Member
I'm a CFI and MEI, still working on my CFII. I have a commercial multi student, however I'm not sure if I can give the minimum 5 hours multi instrument instruction that is required under 61.129 (b)(3)(i). Can my student log that as instrument training, or does he need a CFII to do it?
 
Ed is absolutely right. The reason is that 61.129(b)(3)(I) uses the phrase "instrument training." An "instrument training" requirement always requires a double-I.

Notice how the private pilot hood requirement uses "flight solely by reference to instruments" instead of "instrument training." That's the difference.

But wait! Does your commercial student already have his single engine instrument rating? If so, he doesn't need those 10 hours.
 
Yeah you can give the instruction. The instrument instruction only needs to be from a CFII for the instrument rating
 
A lowly CFI can't even give the instrument training needed for the Wings program.... as said, the difference is 'instrument training' vs 'flight solely by reference to instruments'.
 
[ QUOTE ]

But wait! Does your commercial student already have his single engine instrument rating? If so, he doesn't need those 10 hours.

[/ QUOTE ]Too late to just edit this one, but since we're talking about multis (I was looking at the single engine rule), let's make that last part

But wait! Does your commercial student already have his multi engine instrument rating? If so, he doesn't need those 5 hours.
 
I asked the question in my flight instructor refresher clinic today. CFI's can give instrument instruction required for the private, commercial or wings. It wouldn't make much sense (not that the FAA always makes sense) for a private student to have to fly a CFII for 3 hours just to learn BASIC instrument skills.
 
[ QUOTE ]
I asked the question in my flight instructor refresher clinic today. CFI's can give instrument instruction required for the private, commercial or wings.

[/ QUOTE ]If they actually said that, they are wrong. (Except that there is no "instrument instruction" required for the private).[ QUOTE ]
It wouldn't make much sense (not that the FAA always makes sense) for a private student to have to fly a CFII for 3 hours just to learn BASIC instrument skills.

[/ QUOTE ]You're right. It wouldn't. And a CFI can give this instruction because it's =not= "instrument training". It's instruction in "flight solely by reference to the instruments."
 
I've always thought that a CFI could do the Private instrument flight requirement.

However, This is REALLY close to interpretation of semantics...Call me crazy, but with the wording being this muddy, wouldn't it just make sense to call someone at the FSDO for an interpretation?

I wouldn't want to screw up a student here...
 
A CFI can give the 5 hrs of instrument training. The FAA considers this to be very basic instrument flight, only to the point where a non-instrument rated pilot could turn around, climb, or descend to escape IMC conditions. A CFII is not required for these 5 hours.
 
[ QUOTE ]
I've always thought that a CFI could do the Private instrument flight requirement.

[/ QUOTE ]You always thought correctly. The difference with the private and the others is that the FAA doesn't call it "instrument training".

For example, compare the instrument requirements for the private with the ones for the commercial and you will see the difference. The private one says, "flight training ... on the control and maneuvering of an airplane solely by reference to instruments" which can be done by a CFI. The commercial one uses the magic words "instrument training" or "instrument instruction", which requires a CFII.

And it's not "muddy" at all. The FAA has been making the distinction between the two for a long time. Here's a blurb from a 25 year old FAA Legal opinion

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Since Section 61.65(e)(2) refers to "instrument instruction" by an authorized instructor, the instructor must have an instrument instruction rating. Section 61.107 refers to "instruction from an authorized instructor" and to "control and maneuvering an airplane solely by reference to instruments," rather than to "instrument instruction;" therefore, any certificated flight instructor (CFI) may give the type of instruction described in FAR 61.107.
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The people who say you need a CFII bring up interesting and most likely valid points. Especially with the FAA legal intepretation letter.

I would like to bring up FAR 61.195 (c). It would seem to me that since this is not instruction for the "issuance of an instrument rating" a MEI without a CFII could give the instruction. I guess it comes down to if the FAA considers "instrument priviliages on a ME certificate" an "instrument rating" (assuming the student already has a Comm. Instrument rating (single or ME)).

Anyway, for giggles and grins I called the ORL FSDO and they didn't immediately know the answer. I am waiting for one of the OPS inspectors to call me back. I also emailed the SC FSDO because I did an internship there and asked for their input. When they contact me back I'll post their response.

Regulation discussions are always interesting.
 
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