Teaching CFI applicants

[tgrayson]

Any CFI can give instruction to someone for the CFI checkride

The FAA has said differently in the old Part 61 FAQs:

QUESTION: Our FSDO has come across a situation that seems to be a clear noncompliance issue with initial CFI training and we want to confirm our interpretation of the regulations.

§ 61.195(h) is the issue. Two local Part 61 training schools are taking the position that required training for the initial CFI can be given, in substantial part, by instructors that do not meet the two year/200 hour requirements of 61.195(h) ("senior instructors" in the local vernacular). As we read the regulation all instruction required for an initial CFI applicant has to be conducted by a CFI meeting the two-year/200 hour requirement.

Can a "junior" instructor can be used in preparing an initial CFI applicant, and if so, what limitations on their use would apply?

ANSWER: Ref. § 61.195(h)(2); NO, a “junior” instructor cannot be used.

In accordance with § 61.195(h)(2), which states in pertinent part, ". . . who provides training to an initial applicant for a flight instructor certificate must- . . . . held a flight instructor certificate for at least 24 months . . . have given at least 200 hours of flight training . . ."

The rule requires that the training resulting in the required endorsements for an initial flight instructor applicant must be given by a CFI who meets the requirements of § 61.195(h)(2). Notice that this question does not involve the requirements for an instructor serving in an FAA-approved school under § 61.195(h)(3)(ii).

 

[CoffeeIcePapers]

The rule requires that the training resulting in the required endorsements for an initial flight instructor applicant must be given by a CFI who meets the requirements of § 61.195(h)(2). Notice that this question does not involve the requirements for an instructor serving in an FAA-approved school under § 61.195(h)(3)(ii).

I think this confirms what I posted earlier. They can receive the ground training, but it wouldn't count towards the requirement for the endorsement. If they are taking their CFI checkride under part 61, there isn't a minimum amount of ground hours required. What is to stop them from getting instruction from a "junior" CFI for X amount of hours, followed by ultimately getting ANY amount of ground instruction by a 2 year CFI and receiving the endorsement from the 2 year CFI?

 

[tgrayson]

I think this confirms what I posted earlier.

I don't see how you can possibly derive that interpretation from the question and answer posted. The FSDO that posed the question explicitly asked about using a "junior" instructor and there was nothing offered to say that it was permissible in any circumstances. Had your training scenario been legitimate, it would reasonably have been mentioned in the answer. It wasn't. I cannot see how they could have made their position more clear.

What is to stop them from getting instruction from a "junior" CFI for X amount of hours, followed by ultimately getting ANY amount of ground instruction by a 2 year CFI and receiving the endorsement from the 2 year CFI?

Because it's a scam with the purpose of circumventing the intent of the regulation. Of what significance would this regulation be if junior instructors provided 20 hours of instruction, and a "Senior" instructor provided .5 hours and signed the candidate off for the checkride?

there isn't a minimum amount of ground hours required.

Or flight hours. But the answer to the question was phrased "the training resulting in the required endorsements", and didn't say "required training". If a guy gets 20 hours of instruction, then this was the instruction that resulted in the endorsement, or otherwise, the instruction would not have been given. QED.

There may be well FSDO's that don't care if this goes on. Personally, I'm not sure that a 24-month CFI is necessarily any more qualified to do the training than a 1-month CFI. Maybe less so.

Does your FSDO know and approve of this practice?

 

[CoffeeIcePapers]

I don't see how you can possibly derive that interpretation from the question and answer posted. The FSDO that posed the question explicitly asked about using a "junior" instructor and there was nothing offered to say that it was permissible in any circumstances. Had your training scenario been legitimate, it would reasonably have been mentioned in the answer. It wasn't. I cannot see how they could have made their position more clear.

I specifically bolded the part of that interpretation that you posted. It says the training resulting in the endorsements for an initial flight instructor applicant must be given by a CFI who meets the requirements of § 61.195(h)(2).

The "junior" CFI cannot give them the instruction required for the . They are not qualified to do so, as it states. It doesn't say they can't give them ground instruction or training, period.

similar, but not parallel example, would be a private pilot helping a student pilot prepare for their exam. They are not allowed to give them bona fide instruction, but they can share their experience and definitely help them prepare.

There may be well FSDO's that don't care if this goes on. Personally, I'm not sure that a 24-month CFI is necessarily any more qualified to do the training than a 1-month CFI. Maybe less so.

Does your FSDO know and approve of this practice?

I am not sure. I guess it would depend on which safety inspector I spoke to at the time. Also, why is the "old" Part 61 FAQ? From the disclaimer, it isn't official FAA opinion and is not legally binding. Do you have any court cases or anything that dealt with this matter? I am not trying to be stand-offish in any way, I would like to get a concrete answer on this that is supported by real legal opinion, instead of FSDO employees' opinion.

 

[exleardriver]

By omitting a precise number of hours of ground and flight instruction from an 'authorized instructor', the faa does appear to have inadvertently left a 'gray area' in the requirements for an initial cfi and who may provide the training. from my reading of the regs, personally, it's my belief that the intent is for a cfi meeting the 'authorization' requirements should give all of the ground/flight instruction, and that his/her endorsement reflects precisely that. i cannot envision that a fsdo would interpret otherwise. i've never given an endorsement for an instructor certificate in which i did not knowingly provide all of the required ground and flight instruction. whether or not that instruction was 'supplemented' by the actions of another instructor i am not aware. however, if they received my endorsement, they received all of the applicable /flight training requirements of 61.183, 185 & 187 from me in spite of anything else of which i was not made aware. those are the rules as i've always read and interpreted them. i've had no questions raised by faa inspectors who have given my cfi applicants checkrides. clearly, it would be easy to work around the 'intent' of this regulation were a senior instructor so inclined, but i won't do it.

 

[moxiepilot]

One of the reasons for having a two year CFI as an mentor is because of all the things you have learned. I am still picking up new bits and pieces here and there, and some of the stuff is valuable as hell - which is also knowledge I didn't have as someone with less than a few years teaching.

There may be well FSDO's that don't care if this goes on. Personally, I'm not sure that a 24-month CFI is necessarily any more qualified to do the training than a 1-month CFI. Maybe less so.

kinda surprised to hear you say this tgray- maybe i'm taking it out of context because i didn't read thoroughly enough or i am just shaking off sleep, but IMHO there is a difference between a 1 month wonder and someone with a bit more experience. why is it that you hear all the time, "you're going to learn so much as a CFI in your first 200 hours teaching?"

 

[CamYZ125]

why is it that you hear all the time, "you're going to learn so much as a CFI in your first 200 hours teaching?"

I think that you DO learn a ton in your first 200 hours of teaching, but none of it may help a new CFI applicant pass checkride. It's too bad that it seems as though everything is now training for a checkride, and not training to actually create a good pilot/instructor/whatever.

I think that a 1-month CFI would be able to provide better information for a new CFI applicant to pass a checkride, but a 2-year CFI would provide better information to make a new CFI applicant a better teacher by providing all of their real world experience and knowledge. Teaching students is nothing like a CFI checkride, at least not for me it isn't.

 

[tgrayson]

It doesn't say they can't give them ground instruction or training, period.

I guess you could create a scenario whereby a junior instructor gives 1 hour of instruction and a senior instructor gives 20 yours. In this case, the 1 hour didn't really contribute essentially to the training necessary to get the endorsement.

But that's not what you're talking about. You're talking about the bulk of the training being given by junior instructors and then getting a senior instructor to provide some token training and do the signoff. In this case, the junior instructor was clearly providing training that was needed to get the endorsements.

Where do you draw the line? Somewhat subjective, but if an FSDO saw a whole slew of CFI's being signed off after a couple of hours of training by senior CFI's, it would be clear what was going on, IMO.

private pilot helping a student pilot prepare for their exam. They are not allowed to give them bona fide instruction, but they can share their experience and definitely help them prepare.

True, but the 24-month thing is a training limitation is on CFI's, not on PPLs.

why is the "old" Part 61 FAQ? From the disclaimer, it isn't official FAA opinion and is not legally binding.

You're right, it's not a legal opinion at all, but it is reflective of the FAA interpretation of what the regulation means. Obviously one FSDO agrees with them and I know that ours does, so that makes two. And, no, I do not know of any case law over the issue.

That's why I asked what your FSDO thought. Right or wrong, they're the only ones that are likely to be able to give you grief over the issue.

 

[tgrayson]

1 month wonder and someone with a bit more experience. why is it that you hear all the time, "you're going to learn so much as a CFI in your first 200 hours teaching?"

I agree that you do, but there is a very limited ability to communicate one's own experience to another in any useful fashion. This is why 18-year-olds keep making the mistakes that 70-year-olds warned them about. Realistically, the Flight Instructor checkride rewards rote memorization. A 1-month wonder, fresh from his own checkride, is probably on top of that stuff.

I wasted enormous amounts of time trying to give CFI candidates a deeper understanding of issues I thought important and, in the end, did not succeed, while diverting their attention from the memorization of facts.

 

[exleardriver]

I wasted enormous amounts of time trying to give CFI candidates a deeper understanding of issues I thought important and, in the end, did not succeed, while diverting their attention from the memorization of facts.

i hear that. it is arguably difficult for them though not to worry about all the minutia. how i've dealt with it typically is to help them pass the checkride and then mentor once they begin for that 'deeper understanding' and 'big picture', etc. :bandit:

 

[tgrayson]

how i've dealt with it typically is to help them pass the checkride and then mentor once they begin for that 'deeper understanding' and 'big picture', etc.

Yep, I think that's the best approach.