Teaching in a Multi with no MEI

[Roger, Roger]

And a CFI-A is more qualified, in a real sense, to teach in that aircraft than a CPL-A ? I don't buy that.

I'm not sure what you're saying here. I do believe that someone who is a CFI-AMEL is more qualified to teach in a multi (whether they're teaching instrument or not) than a CFI-ASEL/C-AMEL. Maybe I'm inflating the value of CFI-AMEL training though.

 

[tgrayson]

Maybe I'm inflating the value of CFI-AMEL training though.

It surely depends on the training received, but an MEI add-on to a FI certificate is often less than 5 hours training, mostly just doing the multi-stuff from the right seat. And the training is often given by another low-time flight instructor, who is probably giving away his instructional time as a courtesy and to log the ME time. I don't see a lot of instructional value in that, although the extra ME time doesn't hurt.

 

[Roger, Roger]

It surely depends on the training received, but an MEI add-on to a FI certificate is often less than 5 hours training, mostly just doing the multi-stuff from the right seat. And the training is often given by another low-time flight instructor, who is probably giving away his instructional time as a courtesy and to log the ME time. I don't see a lot of instructional value in that, although the extra ME time doesn't hurt.

The same thing could be said of the pump-em-through CFII initials that are teaching in airplanes with no category rating.

 

[tgrayson]

The same thing could be said of the pump-em-through CFII initials that are teaching in airplanes with no category rating.

Absolutely. That's why I don't associate ratings with being "qualified". The only student I ever had who produced an inadvertent Vmc roll off was already an MEI.

 

[nosehair]

I don't associate ratings with being "qualified".

..aah, now I understand your madness. I understand it, but let's take that to extreme and say any instruction beyond solo is worthless. Let's just don't have any "qualifications", let's just trust that every individual will, of course, get whatever training that person needs to be safe and proficient at the job, but throw out the "rating" system.
I agree. I think that's the way it should be. But do you really think most of us can do that?

 

[nosehair]

I think the question is close enough that there's not a clear "right" and "wrong" and it's a matter of opinion with the only one ultimately counting being the FAA's

...and here is where the "legal" dissection of a regulation can actually be an underlying cause of a compromise in safety.
You interject a "legal" doubt of intent by your logic that teaching the instruments of a single-engine airplane is essentially the same as a ME. You offer arguments to win the "legal" case, ignoring the "obvious" that would be expected of any CFI, that he/she would be qualified in the aircraft cat and class. I say "obvious" because that would be an assumption of any student, or person on the street. The debate about this is only amongst those of us trying to build ME time.

Of course, if the CFI-IASE makes him/herself proficient on the ME drill, he/she is as good as the one who demonstrated it to the FAA, but the danger is in the innocent children who believe, or are made to believe by our sales staff and the promos, that meeting minimums and squeaking through loopholes and perverse "interpretations" is good enough to make them proficient.

CFI's are not just monkeys teaching monkeys to fly. We have a duty to uphold a principle and apply the interpretation that best serves safety and proficiency, not the seeking the "minimum way".

 

[MidlifeFlyer]

...and here is where the "legal" dissection of a regulation can actually be an underlying cause of a compromise in safety.
You interject a "legal" doubt of intent by your logic that teaching the

You may have misunderstood. But that's okay - it seems to be a modern American mental disability to automatically associate understanding of another's viewpoint with an endorsement of it. Good thing it doesn't preclude getting a medical certificate,

To the extent that the analysis is that both positions are supported by regulation and it's history? Well guess what? If you haven't noticed before, =all= of this - every time you step foot in a airplane - is covered by regulation. And instrument flight is covered by even more regulation than visual flight. Go figure!

Back to the "understandmeansupportitis" disease. My personal view on the "legal" question is that the language of 61.195(b) has always required that an instructor teaching in an aircraft have the applicable instructor ratings for the aircraft and that 61.195(c) is not an exception to 61.195(b).

IOW - that in order to teach instruments in a multii, the CFI must have both IA and AME ratings on her CFI certificate. Nut like your, my opion on what it says doesn't matter.

 

[tgrayson]

apply the interpretation that best serves safety

Another name for that is "lying". You don't need to alter your interpretation to accommodate your own beliefs; you're perfectly free to affirm that the regulation means "X", but you have higher standards.

I'm ok with either interpretation of the regulations, but I already have an MEI, so it doesn't matter much to me personally.

 

[germb747]

Airline Transport Pilots have the ability to provide certain kinds of instruction at their jobs without a CFI or MEI, but obviously can't sign people off for certificates, ratings, solo, etc. In this case, though, I'd say just get the MEI; problem solved.

Someone mentioned that it was only about 5 hours of training. The only caveat to that is that you have to have so many hours as PIC time in multiengine airplanes (when I did it, it was 15 hours, not sure if that's in the new Part 61). So you could be ready for the checkride long before you have enough multi PIC time.

 

[nosehair]

Nut like your, my opion on what it says doesn't matter.

Your opinion does matter. That's my point. You are intelligent. What you say is important. Students listen to you. Other, less experienced and trained individuals, are going to form an opinion on what you say and do.

Some regs are black and white. Some others are not. In the case of the CFI-ASE with IA rating but no MEI, giving instrument dual to a ME rated pilot, the interpretation was warped by poor wording in the reg.
Do you think it enhances safety to go along with the lemmings and say it is legal when the case can be made that it is not? We are mentors of flying proficiency, not legal sharpies who get the big bucks by finding the loophole that allows unsafe practice.

Let's get out of the 'legal viewpoint' for a moment. A sharp CFI-ASE can use the interpretation to his advantage and get ME time and not compromise safety. I go along with that. Not having the MEI is not a problem for the guy who is staying on top of himself and his student.

...but, the guy who is not prepared or unable to handle the engine out on take-off with the student sitting like a log waiting for the INSTRUCTOR to take over, ..what? It is not a good deal. They make it bad for all of us. This is the guy you have to protect.

You say you go along with the idea that the CFI should have the MEI, but you push forward the idea that the regulation allowed the SE CFI to give instrument flight instruction in a ME. The MEI is clearly required now, but the old reg said:
61.195(b) "A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:
(1) A pilot certificate with the applicable category and class ratings."

61.195(c) "A flight instructor who provides instrument flight training...must hold an instrument rating on his/her flight instructor certificate that is appropriate to the category and class of aircraft in which instrument training is provided."

That seems pretty clear to me. I know how the wording can be confused by the fact that you interpret the double-eye is not specific to class, but when you put these regs together, and read the last part of (c), "appropriate to the cat and class, the intent seems clear.

There is where we must hold to the interpretation that best serves the intent of the rule. Of course, that isn't always possible, but in this case, I say it is pretty obvious to the experienced instructor's eye, or even a newbie off the street.

These part 61 regs are not a high priority with the FAA. Statistically, they probably don't matter much. Look how long it took them to correct the AGI/IGI error. The FAA is overloaded with Part 91, 121, 135, etc. errors that cause a much quicker danger zone. FAA inspectors and rule writers are mostly from a 121 or military background, and have very little experience working part 61. So it gets little attention.

I see it, and I know you see it also, that there are many 'admin errors' in part 61 regs, so I say it is up to instructors, like you and tgray, to push forward the intent of the reg rather that the technical possibility of an interpretation that encourages unsafe practice.

 

[tgrayson]

you and tgray, to push forward the intent of the reg rather that the technical possibility of an interpretation that encourages unsafe practice.

I don't think the practice unsafe. Nor do I accept your view of what the "intent" of the regulation is; you seem to have a tendency to assume that the intent of regulations are in line with the way you think the law ought to be.

 

[Blackhawk]

Looking at the FAA's clarification on their final rule is even more confusing.

"This revision of § 61.195(c) establishes the flight instructor qualifications for
providing instrument training in-flight at the commercial pilot and ATP certification levels."
It further states:

" This final rule revises § 61.195(c) to establish that a flight instructor who provides instrument training required at the commercial pilot and airline transport pilot certification levels must hold an instrument rating on both his/her pilot and flight instructor certificates that are appropriate to the category and class of aircraft in which instrument training is being provided...​

The FAA has always made a distinction between the instructor qualifications for
flight instructors who provide private pilot training of maneuvering an aircraft “solely by
reference to instruments, including straight and level flight, constant airspeed climbs, and
descents, turns to a heading, recovery from unusual flight attitudes, radio communications,
and the use of navigation systems/facilities and radar services appropriate to instrument
flight” as opposed to the more advanced instrument training required for commercial pilot
certification. A flight instructor without an instrument rating on his/her flight instructor
certificate may provide this training for private pilot certification. However, the more
advanced instrument training required for commercial pilot certification requires a flight
instructor who holds a flight instructor certificate with the instrument qualification. We do
not find any reason to change this policy. Therefore, the FAA is adopting the revision as
proposed in the NPRM....
We have reviewed the rule text language in § 61.195(c) in response to the question of
whether our change now requires an instrument rating on the aircraft category and class
rating of the flight instructor certificate. In § 61.5(c)(4), the rule is clear that the instrument
rating on the flight instructor certificate relates to the aircraft category rating, and is not
issued to the aircraft class rating. The phrase in § 61.195(c) that states “that is appropriate to
the category and class of aircraft for the training provided” applies to the category and class
of aircraft on the flight instructor holder’s pilot certificate. The phrase in § 61.195(c) that
states “that is appropriate to the category … of aircraft for the training provided” applies to
the category of aircraft on the flight instructor holder’s instrument rating and flight instructor
certificate. The commenter was correct that the instrument rating is only associated with the
aircraft category rating on a flight instructor certificate. However, to ensure that the flight
instructor holds the appropriate instrument rating or instrument privileges on both his/her
pilot certificate and flight instructor certificate, we believe this was the most appropriate way​

to write this rule...

In accordance with § 61.195(b)(1), a flight instructor who does not hold the
appropriate airplane multiengine rating on his/her flight instructor certificate and the
appropriate airplane category multiengine class rating on his/her pilot certificate may not
conduct instrument training in a multiengine airplane unless that flight instructor holds the
appropriate airplane category multiengine class rating on his/her pilot certificate and flight
instructor certificate. A flight instructor who only holds a flight instructor certificate with an
Instrument-Airplane rating and no airplane category multiengine class rating on his/her pilot
certificate may not conduct instrument training in a multiengine airplane. The commenter’s​

understanding is wrong."
Huh? The regulation states:
"(c) Instrument Rating. A flight instructor who provides instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates must hold an instrument rating on his or her pilot certificate and flight instructor certificate that is appropriate to the category and class of aircraft used for the training provided." (My emphasis).
What's the joke about the FAA rewriting the FARs if someone actually understands it? Why can't they just write what they mean??

 

[MidlifeFlyer]

I see it, and I know you see it also, that there are many 'admin errors' in part 61 regs, so I say it is up to instructors, like you and tgray, to push forward the intent of the reg rather that the technical possibility of an interpretation that encourages unsafe practice.

There are indeed errors. But I generally accept the idea that the FAA, not I, get to decide what the regs mean.

I can recognize the legal is not necessarily equal to safe. I can encourage what I consider safe practices in my students eve if the official rules allow for a lot less. I can recognize that that doing 3 takeoffs and landings to a full stop tonight does not make a pilot safe to take his family on an overnight trip.

I can also recognize that a 250-hour CFI-IA with no CFI airplane rating at all should limit his probably limit his teaching to a sim while still recognizing that 2000-hour CFI-ASE/II with 5000 of multi time as a Part 135 solo cargo driver just might be competent to teach instruments in a multi.

I can also recognize that none of those give me the right to say that the regs have to say what I want them to say and that my interpretation of the "intent" of the regs, even if relevant, is absolutely, positively correct.

 

[nosehair]

you seem to have a tendency to assume that the intent of regulations are in line with the way you think the law ought to be.

Naa, just old school, that's all. I really cannot quote the regs that existed 40 years ago, but in all my experience until 10 or 15 years ago was that the MEI was, of course, required to teach any flight training in a multi, and that was all good, it was expected.

Then, some one saw the apparent glitch in that an IR or II is not class specific, so they read the reg without the obvious understanding that the MEI still stands. The clumsy wording, "appropriate to ..class" has caused the understanding or meaning of the reg to devolve to the way it was before, I think, 1974 when the CFI was not class or IR specific. A CFI-A was cat specific only. The CFI-A could teach instruments or multi, if and when he got a IR or a ME on his Commercial.

So..in 1974 when they changed to requiring a class and II on the CFI, it seemed a logical jump that teaching IR in a multi would require both ratings on the CFI.

Further, 61.185(b)"A flight instructor may not conduct any flight training in any aircraft for which the flight instructor does not hold:
(1) A pilot cert and a flight instructor certificate with the appropriate cat and class rating."

(c) says the same about instrument instruction, using the "appropriate to cat and class" wording.

So, it seems to me that someone reads that "any flight training" in (b)(1) is not instrument flight training. Not me, but whoever wanted to do IR in multi without multi CFI, that seems to be the aberration, so that makes it easier to see a conflict in (c) with the "appropriate to class" wording.

"(c) Instrument Rating. A flight instructor who provides instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates must hold an instrument rating on his or her pilot certificate and flight instructor certificate that is appropriate to the category and class of aircraft used for the training provided."

"must hold an IR on his..CFI..that is appropriate to the cat and class."

I can understand the desire to see the reg in the light of not having a MEI by a person who has not seen the evolvement, and has the opportunity to teach IR in a multi to build time. I might see it that way myself in a different time, but, as I said to Mark, it is our responsibility to at least lean towards the safer practice when there is an obvious mis-wording or mis-understanding in the regulations.

Yep, that's old school. That means that the instructor is mentor, not just a black-and-white applicator of rigid rules. That's the job of the FAA. They will tell you that. They are limited to a strict legal interpretation and enforcement. They, by federal law, cannot suggest an interpretation, or a technique that will comply with the reg or rule, they are commanded to stay silent and only require enforcement. The fact that some of the regs are mis-leading or downright wrongly written cannot be stated by any federal person or document because of the liability.

That's one of the reasons why they are usually so sour faced. Even when they know what the reg is trying to say, or how you should go about complying, they are not allowed to say it. Because somebody will get it wrong, and then some sharpie will find a way to sue the govt for billions of dollars.

But the FAA does say that flight instructors are the ones who apply the rules and are responsible for the overall safety and effectiveness of our flight training system.

That's all I'm trying to do, here, tgray, carry forward the professionalism of the job.

You say you don't consider teaching IR in a multi w/o the MEI is dangerous.

Of course, that depends solely on the individual. But, as I already said, that logic applies to all certs and ratings.

I agree - just having a rating does not mean proficiency. Why require an IR? or a PP?

Why not train to solo X/C and just let'em go?

Same reason I, and most folks, would agree that at least one demonstrated flight of ME proficiency is better that nothing when you know nothing of the instructor.





.

 

[nosehair]

I'm ok with either interpretation of the regulations, but I already have an MEI, so it doesn't matter much to me personally.

Ahh, OK, it doesn't matter to you personally. Never mind.

 

[nosehair]

I can recognize the legal is not necessarily equal to safe. I can encourage what I consider safe practices in my students eve if the official rules allow for a lot less. I can recognize that that doing 3 takeoffs and landings to a full stop tonight does not make a pilot safe to take his family on an overnight trip.

Different situation. 3 t.o.& ldgs is black-and-white. No real controversy for you, as instructor, to help a student understand.

I can also recognize that a 250-hour CFI-IA with no CFI airplane rating at all should limit his probably limit his teaching to a sim while still recognizing that 2000-hour CFI-ASE/II with 5000 of multi time as a Part 135 solo cargo driver just might be competent to teach instruments in a multi.

Good analogy, and is the root cause of the various interpretations. In most cases this might be ok, however, I have flown with many 'high-time' multi drivers, who have only done 1 (or less) engine cut on T.O., and that was a routine expected drill, in the past year or longer. Multi drivers are the worst at staying proficient in maneuvers.

I can also recognize that none of those give me the right to say that the regs have to say what I want them to say and that my interpretation of the "intent" of the regs, even if relevant, is absolutely, positively correct.

The intent of the regulations is pretty well explained in the pre-amble. I cannot get to the pre-amble of the change in 1974, but somehow, that has always been my interpretation, supported by the regulation as explained in the pre-amble.

Without being able to show that, or refer to it, of course you guys think I'm just whistling Dixie, but my root thinking comes from my background, not my personal agenda.

But, I do take it all personally. What I mean is that I take the job of promoting safe proficient flight training personally.

Every teacher or instructor you ever had that was good took the job personally. He/She intended that you would be the best that you could be, and you got that.

He/She promoted the best practice in all endeavors. When there were confusing rules, as there always are, He/She promoted what He/She thought was best; and you got that, too, didn't you?

I'm just sayin' - BE an instructor, not just a disseminater of technical knowledge. It's not the same, you know?

 

[MidlifeFlyer]

I'm just sayin' - BE an instructor, not just a disseminater of technical knowledge. It's not the same, you know?

Of course it's not.

But recognizing that the regs are only a starting point, you also need to explain the regs to your students as they are (which means as the FAA has interpreted them) and not as you wish they were. They, go right ahead and tell your student why you think they are insufficient or downright wrong.

 

[nosehair]

Of course it's not.

But recognizing that the regs are only a starting point, you also need to explain the regs to your students as they are (which means as the FAA has interpreted them) and not as you wish they were. They, go right ahead and tell your student why you think they are insufficient or downright wrong.

Oh, yeah. That is an automatic. Sorry if I gave anyone the impression that I only say to students what I think is right on a controversial reg, rule, or recommended procedure. I always use the reg as a starting point with as much background as I can, just as I have attempted to do here. I teach responsibility for self (PIC 91.3) throughout all the rules and regs.

This thread is focused on making an intelligent decision when confronted with a reg, rule, or procedure in which there is controversy even within the FAA. That is all an integral part of flight training which is usually left undone in most schools, probably due to the same reason the FAA cannot admit mistakes or "go rogue"; they have deep pockets to attract the whiners who consistently blame others for their own faults, and routinely attempt to sue.

...and I can understand all that financial/liability issue that a govt or business has to protect itself from such vultures, but that...is not about education. That may factor in as part of the explanation in why the rule is in controversy, but money, liability, individual school policies, etc., do not enter the picture when initially teaching or considering what to teach.

As those factors impose themselves, of course, I deal with and explain, according to my personal experience, to each individual student as they occur. I try to do this so that the student knows what I believe is the correct interpretation, but he/she is aware of other possible interpretations. (91.103 all available information) If I didn't do that, he/she would eventually find out, then he/she would see me as an old fart who is way behind the times and teaching in his own world.

 

[MidlifeFlyer]

This thread is focused on making an intelligent decision when confronted with a reg, rule, or procedure in which there is controversy even within the FAA. That is all an integral part of flight training which is usually left undone in most schools, probably due to the same reason the FAA cannot admit mistakes or "go rogue"; they have deep pockets to attract the whiners who consistently blame others for their own faults, and routinely attempt to sue.

Just an FYI. The The federal government can only be sued in those areas in which it has given permission to allow itself to be sued. Practically speaking, that means for operational errors (which is how ATC gets sued in accidents) but not on policy decisions. Yes, clever lawyers come up with ways to try to fir into "operational" but 'taint easy.

 

[nosehair]

The federal government can only be sued in those areas in which it has given permission to allow itself to be sued.

That's technically true, but "practically speaking", the whiners who consistently sue will still start the process, so that the sue-ee has to arm a defense, still costing time and money and aggravation and maybe a "settlement".