Can A CFI give an Instrument Proficiency Check in multi

10 Answers

1. 
   

   
   

   Mark Kolber on Mar 01, 2013

   No.

   Depending on who you spoke to, it was an accepted practice in the past. It’s an area in which there have been disagreements within the FAA. Since at least 2004, various arms of the FAA legal office have said “no.” FSIMS and its predecessor specifically said “yes.” John Lynch, the author of the orphaned “Part 61 FAQ” said “yes” in the FAQ but, shortly before his retirement indicated he thought the answer might be “no.” I even know of one CFI who was brought up on enforcement charges because of it; it was dropped because so many FAA documents said it was ok.

   Finally, in 2009, the FAA made a very minor revision to 61.195(c) and followed it up with a Chief Counsel opinion letter, to finally lay the issue to rest. http://tinyurl.com/847avyh

   Bottom line: in order to act as an authorized instructor in an aircraft, one must have the appropriate aircraft rating on his or her CFI certificate.

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2. 
   

   
   

   Mark Kolber on Mar 01, 2013

   “along the same lines,” also no. That’s never been an accepted practice. The only regulator disagreement was about instrument training, never aircraft training.

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3. 
   

   
   

   Kris Kortokrax on Mar 01, 2013

   Based upon the wording in the regulation (61.195) and the interpretation (which address only “flight training”), I would say yes to the IPC. An IPC is a check, it does not consist of “flight training” and “ground training” as a Flight Review does.

   Ms. Moore who authored the interpretation is not very well informed. She overlooks obvious examples of situations where an individual who is not an authorized instructor under 61.1(b)(2) and also blessed by her interpretation of 61.195 (a) & (b), may give creditable instrument flight instruction toward the issuance of a Commercial, ATP, type rating or instrument rating.

   She overlooks the fact that there is no instruction requirement for an ATP unless one fails the first attempt.

   If I only hold a CFII and have a Commercial or ATP with ASEL & AMEL and I am an instructor for a Part 135 Air Carrier, I can give all training toward an ATP or type rating. I can give the training even if I do not possess the CFII.

   If I am a military instructor, I can give instruction to a military pilot, who once qualified by the military can be granted an FAA Commercial and Instrument rating per 61.73

   If I am an instructor in a foreign country (ICAO member state), I may give instruction that will count toward a pilot certificate or instrument rating.

   This is the problem with having FAA attorneys, cloistered in Washington DC who are not pilots, issue interpretations which affect the pilot population.

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4. 
   

   
   

   Mark Kolber on Mar 01, 2013

   Kris, you’re obviously entitled to that opinion but I think that the FAA has been pretty consistent that an instructor providing endorsements is acting in a “training” capacity. or are you also saying that a CFI without an instrument rating can also give an IPC? After all, as you said, it’s not “instruction.”

   It’s an old argument, but I don’t think this one shows a lack of knowledge by the author of the opinion. It doesn’t seem particularly weird to me to require someone acting in an instructional capacity in an aircraft to have an instructor rating for that aircraft.

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5. 
   

   
   

   Jonathan Seitz on Mar 01, 2013

   Kris,
   The FAA has made it clear that although this was a marginally acceptable practice in the past, this is no longer possible unless the instructor is both MEI and CFII.

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6. 
   

   
   

   Kris Kortokrax on Mar 01, 2013

   Flight training is defined in 61.1. The requirements for an IPC are laid out in the task table contained in the Instrument PTS. The IPC is a check. There is no flight training involved. I see nowhere that the FAA has “made it clear” that this is not possible.

   If they were serious, they would rewrite the regulations to require a Flight Instructor certificate with appropriate category/class ratings as a prerequisite for a Flight Instructor Instrument certificate. They would also change the language in paragraph 5-503 of Order 8900.1. They have done neither.

   Mark,
   Yes, I would say that a CFI without an instrument rating can give an IPC, IF he is a check pilot as allowed by 61.57 (d)(2).

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7. 
   

   
   

   Jon Moore on Mar 01, 2013

   To help understand the answer to the posted question, let me raise a slightly different one. First, you should know that there is no requirement for your first CFI rating to be airplane single-engine. What if your only CFI rating is instrument airplane? Then, without an airplane single-engine rating on your CFI certificate, can you give an IPC in a single-engine plane? Undoubtedly YES! By the same token, you can also give an IPC in a multi. Kris’s interpretation of the regs is correct.

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8. 
   

   
   

   Wes Beard on Mar 01, 2013

   It’s a rather interesting question. Is an IPC, a task as CFII without appropriate category and class ratings allowed to do? I say NO. Absolutely not. The FAA has already stated that giving instrument instruction in an aircraft for which the CFII is not qualified is not permitted. See Grayson Interpretation as well as the Beard Interpretation.

   In reading §61.193. “A person who holds a flight instructor certificate is authorized within the limitations of that person’s flight instructor certificate and ratings to train and issue endorsements that are required for:” … recency of flight experience.

   According to §61.57. An IPC is a recency of flight experience requirement. It is just like taking an instructor out to get day or night current, training event and as such the CFII must have the appropriate category and class rating.

   I agree with Kris that the events of the training event are determined in the front of the instrument PTS – task list but it wasn’t that long ago that CFII’s had the ability to check an appropriate representative amount to determine competence in instrument flying. Usually Kris is right on about the regs… I don’t agree with him this time.

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9. 
   

   
   

   Sam Dawson on Mar 02, 2013

   Per the table on page 1-vii of the Instrument PTS part of an IPC in a ME airplane are tasks VII B (One Engine Inoperative During Straight-And-Level Flight and Turns) and C (One Engine Inoperative-Instrument Approach). A pilot without an MEI has not been trained on how to evaluate these tasks, just as a person with a commercial/instrument rating but not a CFI-I has not been trained to evaluate the other tasks required in an IPC.

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10. 
    

    
    

    Kris Kortokrax on Mar 07, 2013

    Okay,

    First let me say that I am in complete agreement with the idea that an Instrument-Airplane or Instrument-Helicopter rating should not be the entry level certificate for a Flight Instructor. The appropriate category/class should be a prerequisite for the Flight Instructor Instrument ratings. In my opinion, the individuals who pursue the Instrument rating as their initial Flight Instructor certificate are attempting to circumvent being tested on the much larger array of knowledge required during a practical test for CFI Airplane or Helicopter. Additionally, the helicopter applicants are also likely to be attempting to avoid the requirement to learn to perform a touchdown autorotation, while still being able to call themselves helicopter instructors.

    Second, I am more concerned with “what” is right, rather than “who” is right.

    Third, unless anyone posting here works in the Office of Legal Counsel, we may offer opinions. We may cite past interpretations. We may not proffer our opinions as fact.

    I also believe that if someone asked Ms. Moore’s opinion, she would state that one must have category/class in addition to Instrument on one’s Flight Instructor certificate in order to do the IPC.

    The main point I was trying to express is that if I can outline circumstances in which the Grayson interpretation is not valid, then it is incorrect. I did outline several instances where one does not need any Part 61 Flight Instructor certificate to teach. See the Theriault interpretation which allows a Part 135 instructor who holds no Flight Instructor certificate to give both aircraft and instrument training.

    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/Theriault.pdf

    In Wes’ interpretation, it was stated that the “FAA’s consistent interpretation of §61.195(b) and (c) that, in order to conduct instrument flight training in an aircraft, a flight instructor must hold on his or her flight instructor certificate (1) aircraft category and class ratings for the aircraft in which the training is conducted, and (2) an instrument rating appropriate to the category of aircraft.” I submit that in light of paragraph 5-503 or Order 8900.1, that is not a true statement. Further, while not regulatory, John Lynch’s FAQ show that the FAA held quite the opposite view. He worked in AFS-800 and as one who helped author the Part 61 rewrite in 1997, he certainly was in a position to speak for the FAA as to what the regulations mean.

    The only thing I ask is that the FAA correct the regulations and Order 8900 to reflect the policy that Legal Counsel appears to be creating.

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