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4 Answers

CFII instrument training

Asked by: 2968 views Commercial Pilot, FAA Regulations, Flight Instructor, Instrument Rating

61.195(c) States: "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."

61.129(a)(3)(i) States: "Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. Five of the 10 hours must be in a single engine airplane."

61.109(a)(3) States: "3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane soely 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."


So my question is this: Does a flight instructor HAVE to be a CFII in order to do ANY hood work with a commercial pilot applicant? 


One point to support the NO answer was if the commercial applicant was already instrument rated, then those 10 hours would already be met.

If the answer was NO, and a CFI (not CFII) did provide that instruction (legally) would that time then count towards an ATP license in the future?

It is worded differently for a private and commercial pilot applicant.

Also to throw into the mix, differences between part 61 and 141?


Thanks in advance!

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4 Answers

  1. Wes Beard on Mar 05, 2013


    The instrument training requirements of 61.129 are very specific while the instrument training requirements for an instrument rating is very broad. An analogy would be a square is always a rectangle but a rectangle is never a square. In this context, the flight time for the instrument training under 61.129 can apply to the instrument training for the instrument rating under 61.65 but the reverse is not true unless the CFII specifically spells it out that way in the logbook.

    See the Theriault Interpretation. http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/Theriault.pdf

    I think 61.196(c) is quite clear. A CFII must give the instrument training required for commercial and ATP applicants.

    I have always interpretated the wording “instrument training” in the FARs to mean a CFII needs to give the instruction while “by reference to instruments” to mean a CFI can give the instruction.

    This answer is specific to Part 61 schools. Part 141 schools have other requirements that may permit a CFI to provide the instrument instruction.

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  2. Ron Klutts on Mar 06, 2013

    The reference of instruction “by reference to instruments” allows a CFI who isn’t a CFII to give the 3 hours of instrument training to a primary private pilot student, hence the different wording.

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  3. Mark Kolber on Mar 07, 2013

    >>allows a CFI who isn’t a CFII to give the 3 hours of instrument training<<

    That's a sentence that can lead to confusion. Wes is absolutely correct. When the FAA uses the phrase "Instrument training" in a requirement, a CFII is needed.

    The key here is that the "3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments" is very specifically =not= "instrument training." You won't find the phrase "instrument training" anywhere in the requirements for a private pilot certificate.

    Semantics? Yes, absolutely. When reading the regs, the meaning of word and phrases as used in the regs counts.

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  4. Kris Kortokrax on Mar 07, 2013


    Both Part 141 schools and 142 training centers have requirements which appear to parallel those for part 61.

    See 141.33(a)(3) and 142.47(a)(3).

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