Can a ATPL holder instruct and endorse pilots?

10 Answers

1. 
   

   
   

   Brent on Jun 03, 2013

   With some limitations.

   § 61.167 Privileges.
   (a) A person who holds an airline transport pilot certificate is entitled to the same privileges as a person who holds a commercial pilot certificate with an instrument rating.

   (b) An airline transport pilot may instruct—

   (1) Other pilots in air transportation service in aircraft of the category, class, and type, as applicable, for which the airline transport pilot is rated and endorse the logbook or other training record of the person to whom training has been given;

   (2) In flight simulators, and flight training devices representing the aircraft referenced in paragraph (b)(1) of this section, when instructing under the provisions of this section and endorse the logbook or other training record of the person to whom training has been given;

   (3) Only as provided in this section, except that an airline transport pilot who also holds a flight instructor certificate can exercise the instructor privileges under subpart H of this part for which he or she is rated; and

   (4) In an aircraft, only if the aircraft has functioning dual controls, when instructing under the provisions of this section.

   (c) Excluding briefings and debriefings, an airline transport pilot may not instruct in aircraft, flight simulators, and flight training devices under this section—

   (1) For more than 8 hours in any 24-consecutive-hour period; or

   (2) For more than 36 hours in any 7-consecutive-day period.

   (d) An airline transport pilot may not instruct in Category II or Category III operations unless he or she has been trained and successfully tested under Category II or Category III operations, as applicable.

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2. 
   

   
   

   Mark Kolber on Jun 03, 2013

   The key limitation on ATP instruction in the US is the part of 61.167 that says:

   (b) An airline transport pilot may instruct—
   (1) Other pilots in air transportation service…

   Shorn of the regulatory language, it means that both the ATP and the student must be participants in an air carrier’s approved training program. It’s not an authorization for general instruction.

   IOW, an ATP employed by XYZ Airlines can instruct another pilot employed by XYZ Airlines in XYZ’s approved training program. But an ATP hanging out at the airport can’t just instruct another pilot for her private certificate.

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3. 
   

   
   

   Ale on Jun 04, 2013

   Logically NO, legally yes when the training is conducted under part 135 or 121 (i.e. the airlines operations)

   I personally think it is a BIG MISTAKE for a pilot to instruct another pilot without having the knowledge in the fundamentals of instructions (FOI); having the aeronautical knowledge and piloting skills is something and having the ability to teach is something else.

   I personally was trained under this type of training with “instructors” who had no clue about how to teach. True, most of them, have good aeronautical knowledge plus good knowledge in the aircraft systems but this makes them good pilots not good instructors.

   They lack serious knowledge in how to train. If anyone of those instructor (called also Instructor Pilots – IPs) read the FOI book and understand it well, they would realize the BIG MISTAKE to instruct without the basic knowledge of teaching. Those “instructors” should, at least, study and pass the FOI written test before they get involved in the teaching process.

   Being an instructor without the FOI knowledge is like being a pilot in a multi-crew cockpit without CRM knowledge. I wish that the FAA will soon requires all pilots involved in teaching to study and pass the FOI test. The result will be better and safer pilots in the sky.

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4. 
   

   
   

   Mark Kolber on Jun 04, 2013

   Ale, I’m not sure I agree on the “logically.” I don’t know what underlying assumptions you are using, but here’s mine:

   • We’re talking about a “student” who is in an FAA-approved airline training program.
   • The most common “student” of an instructing ATP is already a pilot, most likely the holder a commercial pilot with an instrument rating.
   • The training given is most likely for an ATP and/or a type rating which, except for a combination of both an ATP and a type rating, requires no logged instruction at all [see 61.39(c)].
   • The “student” is being trained specifically for Part 135 or 121 purposes and those commercial companies have as least as much interest as anyone else in seeing to it that the pilots are properly trained.

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5. 
   

   
   

   Ale on Jun 04, 2013

   Mark,

   Thank you for your comment.

   My point represent my personal opinion. I strongly believe that it is not logical for any pilot to teach and train another pilot without acquiring the basic knowledge on how to teach.

   If a pilot giving instruction to an Instrument Rating student is required by the FAA to hold a CFI certificate, wouldn’t it be more logically for a pilot training another pilot on more complicated tasks and more sophisticated equipments to be qualified “teacher” (i.e. CFI)?

   The learning process, planning instructional lessons, barriers to learning, human behavior, teaching methods, critique and evaluation … etc are some of the essential knowledge areas that any person involved in teaching others must acquire before he/she teaches. an elementary school teacher or a professor teaching a PhD degree students needs to know the mentioned knowledge areas.

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6. 
   

   
   

   Mark Kolber on Jun 04, 2013

   I know it’s a matter of personal opinion. We just disagree. I just tend to agree with the FAA’s view that the nature of training at that level means that instructors teaching for an airline will generally have better teaching qualifications and credentials than the typical CFI without the need to specifically regulate it.

   You make the analogy to elementary school and a professor teaching a PhD candidate. Note that the former requires a state teaching certificate; the latter does not.

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7. 
   

   
   

   Ale on Jun 04, 2013

   Mark,
   you said ” … instructors teaching for an airline will generally have better teaching qualifications”…I would agree with u if u said “flying qualifications” not teaching qualifications. The next time you meet one of those so called airline instructors, please ask them to define the learning process; make sure u know the defintion yourself first.

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8. 
   

   
   

   Mark Kolber on Jun 05, 2013

   I’ve met a few. Most of them have CFIs from their earlier aviation careers. Some have teaching experience in other fields, FAA or military. Some teach in formal Part 142 programs. Not too many of them just learned a bunch of mnemonics to regurgitate on the FOI test and promptly forgot them.

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9. 
   

   
   

   Thomas R Glanville on Mar 13, 2015

   Time to bring to light ATP instruction. To clarify 61.167 is called a Part and (a),(b) etc are sections and (1),(2), etc are sub sections.
   In section (b) states; ATP may instruct;
   (1) states: instruct OTHER pilots in air transport service in aircraft in category, class and type for which ATP IS RATED.
   Nowhere does it state it has to be with the same company or being 121, 135 meaning each could teach each other. And DOES state on the ATP license.
   Nowhere in this sub section does it refer to as pertaining to Part 61.3(d)(3)(2) This part and sections are being in an approved training and same company and program. I would like to point out that this instructor has to be listed as an instructor in the company OPS under the guidelines listed in 135.338 and 135.340 and/or same related parts 121. The companies will only use their own instructors and rarely go outside the company. The ATP instructor does not have to have a CFI.
   In Part 135.338(b) rule of Qualifications for company instructor. Nowhere does it say that the instructor has to have an ATP or a CFI. In 121 pilots are ATP
   So if it is as you say then there is really NO ATP PRIVILEGE?
   It would be a privilege of an ATP 121 or 135 multi engine rated pilot to teach a 135 single engine pilot multi engine?

   Sub section (3) Only as provided in this section; meaning ATP MAY INSTRUCT; except that an airline transport pilot who also holds a flight instructor certificate (that would be a CFI only) can exercise the instructor privileges under subpart H of this part for which he or she is rated.
   What this means is that a CFI ATP can instruct under subpart H which is all of the instruction rules which included multi engine, instrument etc. of this part which would be an ATP privilege.
   Now I’ve heard that “which he or she is rated” means that to be on the CFI certificate not on the ATP license. If this was true then there is NO ATP PRIVILEGE!
   Now let’s use some common sense here. If an ATP HAD IT ON THE INSTRUCTOR CERTIFICATE THEN HE/SHE CAN INSTRUCT ANYWAY, ANYBODY AND DOES NOT NEED AN ATP.
   This rule hardly ever comes into play because most ATP pilots have all the instructor endorsements because that’s how they got the hours to get there. And companies use there own pilots for training inside their company where they don’t need an ATP or CFI.
   I believe that since an ATP is the highest license to attain and hear referred equivalent to an PHD to a scientist, that if an ATP holds a CFI that all instruction that he/she is rated should automatically be instated on the CFI?

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10. 
    

    
    

    Kris Kortokrax on Apr 28, 2015

    To clarify your clarification:

    The regulation in question resides in Title 14, Chapter I, Subchapter D, Part 61, Subpart G, Section 61.167, Subsection (a), Paragraph (2), Subparagraph (i).

    See the Creech interpretation at:

    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/creech%20-%20(2010)%20legal%20interpretation.pdf

    Both your text and the text in the interpretation refer to 61.167(b). In its current form that text is contained in 61.167(a)(2).

    It deals with ATPs providing instruction. The FAA attorneys do tie 61.167(b) (61.167(a)(2)(i)) and 61.3(d)(3)(ii) together.

    They affirm that an ATP can only instruct within the confines of an approved training program. There is no air carrier training program which allows for instructing pilots outside the company. Hence, an ATP may only instruct pilots who work for the same company as he/she works for. If his company has a contract to perform training for another company as allowed for in 135.324(a) and documented in OpSpec A031, he may give instructions to pilots employed by the other company. That’s it, unless he possesses a Flight Instructor certificate.

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