Logging dual given in multi-engine aircraft as CFI with CMEL.

5 Answers

1. 
   

   
   

   John D Collins on Mar 20, 2015

   It should be clear in the quoted section of the regulations:

   Sec. 61.195 Flight instructor limitations and qualifications.

   A person who holds a flight instructor certificate is subject to the following limitations:
   (a) Hours of training. In any 24-consecutive-hour period, a flight instructor may not conduct more than 8 hours of flight training.
   (b) Aircraft Ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:
   (1) A pilot certificate and flight instructor certificate with the applicable category and class rating; and
   (2) If appropriate, a type rating.
   (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.

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2. 
   

   
   

   Kris Kortokrax on Mar 20, 2015

   For the purposes of Part 61, an instructor must have an instrument instructor rating to provide instrument training (dual).

   If the individual is designated as an instructor for an air carrier, he does not need a flight instructor certificate. He just needs to have undergone the company training curriculum to be an instructor for the air carrier. He could conceivably provide instrument instruction in one of the company aircraft or simulator to a company pilot and log the time as training time.

   You need to ask your “veteran” which regulations he was referring to.

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3. 
   

   
   

   Mark Kolber on Mar 23, 2015

   Assuming we are talking about Part 61 instruction, John’s regulatory reference is absolutely correct as is Kris’ summary that a CFI must have a CFI-IA rating to give instrument instruction.

   At one time, segments of the FAA took the position that a CFI-IA with a commercial pilot certificate with a AMEL could give instrument instruction without a CFI-AME rating. But in 2009, the FAA amended 61.195 to make it clear a CFI may not give any instruction in an airplane without that airplane rating on his CFI certificate. You migh have your instructor review the Chief Counsel’s written interpretation on the subject, http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/grayson-2%20-%20(2010)%20legal%20interpretation.pdf

   But, AFAIK, for at least the past 20+ years it has never been the FAA’s view that a CFI may give instruction without an instrument rating in her CFI certificate.

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4. 
   

   
   

   Kris Kortokrax on Mar 24, 2015

   In my 1983 book of regulations, 61.195(b) reads as follows:

   “The holder of a flight instructor certificate is subject to the following limitations:
   (b) Ratings. He may not conduct flight instruction in any aircraft for which he does not hold a category, class, and type rating, if appropriate, on his pilot and flight instructor certificate.”
   ____________________________________________________________
   The current 61.195(b) reads as follows:

   “A person who holds a flight instructor certificate is subject to the following limitations:
   (b) Aircraft Ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:

   (1) A pilot certificate and flight instructor certificate with the applicable category and class rating; and

   (2) If appropriate, a type rating.”
   ____________________________________________________________
   Exactly what wording was changed to make it clear that a CFI may not give any instruction in an airplane without that airplane rating on his CFI certificate????????

   Order 8900.1, Volume 5, Chapter 2, Section 11, Paragraph 5-503 still reads:

   “A. Single- and/or Multiengine Ratings. According to part 61, flight instructors who hold an “INSTRUMENT—AIRPLANE” rating only on their flight instructor certificate are authorized to give instrument flight instruction in single- and/or multiengine airplanes for instrument certification, provided they hold single- and/or multiengine ratings on their pilot certificate.”

   Up until the time that nitwit attorney issued the interpretation, it was perfectly acceptable (and was in fact done) for a CFI who held an Instrument Airplane rating only to give instrument dual in a single or multi engine airplane with the appropriate ratings on his pilot certificate.

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5. 
   

   
   

   Mark Kolber on Mar 25, 2015

   I agree with Kris that the wording change was inconsequential. There is a history behind it – one if those internal disputes between Flight Standards and the Chief Counsel’s office. There was even an enforcement action begun against a CFI before the change; it was dropped in part due to the language Chris quoted fro 8900, it’s predecessor, and the orphaned Part 61 FAQ (the timing suggests the demise of the FAQ as a public document may have been tied to this issue).

   But whether one agrees with it or not, it’s a good bet the minor change in the wording was intended to resolve the internal disagreement in favor of saying that a CFI must have a CFI-airplane rating in order to teach in an airplane.

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