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14 Answers

CFII Only Rating

Asked by: 7391 views
FAA Regulations, Flight Instructor, Instrument Rating

Hi everybody, Well i’m an FAA CFII, On my CFII certificates it says Instrument Airplane. I’m holding Also an FAA CPL SE ME IR. A guy working  at the FSDO, told me that i’m not legal to instruct people in an airplane, as per 61.195 (b). I sent an email to Oklahoma city and i get an answer from the faa Supervisor Technical Section telling me that i’m perfectly legal, she said : if you hold only an instrument rating on your Pilot and CFI, you can provide an endorsement for an instrument rating only, not an airplane single engine or multiengine class rating. Both ( Oklahoma and the IFU) sent me the same Legal Interp letter. My question is who is right ? I’ve endorsed for Instrument rating, people, my CFII ride has been done in an airplane, and none of all the DPEs,  rejected my applicants nor the FAA. Please let me know what do you think about this ? Thanks for your Help

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14 Answers



  1. Sam Dawson on Jul 07, 2013

    I’m not sure what happened to your original question and the answer I gave yesterday, but the answer remains the same.
    The FSDO is correct, Oklahoma City is wrong.
    The FAA Chief Counsel came out and clarified this in January 2010- the Grayson Opinion. For some reason I can not get the search function at the FAA Chief Counsel website to work right now, but here is the snipit:
    “Section 61.195(b), which addresses flight instructor limitations and
    qualifications with regard to aircraft ratings, directs that a flight
    instructor may not conduct flight training in any aircraft for which he does
    not hold “a pilot certificate and flight instructor certifIcate with the
    applicable category and class rating[.]” As such, a flight instructor is
    precluded from providing flight training in a specific class of airplane if
    the instructor does not have that class rating on his or her flight instructor
    certificate.”
    In other words, if you do not hold a “Flight Instructor, Airplane Single Engine” you may not give ANY instruction in a single engine airplane. If you do not hold a “Flight Instructor, Airplane Multiengine” you may not give ANY instruction in a multiengine airplane.

    DPEs may be accepting your students, but there are three problems based upon the FAA interpretation if the FAA finds out about this:
    1. The DPEs are at risk of having their DPE status revoked.
    2. The applicants who took their check rides with these DPEs risk having their certificates revoked or possibly face 709 rides.
    3. You are at risk of certificate action.

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  2. Aaron on Jul 07, 2013

    hi y

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  3. Aaron on Jul 07, 2013

    OKC is always right. Even when they’re wrong. 😉 I wouldn’t go against anything Oklahoma City said, because in case an issue does come up, you have that (really strong) defense.

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  4. Sam Dawson on Jul 07, 2013

    The problem is that if you listen to the FSDO and they are wrong no harm no foul. If you listen to OKC and they are wrong you are, as I wrote, setting yourself up for certification action. Given a choice between a FSDO, OKC and FAA Legal, I’d go with FAA legal.

    If you read the FAA legal interpretation I’m not sure how someone from OKC can say that unless they are so entrenched in a former belief that they will not change their mind. The FAA legal interpretation (from the FAA chief counsel), is very clear. If you do not hold a fight instructor rating with the appropriate category and class rating you may NOT teach. Period.

    Again, read the interpretation. One MUST have the appropriate CLASS rating on the instructor certificate. CFII ratings are for categories, so the only possible conclusion is that one must have the class rating (SEL, MEL), on the instructor certificate in order to teach ANYTHING in an airplane.

    Again, if you are still teaching as a CFII you are putting your certificates as well as those of your students at risk.

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  5. Mark Kolber on Jul 07, 2013

    I would forward the OKC response to the FAA Chief Counsel’s office. Differing interpretations cause problem for everyone. That’s what was going on before the 2009 amendment to the reg. It was such a big deal and the Chief Counsel follow-up letter came so close on it’s heels, I can’t help but suspect the person who wrote the letter from OKC simply made a mistake.

    Here’s the Chief Counsel interpretation. It even gets into how the then-current was out of date and incorrect. http://goo.gl/5ZQ2d

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  6. Mark Kolber on Jul 07, 2013

    …um…

    ” It even gets into how the then-current 8900 Order was out of date and incorrect “

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  7. Sam Dawson on Jul 07, 2013

    Thanks for posting the link Mark. For some reason when I attempted to do a search this weekend on the FAA Chief Counsel’s website I got a message “file not found”.

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  8. Mark Kolber on Jul 08, 2013

    The search engine on the Chef Counsel website can be a bit funky. I have direct links to particular letters.

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  9. CFI Academy on Jul 08, 2013

    Maybe this would be a good reason for you to add an airplane single engine and/or multi engine to your CFI IA certificate.

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  10. Mark Kolber on Jul 09, 2013

    Only if he wants to teach anything other than ground school.

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  11. Mark Kolber on Jul 13, 2013

    Just a follow-up. OKC is probably relying on the fact that the FSIMS discussion (which the Chief Counsel said was incorrect more than 2 years ago) has still not been changed.

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  12. Mike on Aug 23, 2013

    DPEs may be accepting your students, but there are three problems based upon the FAA interpretation if the FAA finds out about this:
    1. The DPEs are at risk of having their DPE status revoked.
    2. The applicants who took their check rides with these DPEs risk having their certificates revoked or possibly face 709 rides.
    3. You are at risk of certificate action.

    You are wrong regarding DPE risk. DPE is not required to check CFI credentials nor even know the signing CFI. It os OKC job o sort out who did what.

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  13. Mike on Aug 23, 2013

    DPEs may be accepting your students, but there are three problems based upon the FAA interpretation if the FAA finds out about this:
    1. The DPEs are at risk of having their DPE status revoked.
    2. The applicants who took their check rides with these DPEs risk having their certificates revoked or possibly face 709 rides.
    3. You are at risk of certificate action.

    You are wrong. DPE is not required to check the signing CFI credentials, or even know that CFI. It is OKC job to sort out who did what and if it is legal or correct.

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  14. awair on Apr 18, 2020

    Just in case anyone else is checking on this: it appears that 61.195(b) has been updated since this thread was started/last visited.

    Now includes “Except as provided in paragraph (c)”, which confirms that a CFII (only), may instruct…

    61.195(c)(1)(ii) – paraphrased:
    …if the student is already qualified in category/class…

    …not including multi-engine by virtue of (c)(2)

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