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10 Answers

CFII privileges

Asked by: 2732 views FAA Regulations, Flight Instructor, General Aviation, Instrument Rating

Probably a question for Mr Collins…

In discussing 61.195 (c), "can a CFII provide flight instruction, without a CFI or MEI certificate?", an 'interpretation' opposing this was mentioned (but not specified).

Have there been interpretations on this question that pre-date a change to this regulation?

The general opinion seems to be that this is not permitted, but a reading of paragraph 61.195 (c) seems to give a clear approval. I haven't gotten round to indexing the 1100+ FAA counsel letters.

Thank you in advance.

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10 Answers



  1. Kris Kortokrax on Feb 06, 2022

    First, there is only one Flight Instructor certificate. There is no CFII certificate and no MEI certificate. “Airplane Multiengine” and “Instrument Airplane” are ratings placed on one’s Flight Instructor certificate.

    I’ve been flying for over 50 years and things have changed. In the distant past, there were some people who only had an Instrument Airplane rating on the Flight Instructor certificate. They could and did train pilots for an Instrument Airplane pilot rating in multi-engine airplanes. Someone, at some time, figured that was an easy way to build multi-engine PIC time.

    In the 2009 Part 61 rule rewrite, 61.195 was changed. The FAA then required an instructor to have the category/class rating on their Flight Instructor certificate, in addition to the appropriate Instrument rating.

    In June 2018, the FAA changed 61.195 again. The current wording allows an instructor, who only holds an Instrument rating on his Flight Instructor certificate to provide instrument instruction, unless the aircraft in question is a multi-engine airplane. In that case, the instructor must also hold an “Airplane Multiengine” rating on his Flight Instructor certificate. (61.195(c)(2))

    There is an interpretation that discusses the 2009 rule change.

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2010/Grayson-2_2010_Legal_Interpretation.pdf

    There are no interpretations concerning the 2018 change. The language in the rule is clear.

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  2. awair on Feb 06, 2022

    Thank you Kris,

    That is exactly what I was looking for. It is the history of the rule that I am trying to check.

    I am aware of the correct terminology for Instructor certs & ratings, it’s just that 99% of the world uses the slang for convenience.

    So to clarify, because the interpretation seems more complex than the current rule:

    1. (Some) Instructors used to train Instrument, without a Class rating (on their Instructor Cert)
    2. 2010 – FAA interpretation said this was wrong.
    3. 2009 reg change – confirmed this interpretation
    4. 2018 reg change – confirmed that only Multi (Airplane) required Instructor to have Class rating (on Instructor Cert)

    Many thanks,

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  3. Kris Kortokrax on Feb 06, 2022

    Close. Swap 2 and 3.
    The rule change came first, then the interpretation confirmed the rule change.

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  4. awair on Feb 06, 2022

    Many thanks again Kris.

    Wasn’t sure about the exact sequence since the 2010 FAA letter answered a 2009 enquiry…

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  5. Mark Kolber on Feb 08, 2022

    If you want to add to your history lesson, if you can find an old copy of FSIMS, you will see that #1 was specifically mentioned as proper. For extra credit, you can probably research and tie the demise of the Part 61 FAQ (which was publicly available for a number of years after the big 1997 Part 61 revision and then even more publicly disowned) into it. The FAQ also supported #1. Part of the *unwritten* history is an enforcement action brought against an instructor for doing it which was dropped due to these published contradictions to the Enforcement Division’s position.

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  6. Mark Kolber on Feb 08, 2022

    The reference to FSIMS should actually be to one of its predecessor, the General Aviation Operations Inspector’s Handbook,

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  7. Kris Kortokrax on Feb 08, 2022

    Hi Mark. I used to have an old interpretation that specifically allowed the practice, but I don’t have it any more.

    I retired end of November from 15 years as an FAA Ops inspector. On FSIMS, we had access to the inactive sections of FSIMS. Don’t know why they don’t make that available to everyone. I think that old interpretation is still sitting on my FAA computer somewhere.

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  8. Mark Kolber on Feb 11, 2022

    I think I have it somewhere too, Kris. I knew the instructor who was investigated about it so I was very interested in the subject. I pulled up the Handbook at the time and copied the section.

    But I can sort of understand why the “archives” are not widely available. Yes, it would be great for academic research, but I can also see it being a source for misunderstanding.

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  9. SlingPilot on Jun 18, 2022

    Hi,

    I am not sure if I understand the assertion by Kris, so bear with me.

    I think 61.195 c clearly indicates CFII with no CFI A (let’s stick to SEA for now) is accepted and legal provided the “instructor” holds a CSEL IR AND the student meets the requirements to be PIC on the type of SEA.

    Please take a look at 6.195.c.i or (this is the relevant or) ii

    IFR magazine actually published an article about this sometime ago. https://www.ifr-magazine.com/technique/finally-revised-regs/

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  10. SlingPilot on Jun 18, 2022

    And I think, this is the 2018 rule/clarifications. See specifically, the reference to “instrument only flight instructor” reference. Quoted for convenience:

    https://www.federalregister.gov/documents/2018/06/27/2018-12800/regulatory-relief-aviation-training-devices-pilot-certification-training-and-pilot-schools-and-other

    Thus, § 61.195(c)(1) allows an instrument-only flight instructor to conduct instrument training in an aircraft (other than multiengine airplanes) provided the instructor and the pilot receiving instrument training hold category and class ratings on their pilot certificates that are applicable to the aircraft in which the instrument training is accomplished.[81]

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