Can a CFI do an IPC?

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rookie1255

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rookie1255
My understanding is that a CFI with a current instrument rating can do an IPC and doesn't have to be a CFII. I can't find any section in part 61 that says this isn't true.

Before someone says CFIs can't do any instrument training at all, remember CFIs provide instrument training for student pilots under the 3 hours required for private pilot and don't have to be CFIIs.

An IGI could sign off an IPC in a simulator, wouldn't even have to be a CFI if I understand that correctly. Which means you can have an IGI, who has not taken a CFI checkride, sign people off on instrument currency in a simulator.

I hate the FAR-AIM (I know, blasphemy).
 
rookie1255 said:
My understanding is that a CFI with a current instrument rating can do an IPC and doesn't have to be a CFII. I can't find any section in part 61 that says this isn't true.

Before someone says CFIs can't do any instrument training at all, remember CFIs provide instrument training for student pilots under the 3 hours required for private pilot and don't have to be CFIIs.

An IGI could sign off an IPC in a simulator, wouldn't even have to be a CFI if I understand that correctly. Which means you can have an IGI, who has not taken a CFI checkride, sign people off on instrument currency in a simulator.

I hate the FAR-AIM (I know, blasphemy).
Click to expand...

See AC 61-98B for your answer.
 
rookie1255 said:
My understanding is that a CFI with a current instrument rating can do an IPC and doesn't have to be a CFII. I can't find any section in part 61 that says this isn't true.

Before someone says CFIs can't do any instrument training at all, remember CFIs provide instrument training for student pilots under the 3 hours required for private pilot and don't have to be CFIIs.

An IGI could sign off an IPC in a simulator, wouldn't even have to be a CFI if I understand that correctly. Which means you can have an IGI, who has not taken a CFI checkride, sign people off on instrument currency in a simulator.

I hate the FAR-AIM (I know, blasphemy).
Click to expand...

Only a flight instructor with an instrument rating on their flight instructor certificate (commonly referred to as a CFII) may give instrument instruction. Therefore, a flight instructor without an instrument rating on his or her instructor certificate may not administer an IPC.
 
Htaylor said:
See AC 61-98B for your answer.
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AC 61-98C is the current version and replaced the "B" revision on in November of 2015. Not nit picking just thought there might be some changes that would interest the OP. I have not read the new version yet but I imagine that the changes are minor.
 
rookie1255 said:
My understanding is that a CFI with a current instrument rating can do an IPC and doesn't have to be a CFII. I can't find any section in part 61 that says this isn't true.
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Neither can I. However, the FAA's position is pretty clear. The AC mentioned above as well as an FAA legal interpretation, griffith - (2008), both say a CFII is required. Incidentally, the interpretation notes that an IGI cannot sign off on an IPC in an FTD which came as a surprise to some people.

Personally, I think the FAA position of requiring a CFII makes complete sense, but I'm not convinced that the regulations as currently written support that position.
 
Mason said:
The hood training a CFI gives a Private student is not "instrument training."
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An IPC is not training, it's a checkride to make sure you meet the minimum requirements to continue flying in instrument conditions.

Just like any other checkride is not considering training. Did you mark dual for your PPL checkride?

The language is indeed vague in 61.57 and the 61-98 circular. But this part of the circular leads me to believe a CFII is required:

The CFI 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 IPC
 
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Caramon13 said:
An IPC is not training, it's a checkride to make sure you meet the minimum requirements to continue flying in instrument conditions.

Just like any other checkride is not considering training. Did you mark dual for your PPL checkride?

The language is indeed vague in 61.57 and the 61-98 circular. But this part of the circular leads me to believe a CFII is required:

The CFI 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 IPC
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See this, which refers to this.
The relevant section says:
A flight instructor who does not hold an instrument rating on their flight instructor certificate that is appropriate to the category and class of aircraft that the instrument proficiency check is being conducted in is not authorized to conduct the instrument proficiency check.
Click to expand...
 
Glider/RotorDude, yeah I think we're saying the same thing your quotes are just written differently.

Though if I was put on the spot to ask why, I'd personally rather use an official document released by the FAA at the end of last year to back that up as opposed to a public forum answer from almost 4 years ago.
 
Caramon13 said:
Glider/RotorDude, yeah I think we're saying the same thing your quotes are just written differently.

Though if I was put on the spot to ask why, I'd personally rather use an official document released by the FAA at the end of last year to back that up as opposed to a public forum answer from almost 4 years ago.
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My above quote is not from a "public forum answer", but from the FAA's Flight Standards Service "FAQs Part 61" document, which is intended to harmonize the interpretations among the regional FSDOs. This document was in turn quoted by the public forum ("Ask a CFI") that I linked to above (first link).
It certainly would be "cleaner" and more authoritative to get a simple ruling from the Chief Counsel or even better from the FARs, but apparently this "official" FAA "FAQs" document is the best we can get at the moment, and at least is very clear in its ruling.
If anyone has something better, feel free to share.
 
I guess my question is, legal or not, WHY would you want to get an IPC from someone who isn't qualified to teach instruments? Are CFIIs that hard to find where you are?
 
Have the CFI checkride this week, so dealing with a zillion hypothetical questions. It easy to list required endorsements, aeronautical experience for a practical test, but then it comes down to stuff like:

1. Your student has been signed off for solo and solo cross country in a 150. To do an additional solo in a 172 does the student need a new presolo knowledge test?

2. A private pilot has just bought a Mooney (complex) aircraft and wants to get transition training in it. Before he has been signed off as proficient and gets a complex endorsement, can he log his training time as PIC time?

You study the oral guide and think you know your stuff, but questions like these seem to stump me all the time. Find myself looking at the reg and STILL not getting the answer. Sometimes its not even the reg, but interpreting it. Not sure if this is how the oral is really going to go as far as difficulty, or if my CFI is just trying to push me to a higher standard and is being unreasonable.

By the way, when you don't know the answer there seems to be no way to get it. Other CFI's just provide what they THINK the answer is, no one can point to the reg that supports their opinion, and you're still left wondering if you know the true answer at all after your search.

I know, I'm a pessimist.
 
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rookie1255 said:
Have the CFI checkride this week, so students are getting together with the instructor to deal with a zillion hypothetical questions. It easy to list required endorsements, aeronautical experience for a practical test, but then it comes down to stuff like:

1. Your student has been signed off for solo and solo cross country in a 150. To do an additional solo in a 172 does the student need a new presolo knowledge test?

2. A private pilot has just bought a Mooney (complex) aircraft and wants to get transition training in it. Before he has been signed off as proficient and gets a complex endorsement, can he log his training time as PIC time?

You study the oral guide and think you know your stuff, but questions like these seem to stump me all the time. Find myself looking at the reg and STILL not getting the answer. Sometimes its not even the reg, but interpreting it. Not sure if this is how the oral is really going to go as far as difficulty, or if my CFI is just trying to push me to a higher standard and is be.ing unreasonable.

By the way, when you don't know the answer there seems to be no way to get it. Other CFI's just provide what they THINK the answer is, no one can point to the reg that supports their opinion, and you're still left wondering if you know the true answer at all after your search.

I know, I'm a pessimist.
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FAA is clear on 2

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2009/herman%20-%20(2009)%20legal%20interpretation.pdf
 
Well, issues. Call Orlando FSDO and they will tell you this letter is incorrect. Because the FSDO here says that, the flight schools in the area go by their rues. Embry Riddle says the letter is accurate and they log that time.

I doubt it'll be a checkride question, but I'll have the letter on me, then I can at least have something to point to for the examiner.

Somedudeintn said:
FAA is clear on 2

http://www.faa.gov/about/office_org...2009/herman - (2009) legal interpretation.pdf
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If you're talking about PIC time now (which is a completely separate can of worms), Mark Kolber has a pretty thorough page on that on his site:

http://midlifeflight.com/flying-faq/faq/

Was pretty helpful for me when figuring out when I should and should not fight for PIC time in my logbook. The link is also in his sig, and he's a pretty frequent poster.
 
Caramon13 said:
If you're talking about PIC time now (which is a completely separate can of worms), Mark Kolber has a pretty thorough page on that on his site:

http://midlifeflight.com/flying-faq/faq/

Was pretty helpful for me when figuring out when I should and should not fight for PIC time in my logbook. The link is also in his sig, and he's a pretty frequent poster.
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I love these letters.

http://www.faa.gov/about/office_org...louis glenn - (2009) legal interpretation.pdf
http://www.faa.gov/about/office_org...009/gebhart - (2009) legal interpretation.pdf
http://www.faa.gov/about/office_org...09/hilliard - (2009) legal interpretation.pdf

Is there a database or collection of them so I can read them all? I find them a lot more interesting than the FAR/AIM.
 
You can find some here: http://www.faa.gov/about/office_org.../agc/pol_adjudication/agc200/Interpretations/
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Interestingly, I found something odd in that FAA Interpretation Letters database. By chance I landed on this "Scholz" letter, which refers to a "Michael Griffith" letter from 2008, which seems to address the exact issue that started this thread, "Can a CFI perform an IPC?" (with a very clear answer "no", as noted in the Scholz letter). But I can't seem to find that original Griffith letter anywhere, despite googling hard.
Can anyone find it? Thanks!
 
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RotorDude said:
Interestingly, I found something odd in that FAA Interpretation Letters database. By chance I landed on this "Scholz" letter, which refers to a "Michael Griffith" letter from 2008, which seems to address the exact issue that started this thread, "Can a CFI perform an IPC?" (with a very clear answer "no", as noted in the Scholz letter). But I can't seem to find that original Griffith letter anywhere, despite googling hard.
Can anyone find it? Thanks!
Click to expand...

Ok, I found the Griffith letter.
And in fact, it specifically states:
Therefore only a certified instrument flight instructor (CFII) ... is authorized to endorse for passing that instrument proficiency check.
Click to expand...
I think that trumps the Flight Standards FAQ for "authoritativeness".
 
rookie1255 said:
My understanding is that a CFI with a current instrument rating can do an IPC and doesn't have to be a CFII. I can't find any section in part 61 that says this isn't true.

Before someone says CFIs can't do any instrument training at all, remember CFIs provide instrument training for student pilots under the 3 hours required for private pilot and don't have to be CFIIs.

An IGI could sign off an IPC in a simulator, wouldn't even have to be a CFI if I understand that correctly. Which means you can have an IGI, who has not taken a CFI checkride, sign people off on instrument currency in a simulator.

I hate the FAR-AIM (I know, blasphemy).
Click to expand...
If you read the regs carefully, I believe you'll see the term "authorized instructor" in the list of people who can give an IPC. In this context, "authorized" means a CFII.

You'll also see that what is required for student pilots is flight "solely by reference to instruments", as opposed to the "instrument time" specified for the instrument rating.

Not exactly obvious to the casual observer, but that's the basis of the FAA's interpretations.
 
rookie1255 said:
I love these letters.

http://www.faa.gov/about/office_org...louis glenn - (2009) legal interpretation.pdf
http://www.faa.gov/about/office_org...009/gebhart - (2009) legal interpretation.pdf
http://www.faa.gov/about/office_org...09/hilliard - (2009) legal interpretation.pdf

Is there a database or collection of them so I can read them all? I find them a lot more interesting than the FAR/AIM.
Click to expand...
If you read them you are in the database. http://www.faa.gov/about/office_org.../agc/pol_adjudication/agc200/Interpretations/

The database isn't all-inclusive. It only goes back to the 90's with any degree of completeness. But it has most of what is relevant today. But be aware that Part 61 questions are only a small piece. Most of the database involves other stuff. There is, for example, a lot of duscussion on Part 135 and 121 duty and rest time
 
dmspilot said:
https://en.wikipedia.org/wiki/Begging_the_question
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The use of the pretty generic term "authorized instructor" is precisely because different types of people are authorized to provide different types of instruction.

Yes, "an authorized instructor is someone authorized to provide a certain type of instruction" begs the question (among other things). But that just means one has to look further to answer it.

And, yes, the FAA dies generally consider review and evaluation of knowledge and skill to be part of "training." Most of my teachers since grade school felt the same way.
 
midlifeflyer said:
The use of the pretty generic term "authorized instructor" is precisely because different types of people are authorized to provide different types of instruction.

Yes, "an authorized instructor is someone authorized to provide a certain type of instruction" begs the question (among other things). But that just means one has to look further to answer it.

And, yes, the FAA dies generally consider review and evaluation of knowledge and skill to be part of "training." Most of my teachers since grade school felt the same way.
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Not sure what point you are trying to make. I'm not saying a non-double-I can do it, just that MsuleSkinner's reason given is not a valid argument. (Other posters have presented valid arguments, however.)

"Is a CFI authorized to give an IPC?"
"No, an IPC must be given by an authorized instructor. Therefore a CFI is not authorized. It must be given by a CFII."
 
post-14790-0-78720400-1428969730_zpscgfpenvg.jpg
 
dmspilot said:
Not sure what point you are trying to make. I'm not saying a non-double-I can do it, just that MsuleSkinner's reason given is not a valid argument. (Other posters have presented valid arguments, however.)

"Is a CFI authorized to give an IPC?"
"No, an IPC must be given by an authorized instructor. Therefore a CFI is not authorized. It must be given by a CFII."
Click to expand...

You apparently missed the part about the FAA's interpretations in my post. Apparently I should've linked them all again, with appropriate arrows and circles?
 
MauleSkinner said:
You apparently missed the part about the FAA's interpretations in my post. Apparently I should've linked them all again, with appropriate arrows and circles?
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You mean the FAA interpretations that other people posted? I thought you were trying to set forth a unique argument that hinged on the word "authorized" in "authorized instructor" in 61.56(d)(2). In reality, every time the regulations refer to an instructor, they refer to an "authorized instructor." Focusing on that one word adds no insight to the discussion so I'm still not sure of the point of your post.

MauleSkinner said:
Not exactly obvious to the casual observer, but that's the basis of the FAA's interpretations.
Click to expand...

The Chief Counsel has a history of issuing interpretations based on what they want the regulations to read rather than what they actually read.

In the Griffith letter, the basis of their interpretation seems to be the phrase "related to...an instrument rating" in combination with the phrase "within the limitations of that person's flight instructor certificate and ratings" in 61.193. Not the word "authorized."

Two problems with that letter anyway. First, that regulation has changed and the "related to" part is not there anymore. One could make an argument than an IPC is "an endorsement required for an instrument rating" in which case only a CFII and not a CFI could give an IPC.

Second, the Griffith letter totally ignores 61.195 which explicitly lists the limitations of flight instructors, with 61.195(c) specifying when an instrument rating on a flight instructor is required: "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." Giving an IPC is not in that list, either implicitly or explicitly.

In conclusion, the requirement for only CFIIs to give IPCs is ambiguous at best. It's obvious the FAA wants it so; they ought to write a regulation that actually requires it.

The ambiguity reminds me of the controversy surrounding the advanced ground instructor certificate, which used to allow someone to give ground training "for any certificate or rating." Now it says, "...except for...an instrument rating".
 
So you're saying that technically NO instructors are authorized to give IPCs?
 
An "authorized instructor" is defined by 61.1 as
(ii) A person who holds a flight instructor certificate issued under part 61 of this chapter and is in compliance with §61.197, when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate;
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You point out that an IPC is not listed in the privileges and limitations of an instrument instructor.

So what reg defines ANY instructor as an authorized instructor for signing off an IPC?
 
MauleSkinner said:
An "authorized instructor" is defined by 61.1 as
Click to expand...

I know what it is.

MauleSkinner said:
You point out that an IPC is not listed in the privileges and limitations of an instrument instructor.
Click to expand...

That is not what I pointed out. Here is what I wrote:

dmspilot said:
61.195(c) [specifies] when an instrument rating on a flight instructor is required: "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." Giving an IPC is not in that list, either implicitly or explicitly.
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61.195(c) lists when a flight instructor needs an instrument rating, and IPC is not in there, doesn't that mean that a flight instructor without an instrument rating could give an IPC?

MauleSkinner said:
So what reg defines ANY instructor as an authorized instructor for signing off an IPC?
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61.193(g)
 
61.193 just says an instructor can do so if it's within the limitations of his or her certificate and ratings. What reg defines the rating(s) for which an IPC is within limitations?
 
MauleSkinner said:
61.193 just says an instructor can do so if it's within the limitations of his or her certificate and ratings. What reg defines the rating(s) for which an IPC is within limitations?
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61.193 grants privileges, 61.195 issues limitations.

If 61.193 says you can do something, and 61.195 doesn't say you can't, then you can do it.
 
61.195(c) is a non starter in this case. It doesn't apply.

61.57(d)(2)(iv) states that an authorized instructor is qualified to give the instrument proficiency check.

So the argument is what qualifies as an authorized instructor in this case. Since we are talking INSTRUMENT proficiency check, common sense would dictate that a Flight instructor with instrument privileges on his instructor ticket.

You can argue all day long that in this case "authorized instructor" is not defined but a CFI without instrument privileges on his ticket doing an IPC will be doing a tap dance in front of the FAA if he gets caught doing it.
 
Greg Bockelman said:
61.195(c) is a non starter in this case. It doesn't apply.

61.57(d)(2)(iv) states that an authorized instructor is qualified to give the instrument proficiency check.

So the argument is what qualifies as an authorized instructor in this case. Since we are talking INSTRUMENT proficiency check, common sense would dictate that a Flight instructor with instrument privileges on his instructor ticket.

You can argue all day long that in this case "authorized instructor" is not defined but a CFI without instrument privileges on his ticket doing an IPC will be doing a tap dance in front of the FAA if he gets caught doing it.
Click to expand...

And will need to dance around the Griffith letter which specifically says he can't.
 
It looks pretty clear in the AC that I posted earlier that a CFI can NOT conduct an IPC. It appears that everyone wants to debate black and white to death so I'm going to pose this follow on question that popped in to my head while reading the Griffith memo.

Follow along and tell me what you think....

61.57(d) states:

(d) Instrument proficiency check. Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check. The instrument proficiency check must consist of the areas of operation and instrument tasks required in the instrument rating practical test standards.

(1) The instrument proficiency check must be--

(i) In an aircraft that is appropriate to the aircraft category;
(ii) For other than a glider, in a flight simulator or flight training device that is representative of the aircraft category; or

(iii) For a glider, in a single-engine airplane or a glider.


(2) The instrument proficiency check must be given by--

(i) An examiner;
(ii) A person authorized by the U.S. Armed Forces to conduct instrument flight tests, provided the person being tested is a member of the U.S. Armed Forces;

(iii) A company check pilot who is authorized to conduct instrument flight tests under part 121, 125, or 135 of this chapter or subpart K of part 91 of this chapter, and provided that both the check pilot and the pilot being tested are employees of that operator or fractional ownership program manager, as applicable;

(iv) An authorized instructor; or

(v) A person approved by the Administrator to conduct instrument practical tests.
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So, if I were to go over to the aviation unit and have an IP administer my IPC, would it count?
 
MauleSkinner said:
An "authorized instructor" is defined by 61.1 as


You point out that an IPC is not listed in the privileges and limitations of an instrument instructor.

So what reg defines ANY instructor as an authorized instructor for signing off an IPC?
Click to expand...
Remember that part of his argument is that the Chief Counsel makes things up with the result they want in mind, whether it makes sense or not. Not that he would do such a thing.

After all, an instructor not trained and certified to teach and evaluate instrument knowledge and skill being permitted to issue endorsements to pilots that they have that knowledge and skill is the height of reason and logic, isn't it?
 
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midlifeflyer said:
Remember that part of his argument is that the Chief Counsel makes things up with the result they want in mind, whether it makes sense or not. Not that he would do such a thing.

After all, an instructor not trained and certified to teach and evaluate instrument knowledge and skill being permitted to issue endorsements to pilots that they have that knowledge and skill is the height of reason and logic, isn't it?
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Sarcasm duly noted. Although it's clear in this case what the FAA wants, whether written well in the rules or not, the logic being presented for a CFI with an instrument rating on the pilot certificate giving an IPC without being a real fire-breathing CFII doesn't seem that much out of step with the logic that lets a pilot log PIC time who isn't really the PIC or the logic that allows a CFI who isn't current at night to give night dual to a student who isn't night-current either. Or the logic that says you can't carry passengers in the incidental furtherance of a business despite no such language in the rules. Or the logic that lets a regular CFI give the important life-saving instrument time to a student preparing for a private license. Etc.

dtuuri
 
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