CFI logging instruction in IMC

[turbosuper]

Can a CFI without an instrument rating on his flight instructor certificate (not a CFII) log instruction time while providing instruction in IMC to an instrument rated pilot?

61.195 Flight instructor limitations and qualifications.
(c) Instrument rating.

This section only applies to instruction counting towards getting an instrument rating or for the commercial pilot. Since the instrument training given in my example is not for the issuance of any rating, it seems it should be allowed.

What about an MEI that is only a CFI, not a CFII. Can he give the instruction on the single engine instrument approach required for a multi-engine add-on per the ACS requirement for an instrument rated pilot to have instrument on the multi rating? It seems this situation is the same since you are giving instrument instruction to an instrument rated pilot.

 

[midlifeflyer]

If you ask the Chief Counsel these questions, the answer will be “no.” One of the regs they will point to is 61.193. More generally, they will also talk about how one is only a “authorized instructor” when acting within their instructor ratings and limitations. They have done this in a number of scenarios, like who can endorse an IPC, another example of a trainee who already has the rating.

 

[Gilbert Buettner]

Can a CFI without an instrument rating on his flight instructor certificate

I don't have an instrument rating on my flight instructor certificate. I have one on my commercial certificate. I am not aware of any CFI who is not instrument rated. All private pilot candidates must have three hours of simulated instrument training, therefore, a CFI who is not also a CFII is able to provide that training.

 

[midlifeflyer]

All private pilot candidates must have three hours of simulated instrument training, therefore, a CFI who is not also a CFII is able to provide that training.

Technically, no. A private pilot candidate must have "3 hours of flight training ... on the control and maneuvering of an airplane solely by reference to instruments." The FAA has for a long time distinguished that from the regulatory phrase "instrument training" or "instrument instruction." The former may be given by a "one I". The latter requires two Is.

 

[Lindberg]

I am not aware of any CFI who is not instrument rated.

There are plenty of CFIs who aren't instrument rated; it's not required for all CFI ratings. But that's not what the op is referring to.

 

[Tools]

These discussions make my mind hurt…

So, and really only for the discussion, I’m firmly in the (what do you get when you cross and elephant and rhinoceros?) eliphino camp.

As it turns out, there is such a thing as “instrument dual given”, which I had to cull out to be a 141 chief instructor in a school that offered instrument rating.

In the private 3.5 hrs of hood, it seems a CFI can do it, and log dual given. A CFII can do it and log instrument dual given.

It seems to me a CFI could do what the OP mentions, but can only log dual given, and the student can only log dual received, not dual received towards instrument anything.

It just happened to occur under IFR. Couldn’t you file a IFR flight plan, get a block altitude, be VMC and instruct stalls?

Of course this all seems arcane, but for interpretation sake.

 

[Walboy]

Can a CFI without an instrument rating on his flight instructor certificate (not a CFII) log instruction time while providing instruction in IMC to an instrument rated pilot?

I’m having a hard time understanding why the answer to this question isn’t yes.

What if the instruction is an aircraft checkout or how to use a new engine monitor?

 

[Tools]

(Looking up) THATS what I meant. Coulda saved my thumbs if I thought of that example. It’s early here in Alaska…

 

[midlifeflyer]

I’m having a hard time understanding why the answer to this question isn’t yes.

What if the instruction is an aircraft checkout or how to use a new engine monitor?

I guess the answer is that nothing about learning to use an engine monitor requires instrument training in actual IMC.

The FAA has unfortunately read this more strictly than necessary. Here's a good example: It had been common practice for years for flight schools to use CFI-As who were CFII candidates to cover the instrument hours beyond the required 5 hours with a CFII. The student logged dual and got the benefit of an instructor rather than just a safety pilot. The CFI logged PIC as instruction given and gained practical experience in teaching instruments. Win-Win for all.

Then there was this in 2010. It was one of the few times I followed up on a Chief Counsel letter. I ended up speaking with the author and pointed out a number of scenarios in which instrument tasks - including the basics of instrument approaches - would be helpful to a VFR pilot and that CFIs might be scared off by the letter. The person I spoke with sort of agreed byt said, "We don't want instructors who are not instrument instructors giving instrument training."

Whether that means the "one-I" cannot give dual in IMC at all or is limited to tasks which might fall into the "control and maneuvering" category is a separate question. There are CFIs who take student pilots into the clouds for part of those 3 hours so they have a more realistic experience. And I'm not sure how it would be enforced.

 

[Walboy]

Part of the confusion may be the title to the thread which uses the words "instrument instruction" and then the question in the post which does not use those words.

 

[turbosuper]

Part of the confusion may be the title to the thread which uses the words "instrument instruction" and then the question in the post which does not use those words.

The question is can the CFI log instruction in IMC with an instrument rated pilot. My understanding is that "instrument training" as defined in 61.195(c) is only used towards a rating. So can training be given on cross-country operations if it also happens to be in the clouds? I changed the tread title to make the question more clear.

What about this scenario, an instrument rated commercial pilot wants a CFI to ride along with him on an IFR flight because he likes a second set of eyes or doesn't feel real proficient in IMC, but is current. Can the CFI log this as instruction?

 

[RyanB]

You can’t provide instrument instruction for someone to use toward a rating, it’s that simple. If you’re on an IFR XC with a student that has an Instrument Rating and you’re just there giving instruction, then yes the IMC time can be logged and the whole thing is logged “As flight instructor”, but they cannot count toward any instrument training requirement.

 

[Gilbert Buettner]

There are plenty of CFIs who aren't instrument rated; it's not required for all CFI ratings. But that's not what the op is referring to.

You're right, of course. I wasn't thinking of sport pilot instructor, etc.

 

[Clip4]

Can a CFI without an instrument rating on his flight instructor certificate (not a CFII) log instruction time while providing instruction in IMC to an instrument rated pilot?

It certainly opens the CFI and a flight school to serious liability issues because the CFI isn’t trained to provide the instruction he is giving.

 

[Hengelo]

Is this a fair recap of the discussion thus far?

Yes, CFI can log instruction given
No, CFI cannot log instrument instruction given

 

[MauleSkinner]

It certainly opens the CFI and a flight school to serious liability issues because the CFI isn’t trained to provide the instruction he is giving.

How does it differ from the instruction in flight by reference to instruments they would give a student pilot or on a flight review?

 

[Clip4]

How does it differ from the instruction in flight by reference to instruments they would give a student pilot or on a flight review?

A CFI is trained and authorized to provide very limited flight by reference to the instruments training. The CFI is trained to provide both the training and the evaluation. When a CFI is training a non-IR private pilot or student in flight for reference to instruments, the training is emergency procedures taught in VMC with the admonishment the VFR pilot should never find himself in that real situation because we are not training the pilot to fly in IMC and doing so is one of the leading causes of GA fatal accidents. There is never an implication the pilot is proficient to fly in IMC.

That is not the implication when a non-trained CFI is providing instrument instruction in IMC. The single I is not trained to provide the instruction or the evaluation.

 

[MauleSkinner]

A CFI is trained and authorized to provide very limited flight by reference to the instruments training. The CFI is trained to provide both the training and the evaluation. When a CFI is training a non-IR private pilot or student in flight for reference to instruments, the training is emergency procedures taught in VMC with the admonishment the VFR pilot should never find himself in that real situation because we are not training the pilot to fly in IMC and doing so is one of the leading causes of GA fatal accidents. There is never an implication the pilot is proficient to fly in IMC.

That is not the implication when a non-trained CFI is providing instrument instruction in IMC. The single I is not trained to provide the instruction or the evaluation.

But why is he not trained to provide training and evaluation of flight by reference to instruments in the clouds?

 

[Clip4]

But why is he not trained to provide training and evaluation of flight by reference to instruments in the clouds?

Because he isn’t training people to fly in the clouds, he is training people to fly under instrument flight rules and the CFI has not received the specific training for this.

In the situation given, the CFI in reality is an IR rated commercial pilot providing instrument training and maybe doing so at the private pilot level.

There is a difference in being trained to do and training others to do. If there weren’t, the FAA would allow single Is to IPCs.

 

[midlifeflyer]

How does it differ from the instruction in flight by reference to instruments they would give a student pilot or on a flight review?

I think the FAA sees a difference between teaching a short-term emergency procedure for a VFR pilot to hopefully get out of trouble and the normalization of a sustained scan which is ultimately the smallest part of instrument flight.

The earliest part of instrument training involves moving from the former to the latter.

 

[MauleSkinner]

I think the FAA sees a difference between teaching a short-term emergency procedure for a VFR pilot to hopefully get out of trouble and the normalization of a sustained scan which is ultimately the smallest part of instrument flight.

The earliest part of instrument training involves moving from the former to the latter.

seems like being halfway decent at it would make an emergency more survivable.

 

[crash7]

Because he isn’t training people to fly in the clouds, he is training people to fly under instrument flight rules and the CFI has not received the specific training for this.

Is he? Is he really though? When I take student pilots into the soup so they can see what that's really like, I'm not teaching 91.167 thru 91.193. I'm not teaching L-charts or ODPs. I am giving headings to fly and altitudes to maintain. I'm giving a VOR needle to follow. Not unlike what a CFI-A (not II) does for that 3 hours of training.

 

[Clip4]

Is he? Is he really though? When I take student pilots into the soup so they can see what that's really like, I'm not teaching 91.167 thru 91.193. I'm not teaching L-charts or ODPs. I am giving headings to fly and altitudes to maintain. I'm giving a VOR needle to follow. Not unlike what a CFI-A (not II) does for that 3 hours of training.

Your scenario is not what the OP is proposing. The OP is proposing instructing an IR pilot who does not believe he is competent to fly under IFR in IMC.

 

[crash7]

Your scenario is not what the OP is proposing. The OP is proposing instructing an IR pilot who does not believe he is competent to fly under IFR in IMC.

Fair point. The thread slid a bit into the 3 hours of "training" for PP students. The letter that was referenced earlier talks about training towards that instrument rating. The OP scenario has the trainee as an already IR pilot. He/she isn't seeking the rating that would trigger 61.65(d) or 61.195(c). He/she isn't receiving an IPC. He/she is simply wanting some oversight while in the soup.

I agree that getting the Instrument rating on your CFI certificate -should- make you better at giving such guidance/oversight. However, I don't see it as counter to the regs. An Instrument pilot with tons of cross country real world IFR experience may very well give better guidance/oversight to the OP scenario than I could as a CFII.