Given instrument instruction without double "I"

sdflyer

sdflyer

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sdflyer
I have a student who is working on his instrument rating with other CFII. I'm currently holding only CFI, and in process of giving him complex/high performance endorsement.

We have some cloudy days so my student wants to take opportunity and do some IMC flying under my supervision. Basically getting on top, do some maneuvers in VFR, and come back IFR

I know IR requires 15 hours from authorize instructor (CFII) out of 40 total. So my understanding it is not prohibited to give some portion instrument instruction under the hood without CFII. Now how does it plays out in IMC?
Any ideas and recommendations are appreciated!
 
You can give the instruction in or out of imc and it can be logged dual received and actual or simulated as appropriate. It just does not count towards the authorized instructor hours.

Just because it can be done may or may not mean its a good idea. That's for you to decide.
 
jesse said:
You can give the instruction in or out of imc and it can be logged dual received and actual or simulated as appropriate. It just does not count towards the authorized instructor hours.

Just because it can be done may or may not mean its a good idea. That's for you to decide.
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Thanks . Yes this (good or bad idea) basically bothers me.
 
midlifeflyer said:
The Chief Counsel's office issued an opinion letter in 2010 that a "one-I" can't give instrument training - not even outside of the 15 hours. http://goo.gl/8qv6Z
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So, you should have the CFI simply recorded as a safety pilot rather than recording it as dual received? I have to admit, sometimes I can't figure out FAA Logic no matter how hard I try. :no:
 
LDJones said:
So, you should have the CFI simply recorded as a safety pilot rather than recording it as dual received? I have to admit, sometimes I can't figure out FAA Logic no matter how hard I try. :no:
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That's how I read this situation. The CFI in the right seat is acting as a safety pilot since he/she cannot give instrument instruction toward an instrument rating.
 
midlifeflyer said:
The Chief Counsel's office issued an opinion letter in 2010 that a "one-I" can't give instrument training - not even outside of the 15 hours. http://goo.gl/8qv6Z
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Exactly. It's not "instrument training" unless it comes from a CFI with instrument instructor rating. That doesn't mean a non-IA CFI can't give flight training under IFR or in IMC or on instrument tasks and have it count towards the 40 total hours of instrument time for the IR -- it's just not "instrument training" for FAA purposes.
 
LDJones said:
So, you should have the CFI simply recorded as a safety pilot rather than recording it as dual received? I have to admit, sometimes I can't figure out FAA Logic no matter how hard I try. :no:
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No. It's still legal flight training, and can be logged as training time. It's instrument time and training time, but not "instrument flight training" for FAA purposes, and cannot be used where instrument flight training time is required (e.g., the required 15 hours of instrument flight training for the IR).
 
Ron Levy said:
No. It's still legal flight training, and can be logged as training time. It's instrument time and training time, but not "instrument flight training" for FAA purposes, and cannot be used where instrument flight training time is required (e.g., the required 15 hours of instrument flight training for the IR).
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It still seems like an exercise in semantic stupidity. I would view ALL the time spent under the hood leading up to the instrument checkride as "training" time, recognizing 15 of those hours must be with a CFI-I. To say in instrument-rated flight instructor isn't providing a form of instrument training when flying around with pilot working toward their IFR ticket seems.

So, by a strict interpretation, there is really only 15 hours of "instrument training" time required for the instrument ticket, plus 35 or more hours of flying around building instrument time.

Which begs the question, what exactly do you log for the training time since you can't technically consider anything "instrument training" related?
 
LDJones said:
It still seems like an exercise in semantic stupidity. I would view ALL the time spent under the hood leading up to the instrument checkride as "training" time,
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You can view it any way you want, but the time spent with a non-instructor safety pilot is not "training time," at least not from an FAA regulatory perspective.

So, by a strict interpretation, there is really only 15 hours of "instrument training" time required for the instrument ticket,
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Correct.
plus 35 or more hours of flying around building instrument time.
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Only 25 additional hours -- the minimum total is 40 hours of instrument time.

Which begs the question, what exactly do you log for the training time since you can't technically consider anything "instrument training" related?
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You log what you did.
 
LDJones said:
It still seems like an exercise in semantic stupidity. I would view ALL the time spent under the hood leading up to the instrument checkride as "training" time, recognizing 15 of those hours must be with a CFI-
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By your argument, flying solo is training time.
The FAA doesn't agree. Training time is that flown with an authroized instructor.
INSTRUMENT training time only occurs with a II.
 
flyingron said:
By your argument, flying solo is training time.
The FAA doesn't agree. Training time is that flown with an authroized instructor.
INSTRUMENT training time only occurs with a II.
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Well, no, you can't fly under the hood solo. I just find it interesting that the FAA views time spent with an instrument-rated CFI as exactly the same value (from an instrument rating preparation standpoint) as flying around with a newly minted private pilot. The wording of that FAA letter makes it almost seem as if the CFI is proscribed from actually "training" anything instrument related...he needs to just sit there an make sure the pilot under the hood doesn't bump into anyone.
 
Ron Levy said:
You log what you did.
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But the wording of that letter makes it sound like the CFI shouldn't write anything that sounds like "instrument training" in their logbook as they're not authorized to provide that training other than what's provided for on the private pilot regs. I supposed you could write "Observed constant a/s climbs and descents, holding patterns and VOR approach."
 
LDJones said:
Well, no, you can't fly under the hood solo. I just find it interesting that the FAA views time spent with an instrument-rated CFI as exactly the same value (from an instrument rating preparation standpoint) as flying around with a newly minted private pilot. The wording of that FAA letter makes it almost seem as if the CFI is proscribed from actually "training" anything instrument related...he needs to just sit there an make sure the pilot under the hood doesn't bump into anyone.
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Who said flying under the hood? You missed the analogy.

Flying around without an authorized instructor is NOT training. For the 40 hours of instrument time, the chump in the right seat doesn't need to be a CFI at all, let alone a II. it is NOT training without an instructor; the FAA refers to it as "aeronautical experience." It is not INSTRUMENT training without a CFI.
 
Just remember this: there is official instruction which one records, and there is instruction which may or may not be logable, but which may nevertheless be valuable.
 
spiderweb said:
Just remember this: there is official instruction which one records, and there is instruction which may or may not be logable, but which may nevertheless be valuable.
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Well more precisely, you may learn something flying out side of instructional (by the FAA definition) situations. This is called experience rather than training.
 
LDJones said:
I just find it interesting that the FAA views time spent with an instrument-rated CFI as exactly the same value (from an instrument rating preparation standpoint) as flying around with a newly minted private pilot. The wording of that FAA letter makes it almost seem as if the CFI is proscribed from actually "training" anything instrument related...he needs to just sit there an make sure the pilot under the hood doesn't bump into anyone.
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I so no such proscription. Can you quote the portion you think says that?
 
LDJones said:
But the wording of that letter makes it sound like the CFI shouldn't write anything that sounds like "instrument training" in their logbook as they're not authorized to provide that training other than what's provided for on the private pilot regs. I supposed you could write "Observed constant a/s climbs and descents, holding patterns and VOR approach."
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Perhaps you could, but I don't see anything which requires such wording. It just wouldn't count for the 15 hours of instrument flight training required for the IR. That's one reason I put the "-IA" on the back of my CFI number when I sign logbooks for instrument training -- makes it easy for the DPE reviewing the log to determine that it was "instrument flight training" for that purpose.
 
Ron Levy said:
Perhaps you could, but I don't see anything which requires such wording. It just wouldn't count for the 15 hours of instrument flight training required for the IR. That's one reason I put the "-IA" on the back of my CFI number when I sign logbooks for instrument training -- makes it easy for the DPE reviewing the log to determine that it was "instrument flight training" for that purpose.
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I do the same for the same reason.
 
Ron Levy said:
Exactly. It's not "instrument training" unless it comes from a CFI with instrument instructor rating. That doesn't mean a non-IA CFI can't give flight training under IFR or in IMC or on instrument tasks and have it count towards the 40 total hours of instrument time for the IR -- it's just not "instrument training" for FAA purposes.
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My concern with the opinion letter is that it could be read to preclude that as well. When I spoke with the author of the letter (no McPherson, the attorney who actually wrote it) he indicated that's pretty much what was intended "we don't want CFIs without CFI instrument ratings teaching instrument flight".

The examples I gave during our discussion were exposure to IMC in the course of teaching flight by reference to instruments or teaching a private pilot how to use a localizer approach to help finding the airport in marginal VFR conditions. Best I could get was what you hear when they talk about private flights for compensation, "well, maybe there some things but..."

The unfortunate point I got out of the post-letter discussion was that a CFI without the -IA tacked on is acting outside his authority as an instructor when he does anything beyond the specific tasks involved in "flight solely by reference to instruments" under FAR 61.109.

IMO, it's a bad interpretation (which is why I followd up with them). Using CFIs who are CFI-I candidates for the excess hours has benefits for the trainee (something better than a safety pilot), the CFII candidate (learns how to deal with instrument students and their foibles ahead of time) and instrument instruction itself (better trained CFIIs coming through the ranks).

Oh well. My take-away is that a one-I giving instrument training is just another safety pilot. YRMV.
 
midlifeflyer said:
When I spoke with the author of the letter (no McPherson, the attorney who actually wrote it) he indicated that's pretty much what was intended "we don't want CFIs without CFI instrument ratings teaching instrument flight".
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This exchange is very iconic of most all Letters of Interpretation we get from lawyers (present company excluded :wink2:).

I agree on his basic premise, but it lacks considerably in technical knowledge, and is the base problem of trying to regulate in broad sweeps such a complicated process as learning advanced flying skills.

Even when the author knows the technical difficulties and knows the regulations should be re-written to break it down to more specific training, he also knows that takes an act of congress, and we ain't gettn nuthin' done in congress dese days.

So, we have to live with the way it is written, but we don't hafta be stupid about it. Good instructors are also creative in gettin their students trained in the best way possible.
Actually, any instrument student needs a good 10 to 15 hours of basic 'flight by reference to instruments' that a CFI-A can teach. This does not pre-clude the use of navigation instruments in mastering the basic skill of flight by reference to instruments. Very easy to use up 25 hours doing basics.
Then, when the student is really ready to tackle the "instrument training" required by 61.65 by an instructor authorized by 61.193.

Just don't write "instrument training" unless it is authorized on your CFI.
Which I have never written anyway. I just write a few things we did, but not "instrument training" specific.
If we do an approach, it is advancing to flight by reference to the instruments to a skill level appropriate to being able to advance to "instrument training".
 
OK, so here's a quirk....

CFI (No Double-I) is flying with an IR student. Said CFI has a 3rd class medical, and is flying in IMC with the PP/student.

We've established that he is not providing instrument instruction (no II). Can he be paid?

I know that an instructor can be paid with a 3rd Class, because he's paid for instruction, not flying. But the CFI is now acting as PIC (remember it's IMC, and its an IR student here) for compensation now...

Legal or no? Can he still say he's giving instruction (hence allowed to be paid) or not?
 
JeffDG said:
OK, so here's a quirk....

CFI (No Double-I) is flying with an IR student. Said CFI has a 3rd class medical, and is flying in IMC with the PP/student.

We've established that he is not providing instrument instruction (no II). Can he be paid?

I know that an instructor can be paid with a 3rd Class, because he's paid for instruction, not flying. But the CFI is now acting as PIC (remember it's IMC, and its an IR student here) for compensation now...

Legal or no? Can he still say he's giving instruction (hence allowed to be paid) or not?
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Do you REALLY want to go there? :rolleyes:
 
I think CFI doesn't act ad PIC only when he doesn't have any medical.


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JeffDG said:
OK, so here's a quirk....

CFI (No Double-I) is flying with an IR student. Said CFI has a 3rd class medical, and is flying in IMC with the PP/student.

We've established that he is not providing instrument instruction (no II). Can he be paid?

I know that an instructor can be paid with a 3rd Class, because he's paid for instruction, not flying. But the CFI is now acting as PIC (remember it's IMC, and its an IR student here) for compensation now...

Legal or no? Can he still say he's giving instruction (hence allowed to be paid) or not?
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The FAA answered that a long time ago, and it's pretty clearly stated in 61.23 -- yes, the instructor can be paid for giving training in this situation. They made clear that a CFI acting as PIC while being paid for giving training does not cross the line into providing pilot services for compensation/hire.
 
JeffDG said:
CFI (No Double-I) is flying with an IR student.
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No, the student is not actually an "IR student" in the context that we are discussing. He cannot be receiving "instrument training", so he is actually just "a student" seeking advanced training in flight by reference to instruments which the CFI-A is legally providing, whether in actual or simulated conditions.

Plus what Ron said.
 
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