Intense 10-day IFR training - 5 hours on type for instructor?

dtuuri said:
I'd say that's entirely your own speculation,
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No, those are the exact words in the previous and current versions of the regulation.

I interpret the two as meaning exactly the same except powered-lift has been added. I've even read the preamble for this change which says nothing about extending the scope to cover an instrument rating, it only mentions powered-lift.
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Then you're ignoring the plain language of the regulation and inventing your own interpretation without basis in the regulation as it is written. I would advise strongly against trying to act on that interpretation.
 
Ron Levy said:
No doubt the lack of IR is the reason for that. The VFR-only twin owners I've trained for their IR told me their rates would drop a lot when they passed.
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My thought as well. The IR has a definite impact on the insurance company's view of your capabilities.
 
dtuuri said:
I'd say that's entirely your own speculation, I interpret the two as meaning exactly the same except powered-lift has been added. I've even read the preamble for this change which says nothing about extending the scope to cover an instrument rating, it only mentions powered-lift.
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The preamble only mentions powered lift. But the regulatory language changed in other respects, from

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(f) Instruction in multiengine airplane or helicopter. He may not give flight instruction required for the issuance of a certificate or a category, or class rating, in a multiengine airplane or a helicopter, unless he has at least 5 hours of experience as pilot in command in the make and model of that airplane or helicopter, as the case may be.
==============================

to

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Training received in a multiengine airplane, a helicopter, or a powered-lift. A flight instructor may not give training required for the issuance of a certificate or rating in a multiengine airplane, a helicopter, or a powered-lift unless that flight instructor has at least 5 flight hours of pilot-in-command time in the specific make and model of multiengine airplane, helicopter, or powered-lift, as appropriate.
==============================

As the Chief Counsel indicated in a fairly recent opinion letter, the preamble is the preamble, but the rule as written is what counts. And that was in a case (currency approaches in a sim not requiring an instructor) where the preamble was quite explicit about what it intended, not merely silent.

The removal of the "category or class" language pretty clearly indicates the rule, as of 1997, is not limited to "category or class" ratings.
 
This is right up there with the serruptitious change to the safety pilot /SIC rule. The change was lost in the NPRM, comments, and FR preamble where it discusses the goal to change the SIC (for 135/121 primarily) training requirements. However, the fact that the rejiggered the sections means the exemption for SIC to have an instrument rating for safety piloting was lost.

However, I stopped fighting this when we got a counsel opinion that the safety pilot isn't SIC at all (which doesn't really make any sense in terms of the SIC regulation wording) but if they want to believe that, I'm not going to fight it. The result is the same.
 
midlifeflyer said:
The preamble only mentions powered lift. But the regulatory language changed in other respects, from

==============================
(f) Instruction in multiengine airplane or helicopter. He may not give flight instruction required for the issuance of a certificate or a category, or class rating, in a multiengine airplane or a helicopter, unless he has at least 5 hours of experience as pilot in command in the make and model of that airplane or helicopter, as the case may be.
==============================

to

==============================
Training received in a multiengine airplane, a helicopter, or a powered-lift. A flight instructor may not give training required for the issuance of a certificate or rating in a multiengine airplane, a helicopter, or a powered-lift unless that flight instructor has at least 5 flight hours of pilot-in-command time in the specific make and model of multiengine airplane, helicopter, or powered-lift, as appropriate.
==============================
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I see that as an economization of words. They dropped "category" from the original language because it was unnecessary. For example, helicopter-only pilots seeking ME airplane privileges couldn't get just a new category rating they'd get a ME class rating too and nothing but that, i.e., not an instrument rating. Hence no need for extra words like "category" and "class" when simply "rating" will do.

midlifeflyer said:
As the Chief Counsel indicated in a fairly recent opinion letter, the preamble is the preamble, but the rule as written is what counts. And that was in a case (currency approaches in a sim not requiring an instructor) where the preamble was quite explicit about what it intended, not merely silent.

The removal of the "category or class" language pretty clearly indicates the rule, as of 1997, is not limited to "category or class" ratings.
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I can certainly agree with that when the rule is plain to all. In this case, though, it's plain to me that the rule does not apply to instrument training at all and merely adds "powered-lift" to the existing rule when instructors didn't need five hours in make and model to give instrument instruction to rated ME pilots. Here's the preamble language for others to decide for themselves:
"Proposed paragraph (f) expanded the
existing rule that requires a flight
instructor to have at least 5 flight hours
of operating experience as a pilot in
command in the specific make and
model of multiengine airplane or
helicopter, to include powered-lifts. The
complexity and flight characteristics of
these aircraft require that a flight
instructor be proficient in the aircraft
and requires that the flight instructor
requirements for powered-lifts parallel
those requirements for multiengine
airplanes and helicopters."​
Thank you again for providing me that reference offline, Mark.

dtuuri
 
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I guess, then, that you think an instrument rating is not a "rating." You might want to refer to 14 CFR 61.5 and then rethink your position.
 
Ron Levy said:
I guess, then, that you think an instrument rating is not a "rating." You might want to refer to 14 CFR 61.5 and then rethink your position.
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And you, I guess, think there's a difference between the 15 hours of "required" instrument instruction and the other 25 hours of dual you give while accruing the requisite 5 hrs in make and model? YGBSM.

dtuuri
 
midlifeflyer said:
==============================
(f) Instruction in multiengine airplane or helicopter. He may not give flight instruction required for the issuance of a certificate or a category, or class rating, in a multiengine airplane or a helicopter, unless he has at least 5 hours of experience as pilot in command in the make and model of that airplane or helicopter, as the case may be.
==============================
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Also, Mark, the original language here makes sense when only referring to airplanes and helicopters, but not if simply tacking on powered-lift. There are no "class" ratings for the latter. So a language change seems reasonable to refer to just "rating" which includes both categories or any classes of the three kinds of aircraft.

dtuuri
 
dtuuri seems to think he can infer that the regulations mean something other than they say. The Chief Counsel has repeatedly said you cannot make such inferences. Y'all do what you want, but my advice is to do what the regs actually say, not what dtuuri wishes they said.

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Yes, liability and medical only. If I prang her, it's on me.

I would agree. I went on a long work trip from LA to NY and back just recently, and cruised at 17,500ft for most of it going east. Not a single soul up there. No GA, no regionals, nothing. Only time I saw an airplane was when an airliner transitioned through my altitude.
 
Ron Levy said:
dtuuri seems to think he can infer that the regulations mean something other than they say. The Chief Counsel has repeatedly said you cannot make such inferences. Y'all do what you want, but my advice is to do what the regs actually say, not what dtuuri wishes they said.

-30-
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pot_calls_kettle_black.jpg
 
Do you know Joe Agreeda from AOPA forums? I think he is a aopa admin on their forums.

He lives in LA area and is a CFI. If he isn't mult E CFI I bet he has a reference through his school or organization.



stratobee said:
The Aerostar Owners Association has only one known CFII/MEI's on the west coast with lots of experience in Aerostars, but she's in Africa flying until Dec. They have loads of people that can train you in type and are approved by the insurance companies here, but for that you don't need to be a CFI (and few of them are). Nor do I need that - I've already done a 10 day type conversion in June and have flown the aircraft for over 50hrs now. I can fly Aerostars, now I need to know how to fly instruments. There are a couple of instructors back east, but then I need to either fly there or fly them here and put them up in hotels etc which becomes expensive and inflexible with my job. I'll just have to slog it out with the DPE, I suppose. Be done with the rating in 2016 at this pace... But thanks for info, I will call PIC and some of the others offering the finish up services.
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