Instrument Dual in a Multi

[peter185]

Can I legally give instrument dual as a CFI-I in a multiengine airplane if I have a multiengine rating but no MEI?

Or would that time just be considered safety pilot time?

 

[JB74]

§ 61.195 Flight instructor limitations and qualifications.

A person who holds a flight instructor certificate is subject to the following limitations:

(b) Aircraft ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:

(1) A pilot certificate and flight instructor certificate with the applicable category and class rating

(c) Instrument Rating. A flight instructor who provides instrument flight training for the issuance of an instrument rating or a type rating not limited to VFR must hold an instrument rating on his or her flight instructor certificate and pilot certificate that is appropriate to the category and class of aircraft in which instrument training is being provided.

The way I read it, no. It is only SP time.

 

[BritishGuy]

Just so long as you're teaching insturments to the guy, you don't need an MEI. So it's PIC time.

 

[Lead Sled]

Hey Pete...

Aviation Internet Message Board Rule #1: Never, ever, take anything you read on one of these boards as the gospel truth.

With that in mind, why don't you just ask one the your friendly local feds what his intrepretation is. After all, s/he'll be the one who will be pressing charges against you if his/her opinion differs from yours.

That being said, I happen to agree with JB74 - but then it's never come up before and I haven't discussed it with the feds. As an active CFI, it's probably a good thing to have a cordial, working relationship with the Feds. They're actually, for the most part, friendly and quite helpful.

Lead Sled

 

[FlyFastLiveSlow]

I actually have had this discussion with the FAA. If the person whom you are instructing in multi-engine rated and you are multi engine rated and you are giving him instruction only for the purposes of an instrument rating it is legal. Although I agree....clarify it with your local FSDO.

 

[Ralgha]

Um, JB74 just quoted the regs. Why do you others say otherwise?

If you are not an MEI, you can not provide instruction of any kind in a twin.

Also, if you get your initial CFI as an instrument instructor, you can't provide any flight instruction until you tack on either a single or multi engine rating to that CFI ticket.

 

[EDUC8-or]

Call your local federales and see what they say. My local FSDO has said if the student already holds at least a PPL in the category and class of what you're using for the instrument rating, you're good to go.

I haven't seen it done in a twin, but I know several guys who got their CFII initial and had students before the CFI add on.

Personally I would just get the MEI. You can always call the FSDO. Make sure you get the name of who you are speaking with, it might come in handy one day.

 

[nosehair]

Experience is Sometimes a Hindrance

Yeah, it used to be that you could do instrument instructing in a twin without the MEI, as long as you did only instruments. But it has changed. 61.195 (b)(1) & (c)(1) both say that. Flight Instructor. Category and Class. Black and White on this one. You still hear it the other way, because so many of the old heads, incliding Examiners and Inspectors, who just have not come across it yet.

 

[midlifeflyer]

Um, JB74 just quoted the regs. Why do you others say otherwise?

Probably because John Lynch's Part 61 FAQ has caused a lot of confusion. JB74 is exactly right, but here's the problem (personal FAQ)

******************************
The common wisdom has been that a CFI with only an "instrument airplane" rating, but no "airplane" rating is permitted to provide instrument training in an airplane, so long as he doesn't cross the line into teaching how to fly the airplane itself. Even John Lynch's Part 61 FAQ has taken this view, saying such things as a CFII with no MEI =can't= give training in one-engine failure during takeoff but =can= give instruction in single-engine operations under instrument conditions.
Finally, as a result of an inquiry by Ron Levy, an instructor at the University of Maryland and a regular contributor to Aviation Safety Magazine, the Eastern Region FAA legal counsel has started the process of putting that one to rest.

The ultimate answer is, no, a CFII with a commercial single and multi (No MEI) can =not= I give instrument instruction to a student in a Multi-engine aircraft who already has his private multi.

The response from the counsel is posted below. The full opinion takes a bit of wading to get through it since it goes off on a completely different question. I've included what I thik are the pertinent parts.

==============================
JAN 6 2004

Capt Ronald B. Levy
Director, Aviation Sciences Program
University of Maryland Eastern Shore
30806 University Boulevard South
Princess Anne, MD 21853-1299

Dear Capt. Levy:

This responds to your request for an interpretation of 14 CFR § 61.195 pertaining to the providing of instrument instruction. You have raised your disagreement with information contained in the FAA web site maintained by flight Standards (specifically, AFS-840) where answers are provided to frequently asked questions (FAQs). We apologize for the delay in providing this response to you and appreciate your patience.

Your related question deals with the qualifications to provide instrument training corresponding to the category and class of the aircraft. As you point out, § 61.195(b) provides, “A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold: (1) A pilot certificate and flight instructor certificate with the applicable category and class rating; and (2) if appropriate, a type rating.” You have indicated that some persons hold the belief that the possession of a CFI-IA authorizes the holder to provide instrument training without regard to the class rating held, a belief you do not share.

In construing § 61.195(b), we must rely on the plain language since it appears to be unambiguous and we are not aware of any agency-condoned practices that deviate. Section 61.195(b) refers specifically to category and class, as you have pointed out. The category of aircraft is airplane, but the class can consist of, for example, single engine, multiengine, land, and water (sea), as defined in 14 CFR 1.1. As provided in 61.195(b), to provide flight training, the instructor must bold both a pilot certificate and a flight instructor certificate with the category and class rating applicable to the training being provided. For example, an instructor must hold a pilot certificate and an instructor certificate, each with an airplane multiengine instrument rating, to give instrument training in a twin airplane (empgasis added). We do not construe Q&A-249 as indicating any other position.

I trust that this response satisfactorily answers your question. Should you need any further clarification, please contact Stephen Brice in this office at 718 553-3268.

Sincerely,

Loretta E. Alkalay

==============================

There is a follow-up:

Scott Dennstaedt sent a copy of the Eastern Region opinion to John Lynch, who responded:

*************************************************************************

I see where you indicate the conflict on page 3 of Ms. Alkalay's letter:

"For example, an instructor must hold a pilot certificate and instructor certificate, each with an airplane multiengine instrument rating, to give instrument training in a twin airplane."

However, the reference you used for the one answer in Q&A-249 is not the one where it conflicts with the legal interpretation. More so, further up (as stated below) where I gave an example to answer a long list of questions is where there is a conflict.

Another example. A flight instructor, who only holds a CFII-A rating is giving instrument training to an Instrument-Airplane applicant in an multiengine land airplane. That flight instructor must hold the following:

Flight Instructor Certificate
Commercial Pilot Certificate or ATP Instrument-Airplane
Airplane Multiengine Land

Instrument-Airplane

Looking at § 61.195(c), I now believe my answer is wrong and Ms. Alkalay's answer is correct. Because, per § 61.195(c), it states: ". . . must hold an instrument rating on his or her flight instructor certificate and pilot certificate that is appropriate to the category and class of aircraft in which instrument training is being provided."

I will need to consult with our attorney in AGC-200 to resolve the issue. I will be in touch with you.

John D. Lynch

 

[JB74]

Also, I wouldn't want to be a CFI taking his MEI ride with a logbook showing 40hrs dual given in a Seminole.