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Originally Posted by ElyJs  I know you must be a ii for instruction for a rating but where in the regs does it say you can't do IPC's? "Authorized instructor" that means ii? Maybe someone else has the crystal clear reg. |
The issue isn't crystal clear. The regs don't forbid a CFI from doing instrument training, but the FAA has taken a harder line in their interpretation of the regulations. The various FAQs say that it takes a -II to do an IPC and a -II to do the instrument training for the Commercial, but a regular CFI can do the "flight by reference to instruments" for a PPL. When the question was asked to them about using a -II for the 15 hours of required instrument training for the instrument rating, and a regular CFI outside of that, they said "no", but it's not clear that they actually understood the question. Still, none of those interpretations are regulatory and aren't as binding on FSDO's as much as a letter of interpretation from the General Counsel's Ofice.
Based on the trend of the interpretations, the intent appears to be that it takes a -II to do instrument training and that's as it should be, IMO. However, no regulation explicitly says so. My view is that a CFI providing this training would be prudent to log it as "flight by reference to instruments". Hopefully, the future revision of Part 61 regulations will make this clearer, but I'm not counting on it.