Do you or do you not.....

[X-Forces]

Need a CFII to give a IPC?

I have got a bet going, but the regs are a bit ambiguous . Anyone know for sure?


KD

[mojo6911]

An IGI can do it in an approved FTD/SIM.

[MidlifeFlyer]

Originally Posted by mojo6911

An IGI can do it in an approved FTD/SIM.

Problem is, are there any available sims that are certified for all of the tasks required for an IPC?

KD, I have never seen the FAA formally answer the specific question, so you can be stuck with an argument, but everything else I've read on the subject leads me to the conclusion that an "authorized instructor" for anything that involves training or endorsing something that is to be counted toward instrument ratings or qualifications, must be done by an instrument instructor (flight or ground).

Other than playing "pretend lawyer" with the language of the regs, what is the argument being made that the FAA is interested in instructors who have not themselves been qualified to teach and evaluate instrument pilots passing on the qualifications of someone to safely operate in the system?

[mojo6911]

Originally Posted by MidlifeFlyer

Problem is, are there any available sims that are certified for all of the tasks required for an IPC?

I am not sure, as I haven not seen the letter of authorization, but I would assume the sims at a place like Simuflite or Flight Safety have the proper authorization, and I know for a fact that some of their instructors only have IGI/AGI, without a CFII.

[tgrayson]

Originally Posted by X-Forces

Need a CFII to give a IPC?

I have got a bet going, but the regs are a bit ambiguous . Anyone know for sure?KD

Here's what the old FAQ's said about the subject:

================================
QUESTION: Is it true that a CFI giving an endorsement for an Instrument Proficiency Check must have an instrument rating (CFII) on his/her flight instructor certificate? I can't seem to find anything in the current Part 61 that states that an Instrument Proficiency Check endorsement requires a CFII. The §61.57(d)(2)(iv) requires an “authorized instructor”. The definition of “authorized instructor” now seems to come from § 61.193 (Flight Instructor Privileges) and § 61.195 (Flight Instructor Limitations). The only reference to a requirement for a CFII that I can find is in § 61.195(c).

ANSWER: Ref. § 61.57(d)(2)(iv) and § 61.193; A flight instructor who performs an instrument proficiency check, as required by § 61.57(d), must hold the appropriate instrument rating for the category and class of aircraft that the instrument proficiency check is being conducted in. As per §61.193, it states in pertinent part, “. . . A person who holds a flight instructor certificate is authorized within the limitations of that person's flight instructor certificate and ratings to give training and endorsements that are required for, and relate to:
* * * * *
(f) An instrument rating;

A flight instructor who does not hold an instrument rating on their flight instructor certificate that is appropriate to the category and class of aircraft that the instrument proficiency check is being conducted in is not authorized to conduct the instrument proficiency check.

The term “authorized instructor” was intentionally used in § 61.57(d) because authorization to conduct an instrument proficiency check is not limited to a CFII. A Ground Instructor Certificate - Instrument Rating is also an “authorized instructor” and is authorized to give the instrument proficiency check in an approved flight training device. Also, a Part 142 training center instructor, who may or may not hold any certificate or ratings, can be an “authorized instructor” who may give the instrument proficiency check that is performed under an approved Part 142 training program in an approved flight simulator, in accordance with a Part 142 approved training program.

Another example, a pilot who holds a Letter of Operational Authority (LOOA) may give the endorsements for the instrument proficiency check to a holder of a Letter of Authorization (LOA).) Holders of an LOOA give training for the endorsement for the Letter of Authorization (LOA) allowing a pilot to act as pilot in command in surplus military turbine or piston powered airplane, in accordance with FAA Order 8700.1, Chapter 32. However, in this case, the holder’s Letter of Operational Authority (LOOA) must specifically state this authority to give the endorsements for the instrument proficiency check. And so the rulemaking team that drafted the new Part 61 decided on merely stating . . . An authorized flight instructor . . .” But notice in §61.57(d)(2)(v), we also included “. . . A person approved by the Administrator to conduct instrument practical tests.”
=============================================

[MidlifeFlyer]

Originally Posted by mojo6911

I am not sure, as I haven not seen the letter of authorization, but I would assume the sims at a place like Simuflite or Flight Safety have the proper authorization, and I know for a fact that some of their instructors only have IGI/AGI, without a CFII.

I am sure there are a few, but there are not many sims/FTDs generally available at flight schools/FBOs that are certified for circling approaches.

[MidlifeFlyer]

Originally Posted by tgrayson

Here's what the old FAQ's said about the subject:

That's why I said I never saw the FAA "formally" answer the question.

[tgrayson]

Originally Posted by MidlifeFlyer

That's why I said I never saw the FAA "formally" answer the question.

Yes, I knew *exactly* why you phrased it that way.

[Berkut]

Originally Posted by MidlifeFlyer

KD, I have never seen the FAA formally answer the specific question

I stumbled across an old post of yours on this forum that seems to contain an FAA legal opinion that covers this:
http://forums.jetcareers.com/308871-post11.html

But if you’re asking whether a CFI-ASE only can administer the Instrument Proficiency Check of § 61.57(d), the answer is no. The flight instructor must hold a CFII-Airplane rating to administer the Instrument Proficiency Check of § 61.57(d).

Is this not considered a formal answer? Am I missing something?

[MidlifeFlyer]

Originally Posted by Berkut

I stumbled across an old post of yours on this forum that seems to contain an FAA legal opinion that covers this:
http://forums.jetcareers.com/308871-post11.html
Is this not considered a formal answer? Am I missing something?

Choose the correct answer:

1. That's an old post. You think I remember everything?
2. That was a Regional opinion and I've become hesitant about calling a Regional response "official."
3. Heck, the main part of the Legal opinion was wrong (about what a CFII with no aircraft rating is allowed to do), so why not this part also?
4. All of the above

[SlantG]

Here's the simple answer: To avoid an FAA enforcement investigation, have the instrument rating for the appropriate aircraft category on the flight instructor certificate.

Ref:
61.195(c) (an IPC is "for a rating", limitations)
61.193(f) & (g) (privileges)
61.57(c)(2)(iv) (authorized instructor)
61.1(b)(2)(i-iii) (defines authorized instructor)

61.1 (2) Authorized instructor means--
(i) A person who holds a valid ground instructor certificate issued under part 61 or part 143 of this chapter when conducting ground training in accordance with the privileges and limitations of his or her ground instructor certificate;
(ii) A person who holds a current flight instructor certificate issued under part 61 of this chapter when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate; or
(iii) A person authorized by the Administrator to provide ground training or flight training under SFAR No. 58, or part 61, 121, 135, or 142 of this chapter when conducting ground training or flight training in accordance with that authority.

[mjg407]

Originally Posted by MidlifeFlyer

Problem is, are there any available sims that are certified for all of the tasks required for an IPC?

there are lots of companies who specialize in IPCs, but it's probably more than the average Joe would want to spend. We are required by our contract to have an annual IPC done by a "professional" simulator company, but it costs about 2K, plus the cost of getting there.