Teaching in a Multi with no MEI

[Fly_Unity]

Scenario:

# 1 person has a Multi commercial license, CFI, CFII, MEI (and no turbine time)

# 2 person has Multi Commercial and CFI and CFII But no MEI (and 100 hours of King Air time)

Can # 2 give dual to #1 like in a King Air 90 As instrument training?

I remember a letter someone showed from the FAA saying that one could give Instrument training in a Multi Engine Aircraft without an MEI. Does anyone know where that is?

[tgrayson]

Originally Posted by Fly_Unity

I remember a letter someone showed from the FAA saying that one could give Instrument training in a Multi Engine Aircraft without an MEI. Does anyone know where that is?

The original Part 61 regulations were written poorly regarding this, but the interpretations of them by the FAA clearly allowed this sort of training to occur. However, the recent Part 61 changes reworded the pertinent regulation and makes the previous FAA interpretation much more of a stretch. Whether this was intentional or not, I don't know. I submitted a letter to the FAA Chief Counsel's Office immediately after the Final Ruling requesting clarification, but haven't receive a response as yet.

[Douglas]

Edit: memory needs to change.

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[poser765]

Originally Posted by tgrayson

The original Part 61 regulations were written poorly regarding this, but the interpretations of them by the FAA clearly allowed this sort of training to occur. However, the recent Part 61 changes reworded the pertinent regulation and makes the previous FAA interpretation much more of a stretch. Whether this was intentional or not, I don't know. I submitted a letter to the FAA Chief Counsel's Office immediately after the Final Ruling requesting clarification, but haven't receive a response as yet.

What tgrayson said. I don't remember how it was worded in the the changes, but I do remember reading it and thinking "oh no more multi instructing without an MEI." So to avoid possible problems down the road I would hold off for a little while at least.

[CFIT99]

Originally Posted by Douglas

I'd have to dig it up somewhere but the answer was yes you can as long as you stick to teaching instruments and not multi.
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correct...as long as your not teaching multi your in the clear

just stick with the instrument training (remember though there is some multi flows to worry about, i.e. approach/landing checklists)

[MidlifeFlyer]

Originally Posted by tgrayson

The original Part 61 regulations were written poorly regarding this, but the interpretations of them by the FAA clearly allowed this sort of training to occur. However, the recent Part 61 changes reworded the pertinent regulation and makes the previous FAA interpretation much more of a stretch. Whether this was intentional or not, I don't know. I submitted a letter to the FAA Chief Counsel's Office immediately after the Final Ruling requesting clarification, but haven't receive a response as yet.

Good.

Here's what the FAA said the revised reg says:

==============================
In accordance with Sec. 61.195(b)(1), a flight instructor who does not hold the appropriate airplane multiengine rating on his/her flight instructor certificate and the appropriate airplane category multiengine class rating on his/her pilot certificate may not conduct instrument training in a multiengine airplane unless that flight instructor holds the appropriate airplane category multiengine class rating on his/her pilot certificate and flight instructor certificate. A flight instructor who only holds a flight instructor certificate with an Instrument-Airplane rating and no airplane category multiengine class rating on his/her pilot certificate may not conduct instrument training in a multiengine airplane. 74 Federal Register at Page 42536. 74 Federal Register at Page 42536
==============================

Two sentences that may suggest completely different answers. And the first one is double talk: A CFI without A and B can't give the training unless the CFI has A and B.

[Fly_Unity]

Originally Posted by MidlifeFlyer

Good.

Here's what the FAA said the revised reg says:

==============================
In accordance with Sec. 61.195(b)(1), a flight instructor who does not hold the appropriate airplane multiengine rating on his/her flight instructor certificate and the appropriate airplane category multiengine class rating on his/her pilot certificate may not conduct instrument training in a multiengine airplane unless that flight instructor holds the appropriate airplane category multiengine class rating on his/her pilot certificate and flight instructor certificate. A flight instructor who only holds a flight instructor certificate with an Instrument-Airplane rating and no airplane category multiengine class rating on his/her pilot certificate may not conduct instrument training in a multiengine airplane. 74 Federal Register at Page 42536. 74 Federal Register at Page 42536
==============================

Two sentences that may suggest completely different answers. And the first one is double talk: A CFI without A and B can't give the training unless the CFI has A and B.

So this is the "newest" regs? Does this mean I can not receive a BFR in a Twin unless I have an MEI do it?

[AP2B]

Originally Posted by MidlifeFlyer

Two sentences that may suggest completely different answers. And the first one is double talk: A CFI without A and B can't give the training unless the CFI has A and B.

It's funny too, because it is: A CFI without A and B can't give training unless the CFI has B and A... lol


Also, fwiw, the wording change in 61.195(c) just switched around some of the wording.

New Wording:

must hold an [instrument rating on his or her pilot certificate] and [flight instructor certificate that is appropriate to the category and class of aircraft used for the training provided].

Old Wording:

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]...

The old wording allowed the interpretation you could provide instrument flight training in a multi with no MEI. The new wording does not in any way that I can see.


Definitely need an MEI for a flight review in a multi.

[Douglas]

I can only reason that they changed the wording because the wanted to change the meaning.


It's my opinion that you cannot do the BFR.

[tgrayson]

Originally Posted by Douglas

I can only reason that they changed the wording because the wanted to change the meaning.

Or at least ONE person wanted to change the wording in order to "clarify" what he thought the regulation really meant. Had this been a consensus within the organization, they would likely have retracted their interpretation well before this point. I wonder how many -II only instructors have become disenfranchised?

[Douglas]

Could be that too.

[Mike H]

Originally Posted by Fly_Unity

Scenario:

# 1 person has a Multi commercial license, CFI, CFII, MEI (and no turbine time)

# 2 person has Multi Commercial and CFI and CFII But no MEI (and 100 hours of King Air time)

Can # 2 give dual to #1 like in a King Air 90 As instrument training?

I remember a letter someone showed from the FAA saying that one could give Instrument training in a Multi Engine Aircraft without an MEI. Does anyone know where that is?

In this scenario, I don't see how CFI #2 would be giving instrument instruction or training to CFI #1. #1 already has an instrument rating- both of them have instrument ratings, so if anything, #2 would be acting as a safety pilot (unless an IPC was being conducted, but that's not part of the scenario) The C90 doesn't require a type rating, so #2 wouldn't be giving multi instruction either.

[MidlifeFlyer]

Originally Posted by Fly_Unity

So this is the "newest" regs? Does this mean I can not receive a BFR in a Twin unless I have an MEI do it?

You couldn't have a BFR in a twin without an MEI doing it even before the re-write.

[MidlifeFlyer]

Originally Posted by tgrayson

Or at least ONE person wanted to change the wording in order to "clarify" what he thought the regulation really meant. Had this been a consensus within the organization, they would likely have retracted their interpretation well before this point.

It was really weird on the question whether a CFI with an instrument rating, no CFI-AME rating but a commercial pilot certificate with an AMEL rating could teach instruments in a multi.

• John Lynch had an interpretation in the orphaned FAQ that the CFI could.
• FAA Legal (at least Regional Counsel in New York) said the CFI could not. Lynch was going to look into revising the FAQ based on the Regional Counsel opinion.
• The FAA Order that deals with a whole bunch of issues said the CFI could.
• At least one CFI got caught up in a certificate action on the issue (it was dropped).
• In the explanatory material for the October 2009 revision, Lynch comes up with the strange explanation - which should have been much clearer given the confused history.

[tgrayson]

Originally Posted by MidlifeFlyer

It was really weird

In my letter, I explicitly quoted the FAA Order that said you could and at least referenced the FAQ that said you could, and also quoted the FAA response to the comments on the NPRM that said you couldn't. Hopefully, that evidence will prevent them from dancing around on the issue.

[Roger, Roger]

I hope they get their stuff straight.

"Thou shalt not give ANY dual instruction in ANY aircraft for which thou doest not have a category/class instructor rating".

[MidlifeFlyer]

Originally Posted by Roger, Roger

I hope they get their stuff straight.

"Thou shalt not give ANY dual instruction in ANY aircraft for which thou doest not have a category/class instructor rating".

Personally, I not sure it really matters that much. Take the multi example:

• The instrument rating is category, not class specific to begin with - the rating is "instrument airplane" not "instrument single-engine airplane." Even the currency rules are category and not class-specific.
• The CFI has a CFI-IA showing qualification to teach instrument procedures in the airplane category.
• The CFI, although not having a CFI-AME rating, does have a Commercial pilot certificate with an AMEL rating.
• The student is already multi-rated.

The biggie on the other side is the single-engine approach - a multi-specific instrument procedure with the question being whether the combination of commercial multi-pilot and CFI-IA is enough for both instructional competence and safety.

I think the question is close enough that there's not a clear "right" and "wrong" and it's a matter of opinion with the only one ultimately counting being the FAA's

[Roger, Roger]

Originally Posted by MidlifeFlyer

Personally, I not sure it really matters that much. Take the multi example:

• The instrument rating is category, not class specific to begin with - the rating is "instrument airplane" not "instrument single-engine airplane." Even the currency rules are category and not class-specific.
• The CFI has a CFI-IA showing qualification to teach instrument procedures in the airplane category.
• The CFI, although not having a CFI-AME rating, does have a Commercial pilot certificate with an AMEL rating.
• The student is already multi-rated.

Meh. My personal opinion is that if one is teaching in an aircraft, one should be qualified to teach in the aircraft.

[tgrayson]

Originally Posted by Roger, Roger

....if one is teaching in an aircraft, one should be qualified to teach in the aircraft.

And a CFI-A is more qualified, in a real sense, to teach in that aircraft than a CPL-A ? I don't buy that.

[wjmiller3]

Originally Posted by tgrayson

And a CFI-A is more qualified, in a real sense, to teach in that aircraft than a CPL-A ? I don't buy that.

The FAA would prabably say so!!

[Roger, Roger]

Originally Posted by tgrayson

And a CFI-A is more qualified, in a real sense, to teach in that aircraft than a CPL-A ? I don't buy that.

I'm not sure what you're saying here. I do believe that someone who is a CFI-AMEL is more qualified to teach in a multi (whether they're teaching instrument or not) than a CFI-ASEL/C-AMEL. Maybe I'm inflating the value of CFI-AMEL training though.

[tgrayson]

Originally Posted by Roger, Roger

Maybe I'm inflating the value of CFI-AMEL training though.

It surely depends on the training received, but an MEI add-on to a FI certificate is often less than 5 hours training, mostly just doing the multi-stuff from the right seat. And the training is often given by another low-time flight instructor, who is probably giving away his instructional time as a courtesy and to log the ME time. I don't see a lot of instructional value in that, although the extra ME time doesn't hurt.

[Roger, Roger]

Originally Posted by tgrayson

It surely depends on the training received, but an MEI add-on to a FI certificate is often less than 5 hours training, mostly just doing the multi-stuff from the right seat. And the training is often given by another low-time flight instructor, who is probably giving away his instructional time as a courtesy and to log the ME time. I don't see a lot of instructional value in that, although the extra ME time doesn't hurt.

The same thing could be said of the pump-em-through CFII initials that are teaching in airplanes with no category rating.

[tgrayson]

Originally Posted by Roger, Roger

The same thing could be said of the pump-em-through CFII initials that are teaching in airplanes with no category rating.

Absolutely. That's why I don't associate ratings with being "qualified". The only student I ever had who produced an inadvertent Vmc roll off was already an MEI.

[nosehair]

Originally Posted by tgrayson

I don't associate ratings with being "qualified".

..aah, now I understand your madness. I understand it, but let's take that to extreme and say any instruction beyond solo is worthless. Let's just don't have any "qualifications", let's just trust that every individual will, of course, get whatever training that person needs to be safe and proficient at the job, but throw out the "rating" system.
I agree. I think that's the way it should be. But do you really think most of us can do that?