Question about instruction.

[t-cart]

I've got a question that you guys can probably answer for me.

Can I, holding only a commercial ticket and instrument rating, provide "Ag flying" instruction in a commercial flight school environment? I DO NOT hold any instructor certificate.

I had a chief instructor at a large flight school tell me that I could. Is this correct? I would not be giving instruction towards a certificate or rating. A part 137 signoff (low level waiver) is all that is required and the "student" will recieve this from his business owner/operator.

I'd like to hear why I can or cannot do this without a CFI ticket.

Thank you.

[esa17]

Originally Posted by t-cart

I've got a question that you guys can probably answer for me.

Can I, holding only a commercial ticket and instrument rating, provide "Ag flying" instruction in a commercial flight school environment? I DO NOT hold any instructor certificate.

I had a chief instructor at a large flight school tell me that I could. Is this correct? I would not be giving instruction towards a certificate or rating. A part 137 signoff (low level waiver) is all that is required and the "student" will recieve this from his business owner/operator.

I'd like to hear why I can or cannot do this without a CFI ticket.

Thank you.

Yes, you're not giving anyone any instruction for the issuance of a certificate or rating. You are just showing them the ropes. The argument could be made that you are in a way acting as a safety pilot. Legally you could do it.

I wouldn't do it without a CFI, you're really asking for trouble. If something bad happens you'd better believe the owners will hang you out to dry and you won't have anyone on your side.

What I gather from your posts is you are a very accomplished pilot. Take a week and go add on a CFI and eliminate all the issues anyone could have.

[N18040]

One of the Ag pilots where I work was talking about doing this, but he was saying that he could also give someone a tailwheel endorsement even though he didn't have his CFI. From how I read the regs I wouldn't let someone give a tailwheel endorsement without their CFI, but I would let them show them the ropes of ag flying. I would not log it as dual given or recieved though.

[jhugz]

Originally Posted by esa17

What I gather from your posts is you are a very accomplished pilot. Take a week and go add on a CFI and eliminate all the issues anyone could have.

[Mike H]

Originally Posted by t-cart

I've got a question that you guys can probably answer for me.

Can I, holding only a commercial ticket and instrument rating, provide "Ag flying" instruction in a commercial flight school environment? I DO NOT hold any instructor certificate.

Short answer: no

Whether it's for a rating or not, you can't legally give flight instruction without an instructor's certficate.

Ask yourself how it would read in the NTSB report (or civil lawsuit) in the event of an accident

[dc3flyer]

I agree with esa that you can... cause you are not actually giving "instruction".

What I would relate this to is when I was doing aerial survey work. Sure, I have my CFI, but I would "teach" other pilots to do aerial survey work. They already knew how to fly the plane, I was only showing them how to do a particular job.

I don't know anything about a 137 endorsement, but since you will not be giving the endorsement, I don't think you would need a CFI to do what you are talking about.

[USMCmech]

Originally Posted by esa17

Yes, you're not giving anyone any instruction for the issuance of a certificate or rating. You are just showing them the ropes.

Any bum off the street can "show a new guy the ropes", only a CFI can "give instruction towards a certificate or rating".

Many aircraft salesmen are only private pilots, yet they clearly "teach" new owners about how to operate their new airplanes. I'm not a CFII, yet I have "taught" pilots how to use the G1000 in the IFR system.

Since there is no "Ag Pilot" rating, you are good to go. However you can't sign off anyone's tailwheel or HP endorsement.

[cencal83406]

Originally Posted by Mike H

Short answer: no

Whether it's for a rating or not, you can't legally give flight instruction without an instructor's certficate.

Ask yourself how it would read in the NTSB report (or civil lawsuit) in the event of an accident

As a commercial pilot, you cannot. As an "Airline Transport Pilot", you can:

FAR 61.167(b)

(b) An airline transport pilot may instruct—
(1) Other pilots in air transportation service in aircraft of the category, class, and type, as applicable, for which the airline transport pilot is rated and endorse the logbook or other training record of the person to whom training has been given;
(2) In flight simulators, and flight training devices representing the aircraft referenced in paragraph (b)(1) of this section, when instructing under the provisions of this section and endorse the logbook or other training record of the person to whom training has been given;
(3) Only as provided in this section, except that an airline transport pilot who also holds a flight instructor certificate can exercise the instructor privileges under subpart H of this part for which he or she is rated; and
(4) In an aircraft, only if the aircraft has functioning dual controls, when instructing under the provisions of this section.
(c) Excluding briefings and debriefings, an airline transport pilot may not instruct in aircraft, flight simulators, and flight training devices under this section—
(1) For more than 8 hours in any 24-consecutive-hour period; or
(2) For more than 36 hours in any 7-consecutive-day period.
(d) An airline transport pilot may not instruct in Category II or Category III operations unless he or she has been trained and successfully tested under Category II or Category III operations, as applicable.

[esa17]

Originally Posted by cencal83406

As a commercial pilot, you cannot. As an "Airline Transport Pilot", you can:

True, but here is the kicker from the "legal" stand point. He isn't involved in air transportation, he is aerial application, and there would be no endorsement required.

FAR 61.167(b)

(b) An airline transport pilot may instruct—
(1) Other pilots in air transportation service in aircraft of the category, class, and type, as applicable, for which the airline transport pilot is rated and endorse the logbook or other training record of the person to whom training has been given;
(2) In flight simulators, and flight training devices representing the aircraft referenced in paragraph (b)(1) of this section, when instructing under the provisions of this section and endorse the logbook or other training record of the person to whom training has been given;
(3) Only as provided in this section, except that an airline transport pilot who also holds a flight instructor certificate can exercise the instructor privileges under subpart H of this part for which he or she is rated; and
(4) In an aircraft, only if the aircraft has functioning dual controls, when instructing under the provisions of this section.
(c) Excluding briefings and debriefings, an airline transport pilot may not instruct in aircraft, flight simulators, and flight training devices under this section—
(1) For more than 8 hours in any 24-consecutive-hour period; or
(2) For more than 36 hours in any 7-consecutive-day period.
(d) An airline transport pilot may not instruct in Category II or Category III operations unless he or she has been trained and successfully tested under Category II or Category III operations, as applicable.

61.191 & 61.193 outline the instructor limitations and privileges and all of this falls outside their scope.

[cencal83406]

Originally Posted by esa17

True, but here is the kicker from the "legal" stand point. He isn't involved in air transportation, he is aerial application, and there would be no endorsement required.



61.191 & 61.193 outline the instructor limitations and privileges and all of this falls outside their scope.

I was merely trying to be Mr. Smarty-Pants and point out that "just because" you don't have the CFI doesn't mean you can't provide instruction....

I know that it's a very limited scope.

[Douglas]

T-Cart, just be careful the people you are "showing the ropes" to don't think you are giving them "instruction" in any way, shape or form. That could come back to bite you after somebody piles one in.

[anthenry]

Agreed, you can. This is not dual given, or as stated before instruction toward a rating or certificate, or even an endorsement technically, because you are not signing it off. You are also not signing a logbook with 'CFI' at the end of you certificate number.
That being said, it wouldn't hurt to run it by the schools POI. If this school, being a large flight school, is 141, I really don't see it being ok. To flight instruct under a 141 syllabus, CFI would be required.

[CN94559]

I would say its okay for you to do it as long as you make sure you cover yourself as "showing the ropes" not "instruction" in case anything goes wrong.

I'm sorta in the same situation with the guy I'm being "instructed by" for aerobatics. He is not a CFI, but we go up and fly the plane and I just sorta learn how to do it. He's showing me the ropes of the plane, not instructing me.

[OhioStatePilot]

Originally Posted by anthenry

Agreed, you can. This is not dual given, or as stated before instruction toward a rating or certificate, or even an endorsement technically, because you are not signing it off. You are also not signing a logbook with 'CFI' at the end of you certificate number.
That being said, it wouldn't hurt to run it by the schools POI. If this school, being a large flight school, is 141, I really don't see it being ok. To flight instruct under a 141 syllabus, CFI would be required.

Where does Ag fit into a 141 syllabus?

[anthenry]

It fits in under 141.11(b)(2)(iv).

[OhioStatePilot]

Originally Posted by anthenry

AGI is ground. So it fits in on the ground.

He's referring to Ag as in Agricultural Aerial Application flying.

[anthenry]

Ah. I understand what you are saying. I apologize. It fits in under 141.11(b)(2)(iv). Now I'm not saying that the school is approved for this course, just that asking the POI what he thought of these operations would be a good place to start. If there is a student paying money to learn something from a flight school it could certainly be misubnderstood that this is 'flight instrucing' and the person that oversees that schools 141 certificate would be a good person to get a justment call on the matter.

After reading Part 137, specifically 137.19, and 137.41, the wording used is "supervisor". It says nothing about instruction, or certified instructor.

[nosehair]

So,...I hope everyone reading this will grasp the concept that flight instruction that requires a CFI is only the instruction required under part 61 in the pursuit of a certificate or rating. I think the question arises about what is a rating? That's all under part 61 which is Sport, Rec, Private, Instrument, Comm, ME/SE, etc. There are lots of non-cfi teaching sessions going on, especially in the new-era electronics. and I'm sure they're highly paid,..probably more than the lowly cfi. ...oh, and by the way, whether you have a commercial or not makes no difference. A non-pilot computer geek, or a local area mountain guide can do the same job for more pay.

[WacoFan]

Like a lot of people on this thread, it may be legal - but I wonder what kind of personal liability you would have?

How can you protect yourself/family/personal assets if one of the people you are "showing the ropes" to crash and die or become disabled a month after you have done this? The family could conceivably come back on you at this point - so how are you going to protect yourself?

The FAA will also go to an instructor if a student crashes sometimes. I think they can give a 709 ride to you to asses competence. If you have no instructor ticket, is the 709 ride for your commercial certificate, and if so - is that something you really want to risk? (Not sure if this point is a valid point - just thinking out loud here.)

[Mike H]

Originally Posted by nosehair

So,...I hope everyone reading this will grasp the concept that flight instruction that requires a CFI is only the instruction required under part 61 in the pursuit of a certificate or rating. .

How about a IPC? The pilot's already got the certificate & rating there

Flight review? Same story, no?

Back to the topic. If what we're talking about is simply "showing somebody how to do the job", I don't know if I'd call that "flight instruction"

What does the FSDO have to say about it?

[Douglas]

Originally Posted by anthenry

Ah. I understand what you are saying. I apologize. It fits in under 141.11(b)(2)(iv). Now I'm not saying that the school is approved for this course, just that asking the POI what he thought of these operations would be a good place to start. If there is a student paying money to learn something from a flight school it could certainly be misubnderstood that this is 'flight instrucing' and the person that oversees that schools 141 certificate would be a good person to get a justment call on the matter.

After reading Part 137, specifically 137.19, and 137.41, the wording used is "supervisor". It says nothing about instruction, or certified instructor.

dood, The 141 flight school has nothing to do with T-Cart or his operation. He just used the 141 instructor advice in this matter, much like he is using us for advice. T-Cart am I right? That is how I read it.

[tlewis95]

I would ask the FSDO.

[esa17]

Originally Posted by Mike H

How about a IPC? The pilot's already got the certificate & rating there

Flight review? Same story, no?

See the phrase: "authorized instructor".

[texas_pilot]

I would think that you could, much as a line pilot can IOE a Newbie on operating procedures in part 135 operations.

[Patrick]

I'm inclined to think that yes, per the FARs, you could provide "on the job training," which is not "instruction" (and certainly not instruction toward a cert or rating). From a legal liability standpoint, I don't think I'd want to put myself into that situation, even if protected by an LLC.