Can an MEI (without CFII) train for add-on multiengine ratings?

RussR

RussR

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This question was brought to me by a coworker.

He is a CFI-Airplane Single Engine and Multiengine. He is NOT a CFI-Instrument Airplane. (In common vernacular, he is a CFI and MEI but not a CFII.)

Can he train someone for an "add-on" multiengine rating if the applicant is instrument rated, and therefore will need to conduct a single engine instrument approach on the checkride (and therefore obviously must need to do it a few times in training)?

So a Private Pilot - ASEL, IA adding on a Private-AMEL rating, or the same for a Commercial Pilot.

I think the legal answer is "yes, he can". Here is my reasoning.

1) A CFI is required to be a CFII in order to conduct "instrument training for the issuance of an instrument rating... or the instrument training required for commercial pilot and ATP certificates..." (61.195(c)).
2) The applicant is not working on an instrument rating, so that part doesn't apply.
3) There is no instrument training required for adding an AMEL rating onto an existing CP-ASEL certificate - such applicant do not need to meet any specific training requirements (61.63(c)(3)).
4) There is no mention of Private Pilot training in this 61.195(c), but even if they were, it would be the same situation as my #3.

So, there is no instrument training required for the AMEL add-on. But the applicant does need to be able to fly the approach on the checkride. So I guess while practicing for this, the non-CFII would be acting as a safety pilot only?

I did search the Chief Counsel site.
 
I agree with your conclusion, except the part where you guess the single-I can only act as safety pilot during approaches.

61.195(c) is pretty clear about when you need an instrument instructor rating. The fact that "type rating not limited to VFR" is enumerated as requiring a CFII but that "class rating not limited to VFR" is not one of the things that requires a CFII also helps answer your question.
 
I think there was a LOI a few years ago that said CFII not needed. But don’t take as gospel.
 
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The answer to all these questions is get the damn rating
 
If I understand your question correctly….. the non-Cfii can only sign off the student for a ME rating (VFR by default), not the IFR rating/privileges. So, the student would only end up with a ME rating on their pilots certificate for either the private or commercial certificate. Likely, when the FAA system sees that the application for instrument rating, and the endorsing Cfi doesn’t have that rating, it would probably kick it back. With some exemptions….
the only time a non Cfi, or A non instrument rated cfi can conduct required training is an ATP pilot with a type rating providing specific training for that type aircraft. Also, an already ATP can self endorse for a check ride.
 
They aren't letting people do "VFR only Multi ratings" anymore, if the pilot already has Instrument Airplane and Single Engine Land.

Get the rating and do it right, you have to sign off that you have taught and they have to demonstrate a instrument work in a multi environment, including the single engine ILS and manuevering.
 
My MEI for my multi add on was not a CFII. I still got instrument privileges on both single and multi after my checkride
 
Just because it has happened, doesn't mean that it is right/legit.
How often are the signing off CFI's credentials actually checked for anything?
 
ja_user said:
Just because it has happened, doesn't mean that it is right/legit.
How often are the signing off CFI's credentials actually checked for anything?
Click to expand...

Just because it doesn't seem right doesn't mean it isn't. Read the reg.
 
ja_user said:
I've read it plenty. What exactly are you trying to argue here?
Click to expand...
Nothing in the reg requires an instrument rating for the instructor in a multi-addon. 61.195(c) details what you need the rating for. For a TYPE rating, not limited to VFR you need to be an II, but for a multi add-on, no such requirement.
 
flyingron said:
Nothing in the reg requires an instrument rating for the instructor in a multi-addon. 61.195(c) details what you need the rating for. For a TYPE rating, not limited to VFR you need to be an II, but for a multi add-on, no such requirement.
Click to expand...

Right, that couldn't be a requirement because there are Multi pilots out there without IFR ratings. Those could obviously be taught by Multi Instructors without the II all day long.

But what you can't do, is take a checkride as a single engine instrument-airplane pilot, and add multi with VFR-only privilege's anymore.
 
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ja_user said:
I've read it plenty. What exactly are you trying to argue here?
Click to expand...

Kai stated: "My MEI for my multi add on was not a CFII. I still got instrument privileges"
You replied: "Just because it has happened, doesn't mean that it is right/legit. How often are the signing off CFI's credentials actually checked for anything?"

It sure seemed to me like you were asserting Kai's situation was illegitimate and that the instructor was not qualified. A position that I stated the reg does not support. Then you ask me what I'm trying to argue? Are you that lost or deliberately trying to be passive aggressive and cryptic?
 
I'm just saying, that there are checkrides that happen where applicants apply without the required pre-requisites for the rating. Actually it happens a lot, sometimes they actually pass and get through.
The credentials of the signing off CFI are probably the least looked at item.

It's clear that a CFI is allowed to teach the "flight by reference to the instruments" for a student to obtain their PPL. It is also clear that a CFII is required for instrument-Airplane privilege's.

We all know that a CFI can sign off the add on multi to a rating, if Instrument airplane is not involved. However the FAA now says if you have instrument airplane single, you can no longer opt to have Multi "VFR only", this is now a relic of the past.

So you are arguing that a CFI without CFII rating is allowed to teach the multi engine tasks by reference to instruments during engine failure, but also the single engine ILS approach technics. I am simply arguing that they are not allowed to teach the approach which is required....

Where else is a CFI that is not a CFII, REQUIRED to sign off and attest to an applicants ability to shoot an approach? On what basis is the pilot adding the instrument airplane rating to a new category without an instructor that can actually sign that off?
 
ja_user said:
So you are arguing that a CFI without CFII rating is allowed to teach the multi engine tasks by reference to instruments during engine failure, but also the single engine ILS approach technics. I am simply arguing that they are not allowed to teach the approach which is required....

So you are arguing that a CFI without CFII rating is allowed to teach the multi engine tasks by reference to instruments during engine failure, but also the single engine ILS approach technics.
Click to expand...

I didn't argue, I described what the reg states. Your response was that you know what it says and have read it "plenty" of times.
ja_user said:
I am simply arguing that they are not allowed to teach the approach which is required.
Click to expand...

Which part of 61.195(c) supports your argument?
 
I am one of those rare pilots that have an MEI with no CFII.

I never have, and never will, understand what I can and cannot do.
No worries, I will steer well clear of the instruction life going forward. I always liked teaching, but not in today’s litigious world….
 
An MEI without a CFI-I can instruct an instrument rated pilot for a ME add on. The applicant’s certificate has an Instrument Airplane Rating, The MEI is providing the ME training he is authorized under 61.193(a)(5).

A flight instructor is required to have an CFI-I to conduct instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates.
 
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ja_user said:
But what you can't do, is take a checkride as a single engine instrument-airplane pilot, and add multi with VFR-only privilege's anymore.
Click to expand...
You keep saying that but haven't given one shred of evidence to support it. There's nothing in the regs that requires any difference in the multiengine instruction and multiengine instructor requirements with regard to whether the student possesses an instrument airplane rating.
 
If you look in the Commercial and Private ACS, Task X does not require C and D (the instrument stuff) for a non instrument rated pilot. An instrument rated pilot must demonstrate C and D in Task X. An instrument rated pilot cannot be issued a ME VFR only restriction with the multi add on. Look in the back of the ACS for the matrix.

The centerline only ME restriction also went bye bye.
 
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I am quite aware of the obligation to do a single-engine approach on the ACS for instrument privs. That's entirely irrelevant. There's no requirement for the instructor signing the student off for the checkride to have an instrument rating. An Instrument Instructor is only required for signing people off for an instrument rating (which the applicant already has) or for TYPE ratings with instrument privs. A non-type rating multi-engine class rating doesn't fall into any of those categories.
 
Russ,

A CFI-IA (instrument airplane, i.e. "CFII") is not a required rating for flight instructors possessing AME (Airplane Multiengine, i.e. "MEI") in the scenario you described. I agree with "dmspilot" regarding your comment on safety pilot.

Basically, you sussed it correctly, aside from the safety pilot supposition you mentioned.

There isn't further justification needed for this response beyond a simple reading of the CFRs, so despite the ongoing conversation in the thread, that's that.
 
ja_user said:
I'm just saying, that there are checkrides that happen where applicants apply without the required pre-requisites for the rating. Actually it happens a lot, sometimes they actually pass and get through.
The credentials of the signing off CFI are probably the least looked at item.

It's clear that a CFI is allowed to teach the "flight by reference to the instruments" for a student to obtain their PPL. It is also clear that a CFII is required for instrument-Airplane privilege's.

We all know that a CFI can sign off the add on multi to a rating, if Instrument airplane is not involved. However the FAA now says if you have instrument airplane single, you can no longer opt to have Multi "VFR only", this is now a relic of the past.

So you are arguing that a CFI without CFII rating is allowed to teach the multi engine tasks by reference to instruments during engine failure, but also the single engine ILS approach technics. I am simply arguing that they are not allowed to teach the approach which is required....

Where else is a CFI that is not a CFII, REQUIRED to sign off and attest to an applicants ability to shoot an approach? On what basis is the pilot adding the instrument airplane rating to a new category without an instructor that can actually sign that off?
Click to expand...

The MEI isn’t attesting the applicant’s ability to shoot an approach. He is attesting the person has been given ME training and is prepared for a test. The applicant isn’t required to be instrument current before the test and passing the ME test does not mean he is instrument current after the test.
 
I think there is one case where they would need an CFII. If this was an initial commercial in an ME. An add on ME wouldn't be required for an add on under 61.63(c) since it doesn't specify what training is required.

61.195... "(c) Instrument rating. A flight instructor may conduct ..., or the instrument training required for commercial pilot and airline transport pilot certificates ..."

-Robert
 
An add-on multi class rating is not training for a commercial or ATP CERTIFICATE.
 
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