Can a CFI without Complex or HP endorsements provide these endorsement?

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Revtach

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Revtach
Hello,

My CFI practical is coming up this week. I am going through everything with a fine tooth comb and came upon this practice question and am somewhat stumped.

Can a CFI without Complex or HP endorsements provide these endorsement to a pilot?

I can't find anything expressly prohibiting it. However, I believe the answer can be deduced.

From 61.31

"(e) Additional training required for operating complex airplanes.

(1) Except as provided in paragraph (e)(2) of this section, no person may act as pilot in command of a complex airplane, unless the person has—
(i) Received and logged ground and flight training from an authorized instructor in a complex airplane, or in a full flight simulator or flight training device that is representative of a complex airplane, and has been found proficient in the operation and systems of the airplane; and
(ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a complex airplane.

(2) The training and endorsement required by paragraph (e)(1) of this section is not required if—
(i) The person has logged flight time as pilot in command of a complex airplane, or in a full flight simulator or flight training device that is representative of a complex airplane prior to August 4, 1997; or
(ii) The person has received ground and flight training under an approved training program and has satisfactorily completed a competency check under § 135.293 of this chapter in a complex airplane, or in a full flight simulator or flight training device that is representative of a complex airplane which must be documented in the pilot's logbook or training record."

From 61.195

"A person who holds a flight instructor certificate is subject to the following limitations:

(b) Aircraft ratings. Except as provided in paragraph (c) of this section, a flight instructor may not conduct flight training in any aircraft unless the flight instructor:
(1) Holds a flight instructor certificate with the applicable category and class rating;
(2) Holds a pilot certificate with the applicable category and class rating; and
(3) Meets the requirements of paragraph (e) of this section, if applicable.

(e) Training in an aircraft that requires a type rating. A flight instructor may not give flight instruction, including instrument training, in an aircraft that requires the pilot in command to hold a type rating unless the flight instructor holds a type rating for that aircraft on his or her pilot certificate."

It seems that a CFI who logged complex time prior to August 4, 1997 could provide the endorsement since they can act as PIC. However, a CFI who does not have a complex endorsement and did not log complex time prior to August 4, 1997 could not act as PIC during the training flight and neither could the applicant seeking an endorsement. So the answer would therefore be no.

The answer to this should apply to the high performance (HP) endorsement as well since that reg is written identically.

Just wanted to get some other interpretations. Thank you.
 
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""""Can a CFI without Complex or HP endorsements provide these endorsement to a pilot?
I can't find anything expressly prohibiting it."""

I don't think so, since not being endorsed herself, he couldn't act as PIC or give instruction in such aircraft.
 
There's an age old question whether a CFI can give any instruction in an airplane which requires an endorsement they don't have. A fun topic.

But the one you are asking is very straightforward. And the answer is the one you deduced. I don't even think you have to go all the way to 61.195.
Revtach said:
However, a CFI who does not have a complex endorsement and did not log complex time prior to August 4, 1997 could not act as PIC during the training flight and neither could the applicant seeking an endorsement. So the answer would therefore be no.
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Who is acting as PIC when giving training to someone who does not have the endorsement? It can't be the trainee since they don't have the endorsement. We're left withe the CFI who, just like any PIC, has to meet PIC requirements.
 
How does the chicken have the egg….? Without first being an egg?;)
 
hindsight2020 said:
I gave an IPC in an RV-9 and I don't land airplanes in reverse. *shrugs*.
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I agree that from a regulatory reading there is no prohibition. OTOH, if you recall the disowned Part 61 FAQ, it's answer was a resounding "no!" After answering the obvious "for the endorsement" question, came the flight review question. While it's not about an IPC, note that it bases itself on whether a CFI without the endorsement is an "authorized instructor" in an airplane requiring an endorsement:

QUESTION: The situation is a flight instructor has asked the question whether he can give a flight review in a tailwheel airplane and yet he has not previously met the additional training requirements for operating a tailwheel airplane [i.e., § 61.31(i)].​

ANSWER: Ref. § 61.1(b)(2); § 61.56(c)(1); No, a flight instructor cannot give a flight review in a tailwheel airplane unless he has complied with § 61.31(i). Per § 61.56(c)(1), it states, in pertinent part, “. . . by an authorized instructor . . . .” Per § 61.1(b)(2)(ii), it states, in pertinent part, “. . . in accordance with the privileges and limitations of his or her flight instructor certificate . . . .” The flight instructor would not be considered an “authorized instructor” for giving a flight review in a tailwheel airplane.​


Then there's the completely practical ASI question if there is an incident or accident, calling CFI judgment into question, "what made you think it was ok to teach in an airplane you could not legally fly yourself?" especially give a long line of cases that a CFI giving instruction has responsibilities equivalent to being PIC.
 
I could be wrong but…..there was a time where the endorsement wasn’t required….prior to the 80’s or 70’s? Maybe those old timers are grandfathered in?
 
midlifeflyer said:
I agree that from a regulatory reading there is no prohibition. OTOH, if you recall the disowned Part 61 FAQ, it's answer was a resounding "no!" After answering the obvious "for the endorsement" question, came the flight review question. While it's not about an IPC, note that it bases itself on whether a CFI without the endorsement is an "authorized instructor" in an airplane requiring an endorsement:

QUESTION: The situation is a flight instructor has asked the question whether he can give a flight review in a tailwheel airplane and yet he has not previously met the additional training requirements for operating a tailwheel airplane [i.e., § 61.31(i)].​

ANSWER: Ref. § 61.1(b)(2); § 61.56(c)(1); No, a flight instructor cannot give a flight review in a tailwheel airplane unless he has complied with § 61.31(i). Per § 61.56(c)(1), it states, in pertinent part, “. . . by an authorized instructor . . . .” Per § 61.1(b)(2)(ii), it states, in pertinent part, “. . . in accordance with the privileges and limitations of his or her flight instructor certificate . . . .” The flight instructor would not be considered an “authorized instructor” for giving a flight review in a tailwheel airplane.​


Then there's the completely practical ASI question if there is an incident or accident, calling CFI judgment into question, "what made you think it was ok to teach in an airplane you could not legally fly yourself?" especially give a long line of cases that a CFI giving instruction has responsibilities equivalent to being PIC.
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Long winded way of saying, it's legal.

As to the "what if there's an accident?", of course. We can reductio ad absurdum that one to death. I couldn't get out of bed in the morning if I held myself to that standard. We're all criminals to somebody. But I concede your point it may not be prudent. But it's not illegal, which was the question. Would I give someone a flight review in a taildragger? Of course not, I find that consequentially different. Landings are a central aeronautical task of the flight review, which could require CFI intervention in order to preserve safety of flight. That is not the case for a CFII providing an IPC. All the tasks I'm entrusted to supervise and intervene in as part of an IPC, I was already rated and evaluated myself on. Landing and takeoffs aren't one of them. Hence I got no problem giving an IPC in a taildragger.

The irony is that I don't do any of it [instruction/review/IPC] anymore in any capacity, nor do I provide Young Eagles flights anymore (before I lost the airplane that is), precisely for all the enumerated PITA petty functionary reasons you enumerated already. So a distinction without difference indeed for me now. But it's not because I found it to be illegal, moot as the point may be.
 
midlifeflyer said:
If you say so. If nothing else, the old FAQ might just be reflective of the FAA's attitude. Beyond that, we make our choices.
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As opposed to you saying what exactly? That I was providing illegal instruction? If so, then say so. If not, then stop shadowboxing with that "well ackshually..." interpretation whack-a-mole.

The scope of my comment was limited to providing an IPC. I've already explained why I think that distinction matters, and why you bringing up flight reviews as a retort to my provided example is a non-sequitur.
 
hindsight2020 said:
As opposed to you saying what exactly? That I was providing illegal instruction? If so, then say so.
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You are reading waaaaaaay to much into my comment. I never said or even thought it. I don't have an answer to the question. Just saying that there are indications suggesting that in the "wrong" situation, the FAA might not look at it the same way as you and I do. Wouldn't be the first time.
 
midlifeflyer said:
There is definitely grandfathering - written right into the regulation.
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Except that what are today considered high performance and complex required still required an endorsement prior to the grandfathering date in the current reg…I think somewhere around 1976 was the previous grandfathering date.

Cool thing is if you logged PIC at altitude in your buddy’s Bonanza prior to the current grandfathering date, you don’t need an endorsement, even though you weren’t legal to act as PIC when you logged it.
 
midlifeflyer said:
I agree that from a regulatory reading there is no prohibition. OTOH, if you recall the disowned Part 61 FAQ, it's answer was a resounding "no!" After answering the obvious "for the endorsement" question, came the flight review question. While it's not about an IPC, note that it bases itself on whether a CFI without the endorsement is an "authorized instructor" in an airplane requiring an endorsement:

QUESTION: The situation is a flight instructor has asked the question whether he can give a flight review in a tailwheel airplane and yet he has not previously met the additional training requirements for operating a tailwheel airplane [i.e., § 61.31(i)].​

ANSWER: Ref. § 61.1(b)(2); § 61.56(c)(1); No, a flight instructor cannot give a flight review in a tailwheel airplane unless he has complied with § 61.31(i). Per § 61.56(c)(1), it states, in pertinent part, “. . . by an authorized instructor . . . .” Per § 61.1(b)(2)(ii), it states, in pertinent part, “. . . in accordance with the privileges and limitations of his or her flight instructor certificate . . . .” The flight instructor would not be considered an “authorized instructor” for giving a flight review in a tailwheel airplane.​


Then there's the completely practical ASI question if there is an incident or accident, calling CFI judgment into question, "what made you think it was ok to teach in an airplane you could not legally fly yourself?" especially give a long line of cases that a CFI giving instruction has responsibilities equivalent to being PIC.
Click to expand...
true for a flight review. however, for an IPC you are exercising your privileges of your CFII, not your CFI.
 
MauleSkinner said:
Except that what are today considered high performance and complex required still required an endorsement prior to the grandfathering date in the current reg…I think somewhere around 1976 was the previous grandfathering date.

Cool thing is if you logged PIC at altitude in your buddy’s Bonanza prior to the current grandfathering date, you don’t need an endorsement, even though you weren’t legal to act as PIC when you logged it.
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Yeah but AFAIK, all the iterations of the rule had grandfathering. I’m actually grandfathered in high performance. I received my HP endorsement in a Cutlass (not HP in the current definition) before 1997 when HP and complex were both defined as HP. But since I flew HP under that endorsement, I was grandfathered when the two were separated.,
 
Why limit yourself, Get the complex and hp endorsememt
 
Revtach said:
(I) Received and logged ground and flight training from an authorized instructor in a complex airplane, or in a full flight simulator or flight training device that is representative of a complex airplane, . . . .
Click to expand...

midlifeflyer said:
Who is acting as PIC when giving training to someone who does not have the endorsement? It can't be the trainee since they don't have the endorsement. We're left withe the CFI who, just like any PIC, has to meet PIC requirements.
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No PIC needed when the instruction is given in a simulator.
 
Lindberg said:
No PIC needed when the instruction is given in a simulator.
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My instrument instructor, Lyle Flick, of Flick's Foggy Flying......stated "simulator time shall be subtracted" from your logbook. Granted, this was 50 years ago and the sims were from WWII.

His favorite saying was "God hates cowards." He flew water bombers in the summer............taught instruments in winter.
 
Lindberg said:
No PIC needed when the instruction is given in a simulator.
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True, but I thought we were talking about airplanes.

If it's a simulator, the issues are different. We're talking at least the FTD level in which case I wouldn't worry too much about the instructor's qualifications.
 
midlifeflyer said:
True, but I thought we were talking about airplanes.
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We're talking about the endorsements required to operate certain airplanes. And the question is whether it's possible a CFI without those endorsements could give them.

The answer seems to be that there's nothing in the regs that would prohibit it, and there's at least two scenarios where it would be legally permissible. In one of those scenarios, it might be less prudent than the other.

At least that's what I'd say if it was my CFI check ride.
 
I received my first certificate in 1969 when I completed Air Force pilot training. Ergo, I am grandfathered in high performance, complex and high altitude. I have a single engine seaplane rating and the tailwheel endorsement, but I don't have enough experience in either to instruct in them.

I am also grandfathered for motorcycles on my driver license.

And I am also a grandfather.
 
\
Lindberg said:
No PIC needed when the instruction is given in a simulator.
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Most people don't have access to "simulators."
The complex/tailwheel/HP endorsements require FLIGHT TRAINING which can not be done in a training device (the computer things most of us call simulators).
 
If a cfi has not received the training and gained proficiency in a HP/complex just WTF are they going to teach to another pilot?

Is this CFI sitting in the right seat with a book out reading to their client?
 
Tarheelpilot said:
If a cfi has not received the training and gained proficiency in a HP/complex just WTF are they going to teach to another pilot?
Click to expand...

Those who can't do, teach. Those who can't teach, become DPEs.
 
Tarheelpilot said:
If a cfi has not received the training and gained proficiency in a HP/complex just WTF are they going to teach to another pilot?

Is this CFI sitting in the right seat with a book out reading to their client?
Click to expand...
Lindberg said:
The question wasn't can most people do it or is it common.
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The question wasn’t, “does it make any sense at all” either :D
 
flyingron said:
\

Most people don't have access to "simulators."
The complex/tailwheel/HP endorsements require FLIGHT TRAINING which can not be done in a training device (the computer things most of us call simulators).
Click to expand...
The reg specifically includes “flight training device.”
 
MauleSkinner said:
The reg specifically includes “flight training device.”
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"full flight simulator or flight training device" for HP, complex, and pressurized. As you point out, the ATDs commonly available to the pilot who is seeking one of those, does not qualify as either.

but the regulatory language for tailwheel if different.

"in a tailwheel airplane." Which answers @Lindberg's "legal in a simulator" for the tailwheel endorsement
 
midlifeflyer said:
"full flight simulator or flight training device" for HP, complex, and pressurized. As you point out, the ATDs commonly available to the pilot who is seeking one of those, does not qualify as either.

but the regulatory language for tailwheel if different.

"in a tailwheel airplane." Which answers @Lindberg's "legal in a simulator" for the tailwheel endorsement
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The FAA has a pretty broad definition for “flight training device.” An ATD could probably be considered a “flight training device”.
 
MauleSkinner said:
The FAA has a pretty broad definition for “flight training device.” An ATD could probably be considered a “flight training device”.
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What is pretty broad about the definitions?

Flight training device (FTD) means a replica of aircraft instruments, equipment, panels, and controls in an open flight deck area or an enclosed aircraft cockpit replica. It includes the equipment and computer programs necessary to represent aircraft (or set of aircraft) operations in ground and flight conditions having the full range of capabilities of the systems installed in the device as described in part 60 of this chapter and the qualification performance standard (QPS) for a specific FTD qualification level.

Full flight simulator (FFS) means a replica of a specific type; or make, model, and series aircraft cockpit. It includes the assemblage of equipment and computer programs necessary to represent aircraft operations in ground and flight conditions, a visual system providing an out-of-the-cockpit view, a system that provides cues at least equivalent to those of a three-degree-of-freedom motion system, and has the full range of capabilities of the systems installed in the device as described in part 60 of this chapter and the qualification performance standards (QPS) for a specific FFS qualification level.

Flight simulation training device (FSTD) means a full flight simulator or a flight training device.

Aviation training device means a training device, other than a full flight simulator or flight training device, that has been evaluated, qualified, and approved by the Administrator.
 
midlifeflyer said:
What is pretty broad about the definitions?

Flight training device (FTD) means a replica of aircraft instruments, equipment, panels, and controls in an open flight deck area or an enclosed aircraft cockpit replica. It includes the equipment and computer programs necessary to represent aircraft (or set of aircraft) operations in ground and flight conditions having the full range of capabilities of the systems installed in the device as described in part 60 of this chapter and the qualification performance standard (QPS) for a specific FTD qualification level.

Full flight simulator (FFS) means a replica of a specific type; or make, model, and series aircraft cockpit. It includes the assemblage of equipment and computer programs necessary to represent aircraft operations in ground and flight conditions, a visual system providing an out-of-the-cockpit view, a system that provides cues at least equivalent to those of a three-degree-of-freedom motion system, and has the full range of capabilities of the systems installed in the device as described in part 60 of this chapter and the qualification performance standards (QPS) for a specific FFS qualification level.

Flight simulation training device (FSTD) means a full flight simulator or a flight training device.

Aviation training device means a training device, other than a full flight simulator or flight training device, that has been evaluated, qualified, and approved by the Administrator.
Click to expand...
I’m currently using a desktop computer as a flight training device per that definition.
 
I realize this is a theoretical question about the regs. And what is legal ain't necessarily safe or prudent, and vice versa. However, I can't help but think about it from a common sense perspective.

Any pilot seeking the endorsement should know enough to ask the instructor providing the endorsement about his own experience with complex and HP. And any CFI should know that if he doesn't have that experience he shouldn't be teaching others. In either case common sense says it would be ... to use a polite word ... inadvisable.
 
MauleSkinner said:
I’m currently using a desktop computer as a flight training device per that definition.
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Wow! If you have a desktop sim that meets Part 60 requirements for FTD approval, I'm impressed. What "qualification performance standards" in Part 60, Appendix B did it meet? Some folks have asked me to help them through the approval process, but it's way too complicated for me. Perhaps you can help them? Is there a particular FSO you found helpful? How many flight tests did you have to go through?
 
Mikey52 said:
Has it been approved by the Administrator, and does it have a certificate?
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Yes, and I don’t know.
midlifeflyer said:
Wow! If you have a desktop sim that meets Part 60 requirements for FTD approval, I'm impressed. What "qualification performance standards" in Part 60, Appendix B did it meet? Some folks have asked me to help them through the approval process, but it's way too complicated for me. Perhaps you can help them? Is there a particular FSO you found helpful? How many flight tests did you have to go through?
Click to expand...
The company developed the DTSs and got FAA approval for their use. I wasn’t a part of that process. But the FSB Report for the airplane I’m training today has FTD requirements, which are fulfilled using the DTS.
 
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