CFI in non-complex airplane?

[n12365]

I am looking at working on my CFI and am confused about how some flight schools are able to do the CFI in a non-complex airplane. I am not going to use ATP flight schools, but there program is a good example of what I am talking about. They have you do the initial instructor rating in a multi-engine airplane, and then add on instrument instructor and single engine instructor ratings. I understand the rational for doing it in that order, but what I don’t understand is how they can do the single-engine add-on in a C172.

When I look at the additional rating task table in the flight instructor PTS, it looks like single-engine CFI applicants who already have a multi-engine CFI, need to perform areas 7, 9, 11, & 13. Area 7 is takeoffs, landings, and go-arounds. The PTS also requires a complex airplane for all of the takeoffs, landings, and emergency procedures. This would indicate to me that a complex airplane needs to be used for a single-engine add-on, but ATP doesn’t have any complex singles, just C172s.

Can someone help me understand how they are able to do this?

Ryan

 

[EdFred]

Because it's an add on, not an initial.

 

[n12365]

Because it's an add on, not an initial.

I understand it's an add-on, but I don't understand how the complex requirement changes. From the PTS:

Aircraft and Equipment Required for the Practical Test
The flight instructor applicant is required by 14 CFR part 61, section 61.45
to provide an airworthy, certificated aircraft for use during the practical test.
This section further requires that the aircraft must:
1. Be of U.S., foreign or military registry of the same category, class,
and type for the certificate and/or rating for which the applicant is
applying;
2. Have fully functioning dual controls except as provided in 14 CFR part
61, section 61.45(c) and (e); and
3. Be capable of performing all appropriate TASKS for the flight
instructor rating sought and have no operating limitations, which
prohibit the performance of those TASKS. A complex airplane must
be furnished for the performance of takeoff and landing maneuvers,
and appropriate emergency procedures. A complex landplane is one
having a retractable landing gear, flaps, and controllable propeller. A
complex seaplane is one having flaps, floats, and a controllable
propeller. Airplanes that are equipped with a full authority digital
engine control (FADEC) system are considered to have a
controllable propeller.

 

[EdFred]

Already did it on the MEI

 

[Greg Bockelman]

Ryan, what you have to do is go further into the PTS. Take a look at the table on Page 1-xi. That table tells you what areas of operation you need to complete if you already have the CFI-ME. I did not go look at the specific areas of operation but I am willing to bet that those that are required do not have anything to do with complex airplanes, hence can be done in a simple single.

If you think about it, unless you did the CFI-ME ride in some exotic twin, a Partinavia or Twin Otter comes to mind, you would have done those particular tasks requiring a complex airplane as a part of the CFI-ME ride.

 

[HPNPilot1200]

Because it's an add on, not an initial.

Exactly. Demonstration of takeoff and landing maneuvers and appropriate emergency procedures need only be in a complex aircraft on the initial issuance checkride. The complex requirement does not exist for add-ons.

 

[Fearless Tower]

Already did it on the MEI

Exactly - this is what ATP flight school does - they do the MEI as the CFI initial checkride. Since you have already demonstrated all of the PTS requirements for a complex rating, you are not required to use a complex plane when you do the SE as an addon to your CFI ticket.

Commercial works the same as well. I did my initial commercial in a twin and then the SE as an addon in a straight leg 172.

 

[EdFred]

In defense of the OP, there is nothing I quickly found from the FAA explicitly stating it as such.

 

[n12365]

In defense of the OP, there is nothing I quickly found from the FAA explicitly stating it as such.

I am also unable to find anything explicit or implied from the FAA that it can be done this way. When I read the PTS, it seams clear to me that you need to have a complex plane, even for the add-on. I don't see an exception for having already demonstrated competency in a complex plane on a different check ride.

Have any of you gone through the process of getting a legal interpretation from the FAA?

Ryan

 

[Greg Bockelman]

Did you look at my post #5? Those areas required for the SE addon don't require the complex to complete.

 

[poadeleted20]

I am also unable to find anything explicit or implied from the FAA that it can be done this way. When I read the PTS, it seams clear to me that you need to have a complex plane, even for the add-on. I don't see an exception for having already demonstrated competency in a complex plane on a different check ride.

Have any of you gone through the process of getting a legal interpretation from the FAA?

There is no legal interpretation involved because this is not a regulatory issue -- it's a PTS matter handled entirely within the Flight Standards Service. Ask any FSDO if you have a question, but the matter is quite settled within the Flight Standards Service -- the complex airplane is required only for your initial Airplane rating for CP and CFI.

 

[n12365]

Did you look at my post #5? Those areas required for the SE addon don't require the complex to complete.

I did look at your post and looked at the table on Page 1-xi. The table has a * for area 7. At the bottom of the table, * is explained to mean "Refer to NOTE under AREA OF OPERATION for TASK requirements". Area 7 is "Takeoffs, Landings, and Go-Arounds". The note states "The examiner must select at least two takeoff and two landing TASKS." Earlier in the PTS, it states a complex airplane is required for takeoff and landing maneuvers.

I still don't understand how you can get away with using a non-complex airplane to complete the tasks for area 7.

Ryan

 

[HPNPilot1200]

From FAA 8710.3E (DPE Handbook). Note that this order has technically been cancelled but incorporated into 8900.1 (FSIMS). Since 8900.1 is tremendously lengthy, I thought I would post this reference from 8710.3E 14-2:

A. Required Use of a Complex Airplane.

(1) For the issuance of a flight instructor
certificate for a rating in the airplane category, a complex
airplane must be used to perform takeoffs, landings, and
emergency operations that are appropriate to complex
airplanes.

(2) An applicant for a flight instructor certificate
in a single-engine airplane is not allowed to use a
complex multiengine airplane for the complex airplane
requirements.

(3) If the applicant is seeking an additional flight
instructor rating in the airplane category and multiengine
class, a complex multiengine airplane must be used.

(4)If an applicant holds a flight instructor
certificate with an airplane category and multiengine class
rating and is seeking an additional airplane single engine
class rating, the applicant need not bring a complex
single-engine airplane.

(Emphasis mine)

 

[n12365]

Thanks Jason! That is exactly what I was looking for.

 

[TMetzinger]

I am also unable to find anything explicit or implied from the FAA that it can be done this way. When I read the PTS, it seams clear to me that you need to have a complex plane, even for the add-on. I don't see an exception for having already demonstrated competency in a complex plane on a different check ride.

Have any of you gone through the process of getting a legal interpretation from the FAA?

Ryan

You really need to look at the task table again.

 

[n12365]

You really need to look at the task table again.

Take a look at post #12 for an explanation of how I think the table applies. I have attached a copy of the table with the relevant sections circled.

However, with the additional information Jason provided, it is clear to me how the FAA wants that situation to be handled.

Ryan