CFI without a medical

While there are no instrument requirements for the issuance of a Sport certificate, there are solo xc requirements and 61.93 clearly requires a little bit of hood time prior to any solo xc by a student pilot.
61.311 spells it out. There is no flight by instruments in a-l, nor are there instrument requirements in 61.309 (KNOWLEDGE).

61.313 specifies 2 hours of cross-county flight training but no instrument work, see table. There is no mention of ANY instrument work at all.

See the headings: "SUBPART J: SPORT PILOTS"

That is why it is not necessary to take an instrument equipped ship to the LSA checkride.
 
Be aware that there are pilots that have their "licenses" issued to them from other countries because of medical reasons. Check Flight Standards to see which countries.
They accept my current NZ license and medical.
 
61.311 spells it out. There is no flight by instruments in a-l, nor are there instrument requirements in 61.309 (KNOWLEDGE).

61.313 specifies 2 hours of cross-county flight training but no instrument work, see table. There is no mention of ANY instrument woiiirk at all.

See the headings: "SUBPART J: SPORT PILOTS"

That is why it is not necessary to take an instrument equipped ship to the LSA checkride.

Read what I said one more time. I clearly stated that there are no Instrument requirements for the issuance of a Sport certificate nor are there any instrument reference tasks on the Sport practical (hence the reason you can use a J-3 cub or something similar);however, 61.313 (a)(1)(iii) requires one solo cross country of atleast 75 nm total distance...and so on. Now, one must refer to 61.93 to determine what a student pilot (a student pilot is a student pilot regardless of what certificate they are training for) must have in order to conduct a solo cross country. 61.93 (e)(12) specifically requires flight training covering control and maneuvering soley by reference to flight instruments.
 
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Now, one must refer to 61.93 to determine what a student pilot (a student pilot is a student pilot regardless of what certificate they are training for) must have in order to conduct a solo cross country. 61.93 (e)(12) specifically requires flight training covering control and maneuvering soley by reference to flight instruments.

Except Sport Pilot is its own sub part. All the requirements are contained within that particular sub-part. 61.93 doesn't really apply to Sport Pilot.
 
Ron, sorry if my comments come off as arguing. Did not intend that.
I am working thru this sport pilot instructor rule and trying to understand it.
One reason I do the Gleim FIRC to renew my CFI every two years even though I could do it on activity is to stay up with little-used portions of my CFI privileges -- especially those relating to Sport Pilot.
 
One of the major causes of accidents is inadvertant flight into IMC, so why wouldn't the FAA encourage basic instrument training in an LSA from a higher level CFI?
I've often wondered about that. I know Sport Pilots aren't allowed to fly at night, so that takes away half the problem, but perhaps the FAA figures are not going to be flying in marginal conditions? :dunno: Might be interesting to see if there is any significant number of LSA's getting into "VFR into IMC" accidents, and whether those pilots involved are PP's using only Sport privileges or actual Sport Pilots.
 
While there are no instrument requirements for the issuance of a Sport certificate, there are solo xc requirements and 61.93 clearly requires a little bit of hood time prior to any solo xc by a student pilot.
Not all Student Sport Pilots -- only those who will solo XC in an LSA with a max Vh greater than 87 knots CAS. See 61.93(e)(12).
(12) Control and maneuvering solely by reference to flight instruments, including straight and level flight, turns, descents, climbs, use of radio aids, and ATC directives. For student pilots seeking a sport pilot certificate, the provisions of this paragraph only apply when receiving training for cross-country flight in an airplane that has a VH greater than 87 knots CAS

Note that due to the safety pilot rules, this training must be given by a CFI-ASE, not CFI-SP, and that CFI-ASE must have a medical certificate. I believe I've heard that this is EAA's argument in favor of allowing CFI-SP's with a DL to act as safety pilots in LSA's (so they can give all the training for Sport Pilot in a fast LSA, just like the wording about instrument work in 61.109 and the aforementioned subparagraph of 61.93(e) which allows a non-IA CFI-ASE to give all the training for PP-ASEL), but AFAIK, the FAA has not yet acted on that proposal.
 
61.311 spells it out. There is no flight by instruments in a-l, nor are there instrument requirements in 61.309 (KNOWLEDGE).

61.313 specifies 2 hours of cross-county flight training but no instrument work, see table. There is no mention of ANY instrument work at all.

See the headings: "SUBPART J: SPORT PILOTS"

That is why it is not necessary to take an instrument equipped ship to the LSA checkride.
But thanks to what it says in 61.93(e)(12), if you're taking an over-87 knot LSA on your solo XC in preparation for that ride, it is necessary to do some training on instrument flying before that solo XC. That will take both at least one gyro instrument and a CFI-ASE with a medical.
 
Except Sport Pilot is its own sub part. All the requirements are contained within that particular sub-part. 61.93 doesn't really apply to Sport Pilot.
Yes, it does. Subpart J only applies to the issuance of the Sport Pilot certificate and the holders thereof. Subpart C Student Pilots applies to all Student Pilots, including those seeking only a Sport Pilot certificate. See 61.81, 61.87(a), and 61.93(a)(1). Note that certain sections (like 61.93(a) subparagraphs (9) and (12)) speak specifically to those training for Sport Pilot. While we often speak of "Student Sport Pilots", that is not an official FAA term, and the certificate those folks training only for a Sport Pilot certificate have in their pocket says "Student Pilot", just like those initially training for Recreational or Private.
 
I've often wondered about that. I know Sport Pilots aren't allowed to fly at night, so that takes away half the problem, but perhaps the FAA figures are not going to be flying in marginal conditions? :dunno: Might be interesting to see if there is any significant number of LSA's getting into "VFR into IMC" accidents, and whether those pilots involved are PP's using only Sport privileges or actual Sport Pilots.
The minimum weather conditions are higher under sport pilot rules - they are required to have three miles no matter what airspace they are in (63.315 c 12) and you can't fly over the top (63.315 c 13). That will keep them safe.
 
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The minimum weather conditions are higher under sport pilot rules - they are required to have three miles no matter what airspace they are in (63.15 c 12) and you can't fly over the top (63.15 c 13). That will keep them safe.
:rofl: We know how well that works for PP's.

BTW, those are references to 61.315, not 63.15, right?
 
Note that due to the safety pilot rules, this training must be given by a CFI-ASE, not CFI-SP, and that CFI-ASE must have a medical certificate.
Where does it say that a higher level CFI than a Sport pilot CFI needs to have a medical if their student is under the hood in a sport plane?

Or, are you saying a higher level CFI license degenerates to sport pilot CFI unless they have a current medical?

The Kern letter I linked to above is clearly talking about the competency requirements for teaching higher level private license maneuvers, so the latter doesn't make much sense. Not having a medical doesn't lower the competency to teach.

dtuuri
 
Even though there is no certification requirement for hood time in an LSA ,we all know of the value of it in control precision and navigation. If I have that knowledge and skill to pass on and, in fact require it of my students.
I would be remiss and somewhat liable for not teaching what we have been taught is the teaching/learning model: control by reference to instruments along with the visual reference.
Use it if you got it.
 
Where does it say that a higher level CFI than a Sport pilot CFI needs to have a medical if their student is under the hood in a sport plane?
14 CFR 91.109(c) and 61.23.

Or, are you saying a higher level CFI license degenerates to sport pilot CFI unless they have a current medical?
No. Just that the safety pilot rule has nothing to do with whether or not one is a CFI.

The Kern letter I linked to above is clearly talking about the competency requirements for teaching higher level private license maneuvers, so the latter doesn't make much sense. Not having a medical doesn't lower the competency to teach.
I agree, but it does disqualify one from acting as a safety pilot required by 91.109(c).
 
OK, the only regulation I can find to support Chief Counsel's reading is:
61.23(a)(3)(v) When exercising privileges of flight instructor and required crew member.
So that means a cfi cannot do LSA with student with no medical.
At all.
 
:rofl: We know how well that works for PP's.

BTW, those are references to 61.315, not 63.15, right?


Wait. Ron pointing out that rules and regs don't make anyone any safer?

I think I must have been transported to another dimension. Ron is the number one reason I know anything about the asinine rules that come from the Chief Counsel's office. Prior to that I though government was content with writing these things called FARs that were annoying enough on their own for their lack of detail and shoddy writing.

To see the King of Chief Counsel letter research on the Internet, and self-appointed teacher of same to all, now claim that rules and regs do not make a pilot any better, or any safer, breaks my whole world view. ;) ;) ;)

Damn it Ron! :) :) :) I thought that crap and all the debates about it here were *important*. Hell. Now I need to go rock back and forth in a corner somewhere and cry.

(LMFAO!)
 
One of the major causes of accidents is inadvertant flight into IMC, so why wouldn't the FAA encourage basic instrument training in an LSA from a higher level CFI?

dtuuri
Now that's an excellent question. A question the's being asked by EAA.
 
OK, the only regulation I can find to support Chief Counsel's reading is:
61.23(a)(3)(v) When exercising privileges of flight instructor and required crew member.
So that means a cfi cannot do LSA with student with no medical.
At all.
I've run out of ways to explain to you that acting as a flight instructor and acting as a safety pilot are separate issues governed by separate sections of the regulations - just like logging PIC time versus being the PIC. As long as you think they are somehow joined at the regulatory hip, you won't understand the issue.
 
Wait. Ron pointing out that rules and regs don't make anyone any safer?
I didn't say that. I do agree that just printing a bunch of rules doesn't improve safety if people don't follow them, and that some rules have little or no safety value in and of themselves. However, when you look at pretty much any accident in the NTSB files, somebody broke a rule that was intended to keep aviation safer.
 
Be fair. Ron also consistently points out that legal does not equal safe.
...nor do you have to be legal to be safe (e.g., the rule about not hiding the airworthiness certificate behind the registration certificate). Further, while I encourage people to be both legal and safe, I've always said that if a situation arises in flight where you find you can't do both, then do whatever it takes to stay safe and worry about the legalities later -- but then again, that's what 14 CFR 91.3b says, too. :wink2:
 
Read what I said one more time. I clearly stated that there are no Instrument requirements for the issuance of a Sport certificate nor are there any instrument reference tasks on the Sport practical (hence the reason you can use a J-3 cub or something similar);however, 61.313 (a)(1)(iii) requires one solo cross country of atleast 75 nm total distance...and so on. Now, one must refer to 61.93 to determine what a student pilot (a student pilot is a student pilot regardless of what certificate they are training for) must have in order to conduct a solo cross country. 61.93 (e)(12) specifically requires flight training covering control and maneuvering soley by reference to flight instruments.
You're correct. Subpart C is entitled "Student Pilots".
sigh. I have never paid any attention to that heading.
 
Where does it say that a higher level CFI than a Sport pilot CFI needs to have a medical if their student is under the hood in a sport plane?
14 CFR 91.109(c) and 61.23.
According to 91.109(c) the "operator", must have a safety pilot during simulated instruments. Since the CFI is the operator and is not under simulated instruments, no safety pilot is required.

According to 61.23(c)(iii) a flight instructor exercising the privileges of a sport pilot CFI and acting as PIC only needs a drivers license not a medical.

dtuuri
 
According to 91.109(c) the "operator", must have a safety pilot during simulated instruments. Since the CFI is the operator and is not under simulated instruments, no safety pilot is required.

According to 61.23(c)(iii) a flight instructor exercising the privileges of a sport pilot CFI and acting as PIC only needs a drivers license not a medical.

dtuuri
You can try that argument if you get caught doing it, but the Chief Counsel's position on the matter is already clear. And I won't be responding to any further posts which propose anyone else's personal opinion which contradicts the Chief Counsel's reading of those regulations, which I have already explained several times.
 
You can try that argument if you get caught doing it, but the Chief Counsel's position on the matter is already clear. And I won't be responding to any further posts which propose anyone else's personal opinion which contradicts the Chief Counsel's reading of those regulations, which I have already explained several times.
If you're going to attribute non-sensical ideas to the Chief Counsel, you ought to provide the reference for it. I've provided one where they discussed the levels of CFI certification required to teach certain maneuvers, such as private pilot instrument flying, but on the medical requirements that letter is silent. I'm not saying they're beyond nonsense, just that I'm never going to simply take your word for it.

dtuuri
 
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A couple things...

The use of the term "Sport pilot" in the text of the question is a red herring. You can leave out the term and the answer would be unaffected. It's well known that a CFI can't be PIC of a non-LSA aircraft without a medical and has been that way since before they invented Sport pilots. In the pre-Sport pilot era, if the "operator" isn't the CFI (PIC), then it made sense to have a medically certified safety pilot while engaged in simulated instrument flight.

This is the post-Sport pilot era, though, and we're not talking about that scenario. In this one, the subpart H CFI is the "operator" (PIC) and does not require a medical, just a driver's license. Thus the CFI's eyes are legally good enough to teach the private pilot maneuvers as per the Kern interpretation.

dtuuri
 
A couple things...

The use of the term "Sport pilot" in the text of the question is a red herring. You can leave out the term and the answer would be unaffected. It's well known that a CFI can't be PIC of a non-LSA aircraft without a medical and has been that way since before they invented Sport pilots. In the pre-Sport pilot era, if the "operator" isn't the CFI (PIC), then it made sense to have a medically certified safety pilot while engaged in simulated instrument flight.

This is the post-Sport pilot era, though, and we're not talking about that scenario. In this one, the subpart H CFI is the "operator" (PIC) and does not require a medical, just a driver's license. Thus the CFI's eyes are legally good enough to teach the private pilot maneuvers as per the Kern interpretation.

dtuuri

Did you read the link?

"However, the flight instructor could not include any simulated instrument time in the flight review, as the safety pilot for such operations must hold a valid medical certificate."

Is that what you are disagreeing with?

I don't see where this Kern letter addresses the use of a view limiting device.
 
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Did you read the link?

"However, the flight instructor could not include any simulated instrument time in the flight review, as the safety pilot for such operations must hold a valid medical certificate."

Is that what you are disagreeing with?

I don't see where this Kern letter addresses the use of a view limiting device.

Is an instructor with a person who holds only a student pilot certificate considered a safety pilot? Doesn't make much sense.
 
So if the aircraft is a LSA, the PIC is a CFI-SP, and a light sport student pilot is at the controls under the hood, then the PIC needs a medical, but he doesn't if the SP is not hooded? What if it's just a passenger under the hood who doesn't log any dual from it?

That REALLY doesn't make sense, but then again this is the same Chief Counsel who gave us the Goodish letter. (That said, I haven't read the opinion in much detail, just going by the conversation in this thread.)
 
Did you read the link?
Of course I read it. Every word of it. :)

"However, the flight instructor could not include any simulated instrument time in the flight review, as the safety pilot for such operations must hold a valid medical certificate."

Is that what you are disagreeing with?
I am agreeing not disagreeing. My point was that it doesn't apply to the scenario we're discussing which is flight training given in an LSA by a subpart H CFI. The question in the link deals with a non-LSA airplane and a CFI sans medical. Although the question included a reference to "Sport pilot", it isn't germane.

I don't see where this Kern letter addresses the use of a view limiting device.
Why would it? The CFI isn't wearing one and s/he is the operator in the business of supplying flight instruction. The salient paragraphs are the ones on subpart H CFIs and their qualifications to teach certain private pilot maneuvers, one of which is basic instrument flying. The CFI is not even required to be a CFII for that, of course, but Sport pilot CFIs are not tested on their ability to conduct that training at all, hence they aren't of a high enough level to give it.

dtuuri
 
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So if the aircraft is a LSA, the PIC is a CFI-SP, and a light sport student pilot is at the controls under the hood, then the PIC needs a medical, but he doesn't if the SP is not hooded?
As the regulations read, that is true.

What if it's just a passenger under the hood who doesn't log any dual from it?
As the regulations read, if the person flying is hooded, a safety pilot is required, and the safety pilot must hold at least a PP with category and class, and a valid medical. There is no exception or condition in 91.109(c) covering the certification status of the person operating the controls.

That REALLY doesn't make sense, but then again this is the same Chief Counsel who gave us the Goodish letter. (That said, I haven't read the opinion in much detail, just going by the conversation in this thread.)
Personally, I agree -- I see no safety reason why a CFI-ASE with a DL rather than a medical certificate should not be allowed to act as a safety pilot in an LSA while giving training on flight solely by reference to instruments. However, that is not permitted by the rules as the currently stand. I do have some concerns about letting a CFI-SP give any sort of training on flight solely by reference to instruments, since that's not part of the instructor training they've received or the instructor skills on which they've been tested, so I'm not sure that's something which should be permitted regardless of whether or not that CFI-SP holds a medical certificate or not.
 
As the regulations read, that is true.

As the regulations read, if the person flying is hooded, a safety pilot is required, and the safety pilot must hold at least a PP with category and class, and a valid medical. There is no exception or condition in 91.109(c) covering the certification status of the person operating the controls.
I thought you said it was the Chief Counsel who says all this. You mean this is what you personally see in the regulations, not what the Chief Counsel saw?

dtuuri
 
This is rich. A CFI-SP without a medical can put a blind person in the left seat and legally let them take the controls, but if it's a sighted person (or even the same blind person) wearing a hood, it's a violation.

And we wonder why some pilots say to hell with the regs?
 
This is rich. A CFI-SP without a medical can put a blind person in the left seat and legally let them take the controls, but if it's a sighted person (or even the same blind person) wearing a hood, it's a violation.

And we wonder why some pilots say to hell with the regs?
Well, we know of one person who thinks that, does anybody else think so too, including the Chief Counsel?

dtuuri
 
Well, we know of one person who thinks that, does anybody else think so too, including the Chief Counsel?

dtuuri

The way I interpret the regs, an Instructor with a student (vision restricted or not) is a PIC, not a safety pilot. Any other interpretation is absurd.
 
This is yet another example of why there should be a $100 user fee to get an answer from the Chief Counsel.
 
The way I interpret the regs, an Instructor with a student (vision restricted or not) is a PIC, not a safety pilot. Any other interpretation is absurd.

Well, if the student is under the hood it only follows that SOMEONE needs to be looking out the window. That makes the CFI both an instructor AND a safety pilot and the appropriate regs regarding safety pilots apply.

Mike
 
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