Instrument Time

Don Jones

Don Jones

Line Up and Wait
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DJones
Apologies if this has been discussed before, but I searched and couldn't find it so here goes.

I was having a discussion the other day with a FSDO examiner and he posed a question to me. He asked if and instructor could send a student to the instrument checkride with exactly 40 hours of logged instrument time(simulated or actual). He said no, saying the 3 hours of instrument training from the private do not count. Looking over the regs it says 40 hours simulated or actual, and 15 hours from an authorized instructor. Anyone want to point me to that regulation? Is it because a student pilot is unable to log the time as pic?

The way I see it, a private pilot could log 25 hours with a CFI or a safety pilot, then get the required 15 hours from a CFII, do the x-country with the CFII, get the sign off and he's good to go. Wrong?

Boy will I be glad when this checkride is over!!!
Just a couple of more days:goofy:

(d) Aeronautical experience. A person who applies for an instrument rating must have logged the following:
(1) At least 50 hours of cross-country flight time as pilot in command, of which at least 10 hours must be in airplanes for an instrument—airplane rating; and
(2) A total of 40 hours of actual or simulated instrument time on the areas of operation of this section, to include—
(i) At least 15 hours of instrument flight training from an authorized instructor in the aircraft category for which the instrument rating is sought;
(ii) At least 3 hours of instrument training that is appropriate to the instrument rating sought from an authorized instructor in preparation for the practical test within the 60 days preceding the date of the test;
(iii) For an instrument—airplane rating, instrument training on cross- country flight procedures specific to airplanes that includes at least one cross-country flight in an airplane that is performed under IFR, and consists of—
(A) A distance of at least 250 nautical miles along airways or ATC-directed routing;
( An instrument approach at each airport; and
(C) Three different kinds of approaches with the use of navigation systems;
 
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I can't point you to it, because I agree with you. As long as you've got 40 hours actual or simulated time, and meet the specifics you quoted, you're good to go.
 
I remember discussing this before, except it was probably on the yellow board. I think since a CFI-A without CFI-IA is allowed to give the 3 hours for private, that wouldn't count as "flight training from an authorized instructor". However, I remember Ron saying that it *could* count, if your 3 hours pre-PP-ASEL was given to you by a CFII and that CFII was willing to sign it with a notation - I believe the notation was something about the training being given on the areas required 61.65(c) and qualified towards the requirements of 61.65(d)(2)(i).
 
flyingcheesehead said:
I remember discussing this before, except it was probably on the yellow board. I think since a CFI-A without CFI-IA is allowed to give the 3 hours for private, that wouldn't count as "flight training from an authorized instructor". However, I remember Ron saying that it *could* count, if your 3 hours pre-PP-ASEL was given to you by a CFII and that CFII was willing to sign it with a notation - I believe the notation was something about the training being given on the areas required 61.65(c) and qualified towards the requirements of 61.65(d)(2)(i).
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While I understand what you are saying, how could one then count 25 hours flying with only a safety pilot, which you can. I can see the 3 hours of private not counting for the 15 hours with a II, but the FSDO guy told me it couldn't be counted at all and no one should show up with the checkride without 43 hours of simulated or actual time. That's just wrong!
 
Don Jones said:
While I understand what you are saying, how could one then count 25 hours flying with only a safety pilot, which you can. I can see the 3 hours of private not counting for the 15 hours with a II, but the FSDO guy told me it couldn't be counted at all and no one should show up with the checkride without 43 hours of simulated or actual time. That's just wrong!
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Hmmm... I see. Well, hopefully Ron has an applicable reference! :yes: Because I disagree with the "43 hours" thing too.
 
flyingcheesehead said:
Hmmm... I see. Well, hopefully Ron has an applicable reference! :yes: Because I disagree with the "43 hours" thing too.
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I really wanted to call him on it, however he is part of my backup plan in case my checkride does not happen in time before my CFI expires. Don't want to *iss him off, lol
 
Without getting into the inevitable flame war about the applicability of the Part 61 FAQs, it is stated therein that the three hours of private pilot training is not instrument time.

Note that 61.109 specifies it as flight training, not instrument training. :no:

Bob Gardner
 
I agree that the 3 hours from the private may not qualify against the 15 hours of specified instruction - but it certainly should qualify for the whole 40, just as if you'd gone up with a safety pilot to do hood work.
 
bobmrg said:
Without getting into the inevitable flame war about the applicability of the Part 61 FAQs, it is stated therein that the three hours of private pilot training is not instrument time.

Note that 61.109 specifies it as flight training, not instrument training. :no:

Bob Gardner
Click to expand...

I suppose that instrument training is not flight training by reference to instruments either. Only the FAA
 
bobmrg said:
Without getting into the inevitable flame war about the applicability of the Part 61 FAQs, it is stated therein that the three hours of private pilot training is not instrument time.

Note that 61.109 specifies it as flight training, not instrument training. :no:

Bob Gardner
Click to expand...
Actually, no, it doesn't say that. It says it is not "instrument training" but does not say it is not "instrument time." In any event, for 61.65 purposes, it counts towards the 40 but not the 15, since it qualifies as "instrument time" under 14 CFR 61.51(g)(a). I've been through this more times than I can count with my IR trainees. Suggest this "FSDO Examiner" (is he a FSDO Inspector or a DPE?) be asked to obtain official legal guidance from his Regional Counsel.
 
Ron Levy said:
Actually, no, it doesn't say that. It says it is not "instrument training" but does not say it is not "instrument time." In any event, for 61.65 purposes, it counts towards the 40 but not the 15, since it qualifies as "instrument time" under 14 CFR 61.51(g)(a). I've been through this more times than I can count with my IR trainees. Suggest this "FSDO Examiner" (is he a FSDO Inspector or a DPE?) be asked to obtain official legal guidance from his Regional Counsel.
Click to expand...

Well that supports what I have been taught as well Ron. He is one of the FSDO Inspectors.
 
Ron Levy said:
Actually, no, it doesn't say that. It says it is not "instrument training" but does not say it is not "instrument time." In any event, for 61.65 purposes, it counts towards the 40 but not the 15, since it qualifies as "instrument time" under 14 CFR 61.51(g)(a). I've been through this more times than I can count with my IR trainees. Suggest this "FSDO Examiner" (is he a FSDO Inspector or a DPE?) be asked to obtain official legal guidance from his Regional Counsel.
Click to expand...

Besides that, the instrument candidate could have obtained his private pilot certificate a long time ago before any instrument flight was required.
 
Don Jones said:
I really wanted to call him on it, however he is part of my backup plan in case my checkride does not happen in time before my CFI expires. Don't want to *iss him off, lol
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Just wait till you pass then "explain it to him".
 
Sounds like a variation on what they say about Harvard Men:

You can always tell an FAA inspector, but you can't tell him much.
 
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