Qualified to train initial CFI applicant?

[calicash]

Here’s the situation: I need initial CFI training to prepare for a CFI checkride in the near future and need an instructor. There is an instructor at my FBO who has not had his CFI certificate for 24 months, but has trained and endorsed more than five checkride applicants in the last 24 months and more than 80% have passed on their first attempt. In my view this qualifies him to train and endorse initial CFI applicants under the new 61.195(h)(2)(ii) which went into effect last December.

More than one local DPE has told this instructor that he is not qualified to endorse initial CFI applicants because the instruction is part 61 and not part of an FAA-approved course, i.e. part 141. Are they wrong?

I did a quick search to make sure this hasn’t been talked about before and didn't find anything but sorry if this has come up already.

 

[Initial Fix]

I wonder if there is more behind the story. On the above it appears they are good to go. Going on an hunch here, are they trying to sign off a 141 candidate without being part of that 141 program? Otherwise why would 61 or 141 come into the conversation.

 

[calicash]

I wonder if there is more behind the story. On the above it appears they are good to go. Going on an hunch here, are they trying to sign off a 141 candidate without being part of that 141 program? Otherwise why would 61 or 141 come into the conversation.

I'm actually the one that wants to be signed off by the instructor, so it's all part 61. I think the reason these DPEs are referencing an "FAA-approved course" is because that was the language in the old rule, and honestly I'm not sure they have even read the new rule.

 

[bbchien]

IIRC the CFI has to show >200 instructional hours logged B4 he can train another for CFI....

 

[Brad Z]

Here’s the situation: I need initial CFI training to prepare for a CFI checkride in the near future and need an instructor. There is an instructor at my FBO who has not had his CFI certificate for 24 months, but has trained and endorsed more than five checkride applicants in the last 24 months and more than 80% have passed on their first attempt. In my view this qualifies him to train and endorse initial CFI applicants under the new 61.195(h)(2)(ii) which went into effect last December.

More than one local DPE has told this instructor that he is not qualified to endorse initial CFI applicants because the instruction is part 61 and not part of an FAA-approved course, i.e. part 141. Are they wrong?

I did a quick search to make sure this hasn’t been talked about before and didn't find anything but sorry if this has come up already.

You noted that the rule changed. Have you read the rule and the explanation? That might help you here.

 

[MauleSkinner]

It looks to me like the instructor can provide the flight training under 61.195(h)(2)(ii), but not the ground training because he doesn’t meet the requirements of (h)(1) for the reason stated by the examiners.

 

[calicash]

You noted that the rule changed. Have you read the rule and the explanation? That might help you here.

Personally I feel like it’s very clear, and I disagree with the DPE’s interpretation. I mostly just wanted to put the question out there and make sure I’m not crazy. Unfortunately I think the CFI will not endorse me regardless because the DPEs won’t consider the endorsement valid, so it’s just not worth fighting.

 

[midlifeflyer]

IIRC the CFI has to show >200 instructional hours logged B4 he can train another for CFI....

The new rule expanded the options. Basically took what was previously a 141 exception to the 36 month/200 hour requirement and made it universal. The question is looking at (ii) which does not include either. Emphasis is mine.

Flight training. A flight instructor who provides flight training to an initial applicant for a flight instructor certificate must meet the eligibility requirements prescribed in §61.183; hold the appropriate flight instructor certificate and rating; meet the requirements of the part under which the flight training is provided; and meet one of the following requirements—​

​

(i) Have held a flight instructor certificate for at least 24 calendar months; and​

​

(A) For training in preparation for an airplane, rotorcraft, or powered-lift rating, have given at least 200 hours of flight training as a flight instructor; or​

​

[snip]​

​

(ii) Have trained and endorsed, during the preceding 24 calendar months, at least five applicants for a practical test for a pilot certificate or rating, and at least 80 percent of all applicants endorsed in that period passed that test on their first attempt; or​

​

@Brad Z mentioned reading the explanation from the Final Rule.

The second qualification option modifies the previous § 61.195(h)(3). Previously, § 61.195(h)(3) allowed a person to serve as a flight instructor in an FAA-approved course for initial flight instructor applicants if that person has trained and endorsed at least five applicants for a practical test, at least 80 percent of those applicants passed the practical test on their first attempt, and the flight instructor has given at least 400 hours of flight training for training in an airplane, rotorcraft, or powered-lift rating (or 100 hours of flight training for training in a glider rating). This final rule modifies these requirements in the new § 61.195(h)(2)(ii) by removing the minimum flight training hour requirement and removing the requirement for the flight instructor to be serving in an FAA-approved course. Section 61.195(h)(2)(ii) now requires a flight instructor to have trained and endorsed, in the preceding 24 calendar months, at least five applicants for a practical test for a pilot certificate or rating, and at least 80 percent of those applicants must have passed that test on their first attempt. This will allow more flight instructors to exercise this qualification option as compared to the similar option previously available under § 61.195(h)(3).​

 

[Lindberg]

Personally I feel like it’s very clear, and I disagree with the DPE’s interpretation. I mostly just wanted to put the question out there and make sure I’m not crazy. Unfortunately I think the CFI will not endorse me regardless because the DPEs won’t consider the endorsement valid, so it’s just not worth fighting.

This was discussed during my CFI oral, along with many of the other regulations pertaining to my new certificate. If your CFI and DPE don't understand the rule, you may have other issues as well. Or perhaps this is an opportunity for you to demonstrate some of your teaching ability.

 

[MauleSkinner]

This was discussed during my CFI oral, along with many of the other regulations pertaining to my new certificate. If your CFI and DPE don't understand the rule, you may have other issues as well. Or perhaps this is an opportunity for you to demonstrate some of your teaching ability.

So am I reading (h)(1) correctly? (Post #6)

 

[midlifeflyer]

So am I reading (h)(1) correctly? (Post #6)

Looks that way. The alternatives for ground compliance are either:

24 months and at least 40 hours of ground training; or​

100 hours of ground training "in an FAA-approved course"​

But I wonder how practically relevant that might be. There is no requirement for a CFI candidate to receive a certain number of hours of ground, so the ground portion can be done in a number of ways. A qualified ground instructor; a qualified CFI or ground instructor doing a mock oral; and online or group ground for the two knowledge tests come quickly to mind. I suspect those are used far more often than one-on-one ground.

Plus, I wonder how many CFIs track ground training given; if they don't, it doesn't exist and they can't meet even that 40 hour requirement. Even if they log it in their student's logbook (a rule that is probably violated every 3 minutes), I doubt there are many who track it for themselves. I've been a CFI since 1999. I doubt I could show 40 hours of ground given.

 

[MauleSkinner]

Looks that way. The alternatives for ground compliance are either:

24 months and at least 40 hours of ground training; or​

100 hours of ground training "in an FAA-approved course"​

But I wonder how practically relevant that might be. There is no requirement for a CFI candidate to receive a certain number of hours of ground, so the ground portion can be done in a number of ways. A qualified ground instructor; a qualified CFI or ground instructor doing a mock oral; and online or group ground for the two knowledge tests come quickly to mind. I suspect those are used far more often than one-on-one ground.

Plus, I wonder how many CFIs track ground training given; if they don't, it doesn't exist and they can't meet even that 40 hour requirement. Even if they log it in their student's logbook (a rule that is probably violated every 3 minutes), I doubt there are many who track it for themselves. I've been a CFI since 1999. I doubt I could show 40 hours of ground given.

While no specific time is required, 61.187 does specifically require ground training. And whether it’s logged or not, if an instructor who doesn’t meet the requirements of 61.197(h)(1) signs an endorsement stating that he gave the training required by 61.187, it wouldn’t seem to me to be a valid endorsement because he’s not an “authorized instructor.”

I think the OP’s DPEs are spot on, but the OP isn’t looking at the whole picture.

§ 61.187 Flight proficiency.​

(a) General. A person who is applying for a flight instructor certificate must receive and log flight and ground training from an authorized instructor on the areas of operation listed in this section that apply to the flight instructor rating sought. The applicant's logbook must contain an endorsement from an authorized instructor certifying that the person is proficient to pass a practical test on those areas of operation.
(b) Areas of operation.

(1) For an airplane category rating with a single-engine class rating:

(i) Fundamentals of instructing;
(ii) Technical subject areas;
(iii) Preflight preparation;
(iv) Preflight lesson on a maneuver to be performed in flight;
(v) Preflight procedures;
(vi) Airport and seaplane base operations;
(vii) Takeoffs, landings, and go-arounds;
(viii) Fundamentals of flight;
(ix) Performance maneuvers;
(x) Ground reference maneuvers;
(xi) Slow flight, stalls, and spins;
(xii) Basic instrument maneuvers;
(xiii) Emergency operations; and
(xiv) Postflight procedures.

 

[calicash]

While no specific time is required, 61.187 does specifically require ground training. And whether it’s logged or not, if an instructor who doesn’t meet the requirements of 61.197(h)(1) signs an endorsement stating that he gave the training required by 61.187, it wouldn’t seem to me to be a valid endorsement because he’s not an “authorized instructor.”

I think the OP’s DPEs are spot on, but the OP ant looking at the whole picture.

I'm just going to use King Schools for the ground training, they're the AGI. I get an endorsement for ground training at the end of it. Then, separately, the flight training is given by a CFI who doesn't need to provide any ground training because I did it already.

 

[calicash]

MauleSkinner, now that you've got me looking at the ground stuff it seems like there is one line in the regs that undermines the entire 61.195(h)(2) rule change, and it's 61.187(b)(1)(iv):

(iv) Preflight lesson on a maneuver to be performed in flight

...because this portion of the ground training has to be done by the applicant in person with an instructor who observes the lesson. So even if you use a flight instructor who satisfies 61.195(h)(2)(ii), you still need an in-person ground instructor who satisfies 61.195(h)(i). I wonder if they just straight-up forgot to change the 61.195(h)(1) language...

 

[Clip4]

Regardless of what the reg states, you are making a poor choice for an instructor for the CFI.

 

[Lindberg]

While no specific time is required, 61.187 does specifically require ground training. And whether it’s logged or not, if an instructor who doesn’t meet the requirements of 61.197(h)(1) signs an endorsement stating that he gave the training required by 61.187, it wouldn’t seem to me to be a valid endorsement because he’s not an “authorized instructor.”

I think the OP’s DPEs are spot on, but the OP isn’t looking at the whole picture.

The endorsing CFI does not have to be the one that gave all of the training.

 

[Clip4]

The endorsing CFI does not have to be the one that gave all of the training.

If a CFI does not meet the experiance requirements to train initial CFIs, they may not provide any training to an initial CFI.

A flight instructor who provides flight training to an initial applicant for a flight instructor certificate must meet the eligibility requirements prescribed in § 61.183; hold the appropriate flight instructor certificate and rating; meet the requirements of the part under which the flight training is provided; and meet one of the following requirements—

The ground training provided to an initial applicant for a flight instructor certificate must be given by an authorized instructor who—

 

[flyingcheesehead]

Ah, another reg thread! Don't tell CAMI how much I love these.

Here’s the situation: I need initial CFI training to prepare for a CFI checkride in the near future and need an instructor. There is an instructor at my FBO who has not had his CFI certificate for 24 months, but has trained and endorsed more than five checkride applicants in the last 24 months and more than 80% have passed on their first attempt. In my view this qualifies him to train and endorse initial CFI applicants under the new 61.195(h)(2)(ii) which went into effect last December.

More than one local DPE has told this instructor that he is not qualified to endorse initial CFI applicants because the instruction is part 61 and not part of an FAA-approved course, i.e. part 141. Are they wrong?

I did a quick search to make sure this hasn’t been talked about before and didn't find anything but sorry if this has come up already.

Okay, let's look at the reg. I'm going to gray some things out that aren't relevant, and enhance others for clarity:

(h) Qualifications to provide ground or flight training to initial flight instructor applicants —

(1) Ground training. The ground training provided to an initial applicant for a flight instructor certificate must be given by an authorized instructor who—​

(i) Holds a ground or flight instructor certificate with the appropriate rating, has held that certificate for at least 24 calendar months, and has given at least 40 hours of ground training; or​

(ii) Holds a ground or flight instructor certificate with the appropriate rating, and has given at least 100 hours of ground training in an FAA-approved course.​

(2) Flight training. A flight instructor who provides flight training to an initial applicant for a flight instructor certificate must meet the eligibility requirements prescribed in § 61.183; hold the appropriate flight instructor certificate and rating; meet the requirements of the part under which the flight training is provided; and meet one of the following requirements—​

(i) Have held a flight instructor certificate for at least 24 calendar months; and​

(A) For training in preparation for an airplane, rotorcraft, or powered-lift rating, have given at least 200 hours of flight training as a flight instructor; or​

(B) For training in preparation for a glider rating, have given at least 80 hours of flight training as a flight instructor;​

(ii) Have trained and endorsed, during the preceding 24 calendar months, at least five applicants for a practical test for a pilot certificate or rating, and at least 80 percent of all applicants endorsed in that period passed that test on their first attempt; or​

(iii) After completing the flight training requirements in paragraph (h)(2)(i)(A) or (B) of this section, as appropriate, have graduated from an FAA-approved flight instructor enhanced qualification training program that satisfies the requirements specified in paragraph (h)(3) of this section.​

Regarding the flight training requirements, in (h)(2), the "or" at the end of (h)(2)(ii) means that only one of (i), (ii), or (iii) needs to be met. Since it sounds like your CFI meets those requirements, and presumably the 61.183 requirements as well, that CFI may give you the flight training and endorse it as such.

It looks to me like the instructor can provide the flight training under 61.195(h)(2)(ii), but not the ground training because he doesn’t meet the requirements of (h)(1) for the reason stated by the examiners.

I agree on the ground part. The "and" in (h)(1)(i) means that all of those requirements must be met for (h)(1)(i) to be satisfied, and while the "or" at the end of the same line means that (h)(1)(i) would be irrelevant if (h)(1)(ii) were met, it doesn't sound like this particular instructor meets either. More on that later.

While no specific time is required, 61.187 does specifically require ground training. And whether it’s logged or not, if an instructor who doesn’t meet the requirements of 61.197(h)(1) signs an endorsement stating that he gave the training required by 61.187, it wouldn’t seem to me to be a valid endorsement because he’s not an “authorized instructor.”

I think the OP’s DPEs are spot on, but the OP isn’t looking at the whole picture.

So, if the OP uses King Schools and gets the ground endorsement from them and takes the written, it doesn't matter that his CFI can't give the ground, right? I'm not aware of any requirement for any rating that the ground and flight have to be signed off by the same person, and in fact that would make Ground Instructors completely irrelevant.

MauleSkinner, now that you've got me looking at the ground stuff it seems like there is one line in the regs that undermines the entire 61.195(h)(2) rule change, and it's 61.187(b)(1)(iv):

(iv) Preflight lesson on a maneuver to be performed in flight

...because this portion of the ground training has to be done by the applicant in person with an instructor who observes the lesson. So even if you use a flight instructor who satisfies 61.195(h)(2)(ii), you still need an in-person ground instructor who satisfies 61.195(h)(i). I wonder if they just straight-up forgot to change the 61.195(h)(1) language...

I'm not sure I agree. At the most basic level it would seem that since it's on the ground, it's ground... But likewise, 61.187(b)(1) includes several items that are "ground" items - All of (i) through (v), (viii), and (xiv). And while 61.187(a) states that the applicant "must receive and log flight and ground training from an authorized instructor...", 61.187 overall is labeled "Flight proficiency." My read would be that the 61.185 items need to be given and signed off by an "authorized instructor" that meets 61.195(h)(1) and the 61.187 items can be given and signed off by an authorized instructor that meets 61.195(h)(2). Per 61.1(b):

Authorized instructor means—​

(i) A person who holds a ground instructor certificate issued under part 61 of this chapter and is in compliance with § 61.217, when conducting ground training in accordance with the privileges and limitations of his or her ground instructor certificate;​

(ii) A person who holds a flight instructor certificate issued under part 61 of this chapter and is in compliance with § 61.197, when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate; or​

(iii) A person authorized by the Administrator to provide ground training or flight training under part 61, 121, 135, or 142 of this chapter when conducting ground training or flight training in accordance with that authority.​

Since good flight training requires some ground training to be conducted as well, and not being able to conduct the 61.187 training would make 61.195(h)(2)(ii) completely irrelevant, I'm fairly confident that the FAA would allow the CFI to give the ground portions of 61.187 and allow for entities like King Schools to do the 61.185 portion as they have for many years.

But, this is an instance where these issues could be brought up to the Chief Counsel's office for an official interpretation. That would prevent DPEs' personal opinions from interfering.

 

[MauleSkinner]

So, if the OP uses King Schools and gets the ground endorsement from them and takes the written, it doesn't matter that his CFI can't give the ground, right? I'm not aware of any requirement for any rating that the ground and flight have to be signed off by the same person, and in fact that would make Ground Instructors completely irrelevant.

61.187 is not about written test prep, it’s about practical test prep, and it specifically requires “ground training,” which requires 61.197(h)(1) qualification.

That doesn’t make ground instructors irrelevant…there are still plenty of training events that a ground instructor can complete, including the ground instruction for a flight instructor practical test. But it also means that if an instructor provides the endorsement required by 61.183(g), he’s attesting that someone else’s instruction is satisfactory. While there are places I might do that, instructor training under Part 61 isn’t one of them.

 

[flyingcheesehead]

61.187 is not about written test prep, it’s about practical test prep,

Agreed - 61.185 is the written part.

and it specifically requires “ground training,” which requires 61.197(h)(1) qualification.

No, it requires "Flight and ground training". Splitting hairs, I know, but give me a sec...

Back to 61.1:

Flight training means that training, other than ground training, received from an authorized instructor in flight in an aircraft.​

Ground training means that training, other than flight training, received from an authorized instructor.​

Gotta love the FAA. "It's A if it's not B, and it's B if it's not A" other than the words "in flight in an aircraft".

But does that mean that the CFI in question here can't give the preflight briefing and instruction about what will be taught in flight, or the post-flight debrief, because he doesn't meet 61.197(h)(1)? That would make (h)(2)(ii) pretty much irrelevant/worthless and it would not meet the intent of the change as published in the Federal Register.

So where exactly do you draw the line? Only the FAA can really answer that question, but they won't answer it until someone asks it.

 

[MauleSkinner]

Agreed - 61.185 is the written part.

No, it requires "Flight and ground training". Splitting hairs, I know, but give me a sec...

Back to 61.1:

Flight training means that training, other than ground training, received from an authorized instructor in flight in an aircraft.​

Ground training means that training, other than flight training, received from an authorized instructor.​

Gotta love the FAA. "It's A if it's not B, and it's B if it's not A" other than the words "in flight in an aircraft".

But does that mean that the CFI in question here can't give the preflight briefing and instruction about what will be taught in flight, or the post-flight debrief, because he doesn't meet 61.197(h)(1)? That would make (h)(2)(ii) pretty much irrelevant/worthless and it would not meet the intent of the change as published in the Federal Register.

So where exactly do you draw the line? Only the FAA can really answer that question, but they won't answer it until someone asks it.

It doesn’t matter where the line is drawn. You’ve got to have an instructor who’s qualified under (h)(1) and an instructor who’s qualified under (h)(2). If they’re different instructors, your premise is that one of them signs off on the other’s instruction in the endorsement required by 61.183(g).

 

[calicash]

I just faxed the Chief Counsel's office so hopefully we'll have some official input soon. Thanks to everyone for all the input so far, very interesting indeed.

 

[midlifeflyer]

If a CFI does not meet the experiance requirements to train initial CFIs, they may not provide any training to an initial CFI.

Absolutely true. I’m guessing he’s saying that instruction does not have to be done by only one person.

 

[flyingcheesehead]

It doesn’t matter where the line is drawn. You’ve got to have an instructor who’s qualified under (h)(1) and an instructor who’s qualified under (h)(2). If they’re different instructors, your premise is that one of them signs off on the other’s instruction in the endorsement required by 61.183(g).

It matters in that if you take the regs and definitions completely literally, there was zero point to the changes to 61.195 because the instructor who doesn't teach for the "FAA Approved course" can't effectively give any instruction unless they have another instructor do their pre and post flight briefs.

However, for other ratings, it's not at all uncommon to have one instructor (or company) sign off for the ground, analogous to the 61.183(d) requirement, and a separate instructor sign off for the flight proficiency section (analogous to 61.187), analogous to the 61.183(g) requirement.

So, either they'll interpret it as "everything in 61.187 is flight training" and the instructor in question here is good, or they screwed up their update because they forgot about 61.195(h)(1) and they need to do another update.

 

[MauleSkinner]

It matters in that if you take the regs and definitions completely literally, there was zero point to the changes to 61.195 because the instructor who doesn't teach for the "FAA Approved course" can't effectively give any instruction unless they have another instructor do their pre and post flight briefs.

However, for other ratings, it's not at all uncommon to have one instructor (or company) sign off for the ground, analogous to the 61.183(d) requirement, and a separate instructor sign off for the flight proficiency section (analogous to 61.187), analogous to the 61.183(g) requirement.

So, either they'll interpret it as "everything in 61.187 is flight training" and the instructor in question here is good, or they screwed up their update because they forgot about 61.195(h)(1) and they need to do another update.

since you keep bringing the knowledge test endorsement into this, it’s clear that you don’t understand the issue, so have a nice day.

 

[flyingcheesehead]

since you keep bringing the knowledge test endorsement into this, it’s clear that you don’t understand the issue, so have a nice day.

I'm trying to understand the issue. It sounds like 61.195(h)(1) completely nullifies the change that the FAA made to 61.195(h)(2)(ii), if (h)(1) applies to any instruction not given in an airplane... So why'd they make the change?

 

[MauleSkinner]

I'm trying to understand the issue. It sounds like 61.195(h)(1) completely nullifies the change that the FAA made to 61.195(h)(2)(ii), if (h)(1) applies to any instruction not given in an airplane... So why'd they make the change?

Per the Final Rule, excerpted earlier, they made the change to “allow more flight instructors to exercise this qualification option as compared to the similar option previously available under § 61.195(h)(3).”

As a practical application, let’s say a pilot without any kind of FAA instructor certificate spends 20 years working for a 121 or 135 operator, and his duties include providing ground instruction for company pilots in their FAA-approved training program, which doesn’t require an instructor certificate. He “has given at least 100 hours of ground training in an FAA-approved course” for the operator.

He retires, and decides to get his flight instructor certificate to share his experience. He endorses 5 pilots for their Private Pilot checkride in his first 6 months, and they all pass.

Within 6 months as a flight instructor, he is qualified to provide both ground and flight training to initial flight instructor applicants, and 61.195(h)(1) isn’t nullified.

 

[flyingcheesehead]

Per the Final Rule, excerpted earlier, they made the change to “allow more flight instructors to exercise this qualification option as compared to the similar option previously available under § 61.195(h)(3).”

As a practical application, let’s say a pilot without any kind of FAA instructor certificate spends 20 years working for a 121 or 135 operator, and his duties include providing ground instruction for company pilots in their FAA-approved training program, which doesn’t require an instructor certificate. He “has given at least 100 hours of ground training in an FAA-approved course” for the operator.

He retires, and decides to get his flight instructor certificate to share his experience. He endorses 5 pilots for their Private Pilot checkride in his first 6 months, and they all pass.

Within 6 months as a flight instructor, he is qualified to provide both ground and flight training to initial flight instructor applicants, and 61.195(h)(1) isn’t nullified.

Aaaaahhhh, now it's starting to make sense. Thank you.

And now I'm kicking myself for not logging the 135 ground instruction I gave. Probably wasn't 100 hours as I mainly just came in to do EFB, SMS, Security, and occasionally some other parts, but it was something.

 

[Sierra_Hotel]

Looks that way. The alternatives for ground compliance are either:

24 months and at least 40 hours of ground training; or​

100 hours of ground training "in an FAA-approved course"​

But I wonder how practically relevant that might be. There is no requirement for a CFI candidate to receive a certain number of hours of ground, so the ground portion can be done in a number of ways. A qualified ground instructor; a qualified CFI or ground instructor doing a mock oral; and online or group ground for the two knowledge tests come quickly to mind. I suspect those are used far more often than one-on-one ground.

Plus, I wonder how many CFIs track ground training given; if they don't, it doesn't exist and they can't meet even that 40 hour requirement. Even if they log it in their student's logbook (a rule that is probably violated every 3 minutes), I doubt there are many who track it for themselves. I've been a CFI since 1999. I doubt I could show 40 hours of ground given.

The only reason I'd be able to show any at all is that's how I tracked total hours I could bill, so I'd track total lesson time for pay, then flight time for time.