"Justin Maas" wrote
Bob - sorry, let me try to clear it up. Some schools were advertising part
91 operations where someone/something would be flown in a multi-engine
aircraft not requiring two crew members. To have the right seat pilot log
multi "dual given" time, they had him sign off the other pilot. Make any
sense? Basically, they were trying to act as if these part 91 flights were
instructional in nature when in fact, they weren't.

And therein lies the problem. There is no FSDO that I know of that
claims that one MEI can't take dual from another MEI, with one logging
PIC and dual given and the other logging PIC and dual received. If
some FSDO came up with this, how would MEI's like me ever be able to
log any recurrent or transition training? Can you imagine how badly
this would screw up my insurance? On the other hand, when two MEI's
take a 1-hour XC flight somewhere and each one comes back with a BFR
endorsement from the other, that's bull****, and we all know it. If
it's a two hour XC flight, I suppose you could claim that the first
hour was the BFR for MEI #1 and the second hour the BFR for MEI #2,
but really it's still bull**** - but not technically against the regs.

So what we've got is a FSDO that says "Hey, this is bull****, you guys
aren't really training, therefore we're not going to accept this as a
BFR." Do they have the legal authority to do this? No, but we can
all understand what they're trying to do. The scope of the BFR is
intentionally left very much open, so that the instructor has the
flexibility to tailor the recurrent training to the needs and
capabilities of the pilot. It might be private level maneuvers for a
pilot who is low time and/or doesn't fly much, but it will almost
certainly be advanced training for a pilot who is current and
proficient. The MEI's who just go somewhere for lunch and sign each
other off are loopholing the regs.

While the FAA really is an evil organization, that doesn't mean that
it's all one-sided. There are plenty of people out there who try to
abuse the system and inspectors who try to curtail the abuse -
generally in a manner that is ineffective, illegal, and incompetent.
That's what you're seeing here, and in a broader sense that underlies
a lot of the reason for the inconsistencies between FSDO's. Someone
comes up with a way to game the system, and some fed takes exception
to it - sometimes properly, as in this case, other times because he's
a worthless bloody loonie. He then comes up with a policy - an
interpretation of the rules - which is often illegal and generally
fails to fix the problem, but will make life difficult for others.
This will not be the same policy as in another FSDO - not better or
worse, but different.

Example - there's a local avionics shop that would do an entire panel
rebuild on a logbook entry (no Form 337). I mean a whole new radio
stack, recutting the instrument panel, the works. Clearly that's
bull**** - it's a major alteration - but they got tired of having
337's bounced back for punctuation errors (no **** - really happens,
happened to me) and decided that anything that was not absolutely
spelled out as a major alteration (autopilot install, for example)
they would consider minor. The result is that the FSDO got ****ed,
and decided that anything you couldn't do with just a screwdriver
would be considered major. It's contrary to official policy, it's
stupid, and it doesn't solve any problems - but that's just the way it
is.

Michael