Does an IPC count as a BFR?

"Richard Kaplan" wrote
I agree that on first glance this would prohibit me from providing flight
instruction in a twin because both my pilot certificate and my instructor
certificate would need to contain both the Category Airplane and the Class
Single-Engine Land. Yet if this is true, then how can there exist flight
instructor certificates which only state "Instrument Airplane" because a
strict interpretation of the above would render such an instructor
certificate useless.

I concur that strict interpretation would render a CFI-IA with no
other ratings useless. In reality, we know the rule is not
interpreted that way. So once again the rules are not clear.

You may be right, but this would be meaningless.

Meaningless but legal -- yes, I agree. Again, I am not proposing I or any
other single-engine CFI do this. It just seems to be a loophole in the
FARS, probably a dangerous loophole at that.

No, my point is that this loophole - a non-multiengine CFII giving
dual in a sim configured as a twin for purposes of an IPC - is not
dangerous at all. For purposes of legality, an IPC given in a single
also covers you in a twin. The only difference between the single and
twin IPC is the engine-out stuff; otherwise the twin flies just like a
complex single. So my point is that the loophole would allow you to
teach and evaluate the multiengine portion of the ICC, and you
probably could not do that competently, but it's not required anyway.

So the question would be - is the sim training ground or flight
training? If it's ground training, then an IGI would be an authorized
instructor and this would be legal. If it's flight training, then he
would not be authorized and it wouldn't be legal.

It is ground training but the ground training can serve as a legal IPC so it
does seem to be a loophole again as I understand it.

Now this is a dangerous loophole - all you need to do to be an IGI is
take two written multiple-guess tests. I would imagine this would be
well within the capability of most professionals with no flight
experience at all...

Michael