Does an IPC count as a BFR?

Mark Kolber wrote
As to why, it's pretty hokey, but there's some theory going around
that the CFI-I is easier, so, if you have to have an inspector for the
first ride, it might as well be the easier one.

The real reason is a little different. For all practical purposes,
you can't rent a complex airplane that isn't decades old. Any
determined fed can ground an airplane that old, and that's normal
practice in many FSDO's. If you go for an initial CFI ride in many
cases you get three inspectors - one ops and two maintenance. The ops
inspector starts your oral, and the maintenance inspectors start going
over the airplane. Oral ends when they ground it, and you get a pink
slip and, if you have the temerity to question their determination
(airplane not airworthy because the placard is curled up/TSO tag on
seatbelt unreadable/repair or alteration logged in logbook is major,
not minor, and requires Form 337) or the inspector just doesn't like
you, you get written up for flying an unairworthy airplane as well. I
know people who have had this happen, and there's at least one CFI on
this newsgroup who has his own story of something very similar.

The CFII ride need not be in a complex airplane - and new full-IFR
C-172's are available for rent all over. It's very difficult to
ground a new airplane. Thus I recommend that anyone doing an initial
CFI go over to a place that rents new C-172's and do the CFII first.

I did my initial CFI in a glider for the same reason - a new glider
was locally available for rent, and there was no way to flunk it
because it was new and completely unmodified - everything was just the
way it came from the factory.

Michael

Related to this question of earning a CFII but not a CFI, I have not done
what follows and I am not sure the regs make sense in this area, but from a
strictly legal perspective I believe I can give an instrument proficiency
check in a multi-engine airplane even though I am not a multi-engine pilot.
My certificates are Commercial Pilot (ASEL + Instrument Airplane) and CFI
(Airplane Single Engine + Instrument Airplane).

Again I realize this may not make much sense from an instructional point of
view, but legally I do not see any reason I could not do this except (even
more oddly) that this would have to be done in actual IMC because I would
not be qualified to act as a safety pilot -- correct?

Perhaps somewhat more practically speaking, I see no reason why I could not
sign off an IPC done with my simulator (Level 3 FTD) in twin-engine mode
since I do not need to be PIC to "create" IMC in the simulator and my CFI
instrument privileges refer to instrument airplane and not specifically to
single- or multi-engine airplanes.

Indeed, extending this further, my understanding is that a non-pilot could
pass the written exam to become an Instrument Ground Instructor and then
without ever setting foot in an airplane he could do an IPC in the simulator
(again a Level 3 FTD) and this non-pilot would have the authority to sign
off the pilot of a cabin-class twin as safe to fly in IMC.

Again, I am not proposing any of these tasks as sane -- I am simply asking
whether my interpretation of the FARs is correct.

--------------------
Richard Kaplan, CFII

www.flyimc.com

"Richard Kaplan" wrote
Related to this question of earning a CFII but not a CFI, I have not done
what follows and I am not sure the regs make sense in this area, but from a
strictly legal perspective I believe I can give an instrument proficiency
check in a multi-engine airplane even though I am not a multi-engine pilot.
My certificates are Commercial Pilot (ASEL + Instrument Airplane) and CFI
(Airplane Single Engine + Instrument Airplane).

I do not believe this is correct.

61.195 Flight instructor limitations and qualifications.
A person who holds a flight instructor certificate is subject to the
following
limitations:
(b) Aircraft ratings. A flight instructor may not conduct flight
training in any aircraft for which the flight instructor does not
hold:
(1) A pilot certificate and flight instructor certificate with the
applicable
category and class rating; and

For purposes of an instructor certificate, there are two classes
within the airplane category - ASE and AME. For purposes of a pilot
certificate, there are four classes within the airplane category -
ASEL, ASES, AMEL, and AMES. Thus, since you do not have a pilot
certificate with airplane category and multiengine land class (AMEL)
rating, I do not believe you could legally provide flight training in
a multiengine airplane.

Perhaps somewhat more practically speaking, I see no reason why I could not
sign off an IPC done with my simulator (Level 3 FTD) in twin-engine mode
since I do not need to be PIC to "create" IMC in the simulator and my CFI
instrument privileges refer to instrument airplane and not specifically to
single- or multi-engine airplanes.

You may be right, but this would be meaningless.

61.57(d)(1) The instrument proficiency check must be --
(i) In an aircraft that is appropriate to the aircraft category;
(ii) For other than a glider, in a flight simulator or flight training
device
that is representative of the aircraft category;

Note that there is no requirement for the simulator to be
representative of the class of aircraft, only the category. There is
no requirement for a multiengine pilot to take his IPC in a
multiengine airplane - any airplane will do. I see no reason why you
couldn't do this, but I also see no reason why anyone would ever want
to. It would have no regulatory purpose, and if you lack multinegine
experience it would have no practical purpose either.

Indeed, extending this further, my understanding is that a non-pilot could
pass the written exam to become an Instrument Ground Instructor and then
without ever setting foot in an airplane he could do an IPC in the simulator
(again a Level 3 FTD) and this non-pilot would have the authority to sign
off the pilot of a cabin-class twin as safe to fly in IMC.

Maybe, but I don't see that as obvious.

61.215 Ground instructor privileges.
(c) A person who holds an instrument ground instructor rating is
authorized to
provide:
(2) Ground training required for an instrument proficiency check;

61.57(d)(2) The instrument proficiency check must be given by --
(iv) An authorized instructor;

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.

Michael

--
--------------------
Richard Kaplan, CFII

www.flyimc.com
"Michael" wrote in message
om...
"Richard Kaplan" wrote
Related to this question of earning a CFII but not a CFI, I have not
done
what follows and I am not sure the regs make sense in this area, but
from a
strictly legal perspective I believe I can give an instrument
proficiency
check in a multi-engine airplane even though I am not a multi-engine
pilot.
My certificates are Commercial Pilot (ASEL + Instrument Airplane) and
CFI
(Airplane Single Engine + Instrument Airplane).

I do not believe this is correct.

61.195 Flight instructor limitations and qualifications.
A person who holds a flight instructor certificate is subject to the
following
limitations:
(b) Aircraft ratings. A flight instructor may not conduct flight
training in any aircraft for which the flight instructor does not
hold:
(1) A pilot certificate and flight instructor certificate with the
applicable
category and class rating; and

For purposes of an instructor certificate, there are two classes
within the airplane category - ASE and AME. For purposes of a pilot
certificate, there are four classes within the airplane category -
ASEL, ASES, AMEL, and AMES. Thus, since you do not have a pilot
certificate with airplane category and multiengine land class (AMEL)
rating, I do not believe you could legally provide flight training in
a multiengine airplane.

Perhaps somewhat more practically speaking, I see no reason why I could
not
sign off an IPC done with my simulator (Level 3 FTD) in twin-engine mode
since I do not need to be PIC to "create" IMC in the simulator and my
CFI
instrument privileges refer to instrument airplane and not specifically
to
single- or multi-engine airplanes.

You may be right, but this would be meaningless.

61.57(d)(1) The instrument proficiency check must be --
(i) In an aircraft that is appropriate to the aircraft category;
(ii) For other than a glider, in a flight simulator or flight training
device
that is representative of the aircraft category;

Note that there is no requirement for the simulator to be
representative of the class of aircraft, only the category. There is
no requirement for a multiengine pilot to take his IPC in a
multiengine airplane - any airplane will do. I see no reason why you
couldn't do this, but I also see no reason why anyone would ever want
to. It would have no regulatory purpose, and if you lack multinegine
experience it would have no practical purpose either.

Indeed, extending this further, my understanding is that a non-pilot
could
pass the written exam to become an Instrument Ground Instructor and then
without ever setting foot in an airplane he could do an IPC in the
simulator
(again a Level 3 FTD) and this non-pilot would have the authority to
sign
off the pilot of a cabin-class twin as safe to fly in IMC.

Maybe, but I don't see that as obvious.

61.215 Ground instructor privileges.
(c) A person who holds an instrument ground instructor rating is
authorized to
provide:
(2) Ground training required for an instrument proficiency check;

61.57(d)(2) The instrument proficiency check must be given by --
(iv) An authorized instructor;

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.

Michael

"Michael" wrote in message
om...:

(b) Aircraft ratings. A flight instructor may not conduct flight
training in any aircraft for which the flight instructor does not
hold1) A pilot certificate and flight instructor certificate with the
applicabl category and class rating; and

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.

It would seem to me that by using the term "Instrument Airplane" on pilot
and instructor certificates the FAA has created a Class of airplane simply
called "Instrument."


For purposes of an instructor certificate, there are two classes
within the airplane category - ASE and AME. For purposes of a pilot

What happens in the case of a CFII without a CFI. In that case doesn't the
instructor certificate read solely "Instrument Airplane"? In that case,
what is the category and class?

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.

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.




--------------------
Richard Kaplan, CFII

www.flyimc.com

"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

"Michael" wrote in message
om...

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.

OK, I agree there. Maybe this is actually helpful because if a twin-engine
pilot came to me to use my sim specifically so I could teach him how to use
a specific GPS or because he wanted to practice 0/0 landings then I could
put the sim in twin-engine mode to make him comfortable and still legally
log the instruction.

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...

Yes, it is dangerous. I think in practice the way this is mostly used is to
allow rated pilots who are seeking the CFI rating to gain some experience
instructing in a flight training device. But the loophole does exist as you
note for someone who has never been inside an airplane in his life to sign
off an IPC.


--------------------
Richard Kaplan, CFII

www.flyimc.com

There is no loophole as far as an IGI is concerned with reference to
his signing off an IPC. As per the part 61 regs, he may give the
ground training required for an IPC, but there is no provision that
allows him to give an endorsement for the IPC itself. This has been
answered through the FAQ's before and has been gone over during every
examiner recurrent seminar I have attended. A CFII is given that
privilege, however if you look at the wording of privileges given to
ground instructors, only endorsements for knowledge tests and ground
training are allowed. They are not allowed to endorse for any recency
of experience issue. An IPC consists of both ground and flight
examination, as per the rating task table of the instrument PTS. A
person who has never been in an aircraft, even though he holds a
ground instructor certificate, can not give an IPC any more than he
can give a flight review. Just compare the privileges of a CFII vs. a
ground instructor, as per the Part 61 regs.


On Fri, 19 Mar 2004 16:22:25 GMT, "Richard Kaplan"
wrote:

"Michael" wrote in message
. com...

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.

OK, I agree there. Maybe this is actually helpful because if a twin-engine
pilot came to me to use my sim specifically so I could teach him how to use
a specific GPS or because he wanted to practice 0/0 landings then I could
put the sim in twin-engine mode to make him comfortable and still legally
log the instruction.

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...

Yes, it is dangerous. I think in practice the way this is mostly used is to
allow rated pilots who are seeking the CFI rating to gain some experience
instructing in a flight training device. But the loophole does exist as you
note for someone who has never been inside an airplane in his life to sign
off an IPC.


--------------------
Richard Kaplan, CFII

www.flyimc.com

One scenario you have not considered. A CFII with no Seaplane RATING
giving instrument instruction in a Seaplane (the student has a
Seaplane rating).
Legal? I think so. Advisable? I don't see a problem with it.

(Michael) wrote in message . com...
"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

Let's not make this more difficult that it is. Just check the
limitations section of the FAR's pertaining to flight instructors.
Determine the category and class aircraft that you intend to get into
and perform some type of flight instructor duty in, be it instruction,
flight review, IPC, whatever. If you don't hold that same category
and class rating on both your pilot and instructor certificate, you
can't do it. This also applies to the class rating you hold
instrument privileges in on you pilot cert. If you are not multi IFR
rated, you can't give any type of instruction in a multi, even if it's
instrument instruction. You must hold a sea rating inorder to give
ANY type of instruction in a sea class airplane. It's pretty clear in
FAR 61.195 (b) & (c) Both of these sections must be considered, not
just one of them. Ask your FSDO. There is no loophole or grey area
here.



On 19 Mar 2004 14:02:17 -0800, (Doug)
wrote:

One scenario you have not considered. A CFII with no Seaplane RATING
giving instrument instruction in a Seaplane (the student has a
Seaplane rating).
Legal? I think so. Advisable? I don't see a problem with it.

(Michael) wrote in message . com...
"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