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

"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

"Bill Zaleski" wrote in message
...

of experience issue. An IPC consists of both ground and flight
examination, as per the rating task table of the instrument PTS. A

I agree for the most part with what you are saying. However, a flight
training device may be used as a substitute for the flight portion of the
IPC. The definition of flight time in 1.1 requires an aircraft for flight.
Therefore, it would seem that the training done in a flight training device
is legally ground training rather than flight training.

Let us take the other side of what you are saying and conclude that an IGI
can only perform the ground training elements of the PTS and not the flight
elements. Well there is no mechanism in Part 91 for an IPC to be done by 2
separate instructors; the only way 2 separate instructors can work on an IPC
is through a certified school such as a Part 142 school. So if an IGI
cannot sign off an IPC in a flight training device, then the IGI would have
no role at all for a Part 91 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

"Bill Zaleski" wrote in message
...

Let's not make this more difficult that it is. Just check the
limitations section of the FAR's pertaining to flight instructors.

I agree this is what the FARs say. However, the FAA then breaks its own
rules when they issue CFII-only certificates bearing "Instrument Airplane"
as the category/class description since "Instrument Airplane" is not a
category/class yet the FARs say an instructor can only instructor in the
category/class on his instructor certificate.


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

www.flyimc.com

Category and class does NOT necessarily go on the instructor
certificate. You never see "sea" on one. You must, however, have the
specific class on your pilot certificate for the aircraft you intend
to give instruction in, even if it's instrument instruction. If you
don't hold multi and instrument priviliges on BOTH of your
certificates, you can't give ANY instrument instruction in multi's.
The reason that reference is made to category and class with respect
to flight instructor certificates in the exception in that an
instrument- rotorcraft helicopter rating on an instructor certificate
does not include gyroplane, since it doesn't exist. The same reg
references the need for a type rating, if appropriate, but of course
that doesn't exist either on CFI certificates. You must however, hold
the type rating on the pilot cert in order to give any instruction in
such an aircraft. Again, there is no gray area. FAR 61.195 (b)
(aircraft ratings) is clear that you must comply with both provisions
in entirety, not just one of them. The pre-1997 wording of the FAR
was a grey area loophole that has been plugged.


On Sat, 20 Mar 2004 14:39:37 GMT, "Richard Kaplan"
wrote:




"Bill Zaleski" wrote in message
.. .

Let's not make this more difficult that it is. Just check the
limitations section of the FAR's pertaining to flight instructors.

I agree this is what the FARs say. However, the FAA then breaks its own
rules when they issue CFII-only certificates bearing "Instrument Airplane"
as the category/class description since "Instrument Airplane" is not a
category/class yet the FARs say an instructor can only instructor in the
category/class on his instructor certificate.


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

www.flyimc.com

Thanks for the clarification.


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

www.flyimc.com