question about instrument proficiency check

Until recently I was convinced that only a CFII could
conduct an instrument proficiency check (as opposed
to a plain CFI), but now I am confused:

14 CFR 61.195(c) says that an instructor must have an
instrument rating on *both* his pilot and instructor
certificates, i.e., be a CFII, in order to "provide(s)
instrument flight training *for the issuance of an
instrument rating*";

This is how a plain CFI (not II) can provide the training
required to satisfy the requirements of good old
14 CFR 61.109(a)(3) -- i.e., the three hours training
by sole reference to instruments required to get a
private certificate;

Now, the problem is that I haven't found where in the
regulations it is specified that a CFII must conduct
the instrument proficiency check (which is *not* training
for the issuance of an instrument rating that the student
already has); 14 CFR 61.57(d) says training has to be
provided by an 'authorized instructor' (in addition to
examiners etc.) -- is this what I am missing? that
would be an odd use of the term 'authorized instructor'
as compared to other places in the regs.

Now I probably missed something obvious, but can a
CFI (not II) provide the training and endorse someone's
instrument proficiency check? (and if not where is it
said in the regs?)

Note: I am not trying to do something silly, but
I am in the process of studying the regs in details
and I like to understand the fine points.

--Sylvain

On Mon, 17 Oct 2005 14:30:27 -0700, Sylvain wrote:

Until recently I was convinced that only a CFII could
conduct an instrument proficiency check (as opposed
to a plain CFI), but now I am confused:


Now, the problem is that I haven't found where in the
regulations it is specified that a CFII must conduct
the instrument proficiency check (which is *not* training
for the issuance of an instrument rating that the student
already has); 14 CFR 61.57(d) says training has to be
provided by an 'authorized instructor' (in addition to
examiners etc.) -- is this what I am missing? that
would be an odd use of the term 'authorized instructor'
as compared to other places in the regs.

Now I probably missed something obvious, but can a
CFI (not II) provide the training and endorse someone's
instrument proficiency check? (and if not where is it
said in the regs?)

I can't find that statement specifically in the regs, although in John
Lynch's FAQ's regarding Part 61, he does state clearly "The flight
instructor who administers the Instrument Proficiency Check of § 61.57(d)
must hold a CFII-Airplane rating and as per § 61.195(c), the flight
instructor must ". . . hold an instrument rating on his or her flight
instructor certificate and pilot certificate that is appropriate to the
category and class of aircraft in which instrument training is being
provided."

Of course, John Lynch has been wrong in certain of his pronouncements; but
this one has been in there for a few years without argument, so far as I
know.

He also writes, in another question, almost identical to yours:

====================================

QUESTION: Is it true that a CFI giving an endorsement for an Instrument
Proficiency Check must have an instrument rating (CFII) on his/her flight
instructor certificate? I can't seem to find anything in the current Part
61 that states that an Instrument Proficiency Check endorsement requires a
CFII. The § 61.57(d)(2)(iv) requires an "authorized instructor". The
definition of "authorized instructor" now seems to come from § 61.193
(Flight Instructor Privileges) and § 61.195 (Flight Instructor
Limitations). The only reference to a requirement for a CFII that I can
find is in § 61.195(c).

ANSWER: Ref. § 61.57(d)(2)(iv) and § 61.193; A flight instructor who
performs an instrument proficiency check, as required by § 61.57(d), must
hold the appropriate instrument rating for the category and class of
aircraft that the instrument proficiency check is being conducted in. As
per § 61.193, it states in pertinent part, ". . . A person who holds a
flight instructor certificate is authorized within the limitations of that
person's flight instructor certificate and ratings to give training and
endorsements that are required for, and relate to:
* * * * *
(f) An instrument rating;

A flight instructor who does not hold an instrument rating on their flight
instructor certificate that is appropriate to the category and class of
aircraft that the instrument proficiency check is being conducted in is not
authorized to conduct the instrument proficiency check.

The term "authorized instructor" was intentionally used in § 61.57(d)
because authorization to conduct an instrument proficiency check is not
limited to a CFII. A Ground Instructor Certificate - Instrument Rating is
also an "authorized instructor" and is authorized to give the instrument
proficiency check in an approved flight training device. Also, a Part 142
training center instructor, who may or may not hold any certificate or
ratings, can be an "authorized instructor" who may give the instrument
proficiency check that is performed under an approved Part 142 training
program in an approved flight simulator, in accordance with a Part 142
approved training program. Another example, a pilot who holds a Letter of
Operational Authority (LOOA) may give the endorsements for the instrument
proficiency check to a holder of a Letter of Authorization (LOA).) Holders
of an LOOA give training for the endorsement for the Letter of
Authorization (LOA) allowing a pilot to act as pilot in command in surplus
military turbine or piston powered airplane, in accordance with FAA Order
8700.1, Chapter 32. However, in this case, the holder's Letter of
Operational Authority (LOOA) must specifically state this authority to give
the endorsements for the instrument proficiency check. And so the
rulemaking team that drafted the new Part 61 decided on merely stating . .
.. An authorized flight instructor . . ." But notice in § 61.57(d)(2)(v),
we also included ". . . A person approved by the Administrator to conduct
instrument practical tests."
{Q&A-315}
=====================================


Note: I am not trying to do something silly, but
I am in the process of studying the regs in details
and I like to understand the fine points.

Good luck. That is one of the known methods of driving yourself crazy!

Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Ron Rosenfeld wrote:
I can't find that statement specifically in the regs, although in John
Lynch's FAQ's regarding Part 61,

thanks a bunch! I feel silly not to have looked for it in
the FAQ first (the fact that there is an entry in the
FAQ on this very subject would tend to show that the regs
by themselves are a wee bit ambiguous :-) )

--Sylvain

On Mon, 17 Oct 2005 22:06:50 -0700, Sylvain wrote:

the regs
by themselves are a wee bit ambiguous :-) )

Fer sure!
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Mon, 17 Oct 2005 22:06:50 -0700, Sylvain wrote:

Ron Rosenfeld wrote:
I can't find that statement specifically in the regs, although in John
Lynch's FAQ's regarding Part 61,

thanks a bunch! I feel silly not to have looked for it in
the FAQ first (the fact that there is an entry in the
FAQ on this very subject would tend to show that the regs
by themselves are a wee bit ambiguous :-) )

--Sylvain



A ground instructor can give the training, but cannot sign off an IPC.
Sounds a little strange, but true. Only a CFII can endorse the IPC.
This information was taught at Oklahoma City during the initial pilot
examiner certification course. You can look at FAR 61.215 and see
that it is not included within the priveliges afforded ground
instructors.

On Tue, 18 Oct 2005 21:51:25 GMT, Bill Zaleski
wrote:

On Mon, 17 Oct 2005 22:06:50 -0700, Sylvain wrote:

Ron Rosenfeld wrote:
I can't find that statement specifically in the regs, although in John
Lynch's FAQ's regarding Part 61,

thanks a bunch! I feel silly not to have looked for it in
the FAQ first (the fact that there is an entry in the
FAQ on this very subject would tend to show that the regs
by themselves are a wee bit ambiguous :-) )

--Sylvain



A ground instructor can give the training, but cannot sign off an IPC.
Sounds a little strange, but true. Only a CFII can endorse the IPC.
This information was taught at Oklahoma City during the initial pilot
examiner certification course. You can look at FAR 61.215 and see
that it is not included within the priveliges afforded ground
instructors.

How about if the IPC is given in a sim?


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Tue, 18 Oct 2005 20:45:29 -0400, Ron Rosenfeld
wrote:

On Tue, 18 Oct 2005 21:51:25 GMT, Bill Zaleski
wrote:

On Mon, 17 Oct 2005 22:06:50 -0700, Sylvain wrote:

Ron Rosenfeld wrote:
I can't find that statement specifically in the regs, although in John
Lynch's FAQ's regarding Part 61,

thanks a bunch! I feel silly not to have looked for it in
the FAQ first (the fact that there is an entry in the
FAQ on this very subject would tend to show that the regs
by themselves are a wee bit ambiguous :-) )

--Sylvain



A ground instructor can give the training, but cannot sign off an IPC.
Sounds a little strange, but true. Only a CFII can endorse the IPC.
This information was taught at Oklahoma City during the initial pilot
examiner certification course. You can look at FAR 61.215 and see
that it is not included within the priveliges afforded ground
instructors.

How about if the IPC is given in a sim?


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Doesn't change anything. A ground instructor's priveliges are
specified in 61.215. Endorsing an IPC is not one of them.

On Wed, 19 Oct 2005 01:34:56 GMT, Bill Zaleski
wrote:

On Tue, 18 Oct 2005 20:45:29 -0400, Ron Rosenfeld
wrote:

On Tue, 18 Oct 2005 21:51:25 GMT, Bill Zaleski
wrote:

On Mon, 17 Oct 2005 22:06:50 -0700, Sylvain wrote:

Ron Rosenfeld wrote:
I can't find that statement specifically in the regs, although in John
Lynch's FAQ's regarding Part 61,

thanks a bunch! I feel silly not to have looked for it in
the FAQ first (the fact that there is an entry in the
FAQ on this very subject would tend to show that the regs
by themselves are a wee bit ambiguous :-) )

--Sylvain



A ground instructor can give the training, but cannot sign off an IPC.
Sounds a little strange, but true. Only a CFII can endorse the IPC.
This information was taught at Oklahoma City during the initial pilot
examiner certification course. You can look at FAR 61.215 and see
that it is not included within the priveliges afforded ground
instructors.

How about if the IPC is given in a sim?


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Doesn't change anything. A ground instructor's priveliges are
specified in 61.215. Endorsing an IPC is not one of them.

OK -- now I have to go back and try to find what I was vaguely remembering
....

That's contrary to what Lynch writes in Q&A315

"... The term "authorized instructor" was intentionally used in § 61.57(d)
because authorization to conduct an instrument proficiency check is not
limited to a CFII. A Ground Instructor Certificate - Instrument Rating is
also an "authorized instructor" and is authorized to give the instrument
proficiency check in an approved flight training device."

Lynch also lists some other, non-CFII types that are authorized to give
IPC's under certain circumstances.

Having written that, I agree with you that 61.215(c) is contrary to what
Lynch writes in that it mentions only the "training" and if the FAA wanted
to allow IGI's to give IPC's in FTD's, they could have specifically so
stated in that section.

So it seems this is another area of Lynch's FAQ's that should be changed.

But let me check the most recent version -- the one I was looking was 2003.

....

Nope -- unchanged in 2005. I'll send him an email.

"onward through the fog"


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Ron Rosenfeld wrote:

So it seems this is another area of Lynch's FAQ's that should be changed.

....or may be it is part 61 that needs some rewrite...

ok, now, I am getting confused (well, a little bit more than I was
already that is :-) ); is there any examiner reading this?
what would be the answers to these questions (privileges of flight and
ground instructors) least likely to have someone fail a CFI checkride?
:-)

--Sylvain

On Tue, 18 Oct 2005 19:36:41 -0700, Sylvain wrote:

Ron Rosenfeld wrote:

So it seems this is another area of Lynch's FAQ's that should be changed.

...or may be it is part 61 that needs some rewrite...

ok, now, I am getting confused (well, a little bit more than I was
already that is :-) ); is there any examiner reading this?
what would be the answers to these questions (privileges of flight and
ground instructors) least likely to have someone fail a CFI checkride?
:-)

--Sylvain

I would think that if OK city is teaching at an Examiner's training session
that an IGI cannot give an FPC in an FTD, & that Lynch's FAQ's say they
can, that something needs to be changed.

I did point all this out in my email to Lynch.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)