wmuflyboy

first things first, i have not been an instructor for 2 years.

if you look in the FARs though it states under 61.195(H)(2):

Except for an instructor who meets the requirements of paragraph (h)(3)(ii) of this section, a flight instructor who provides training to an initial applicant for a flight instructor certificate must—
(i) Meet the eligibility requirements prescribed in §61.183 of this part;
(ii) Hold the appropriate flight instructor certificate and rating;
(iii) Have held a flight instructor certificate for at least 24 months;
(iv) For training in preparation for an airplane, rotorcraft, or powered-lift rating, have given at least 200 hours of flight training as a flight instructor; and
(v) For training in preparation for a glider rating, have given at least 80 hours of flight training as a flight instructor.


61.195(h)(3)(ii) states:

(ii) Have trained and endorsed at least five applicants for a practical test for a pilot certificate, flight instructor certificate, ground instructor certificate, or an additional rating, and at least 80 percent of those applicants passed that test on their first attempt; and

now i have a 100% student pass rate for more than 10 applicants, does this negate the 2 year rule and allow me to teach an initial CFI applicant. the general consensus has been you need to be a 2 year CFI and log 200 dual given. but when i look into the FARs, this seems not to be the case. am i missing something??

Twin Wasp

I think you have to back up a paragraph.

(h) Qualifications of the flight instructor for training first-time flight instructor applicants. (1) The ground training ...
(2) Except for an instructor who meets the requirements of paragraph (h)(3)(ii) of this section, a flight instructor who provides training to an initial applicant for a flight instructor certificate must—
(i) Meet the eligibility requirements prescribed in §61.183 of this part;
(ii) Hold the appropriate flight instructor certificate and rating;
(iii) Have held a flight instructor certificate for at least 24 months;
(iv) For training in preparation for an airplane, rotorcraft, or powered-lift rating, have given at least 200 hours of flight training as a flight instructor; and
(v) For training in preparation for a glider rating, ...

(3) A flight instructor who serves as a flight instructor in an FAA-approved course for the issuance of a flight instructor rating must hold a current flight instructor certificate with the appropriate rating and pass the required initial and recurrent flight instructor proficiency tests, in accordance with the requirements of the part under which the FAA-approved course is conducted, and must—
(i) Meet the requirements of paragraph (h)(2) of this section; or
(ii) Have trained and endorsed at least five applicants for a practical test for a pilot certificate, flight instructor certificate, ground instructor certificate, or an additional rating, and at least 80 percent of those applicants passed that test on their first attempt; and
(A) Given at least 400 hours of flight training as a flight instructor for training in an airplane, a rotorcraft, or for a powered-lift rating; or..

So if you're teaching a 141 CFI program, have an 80% pass rate and have given 400 dual, you don't have to meet the 2 year experience limit. If you say that the 80% pass rate trumps the two years for 61 pilots. it would also negate the requirement for the CFI to have a rating in the category the student CFI is applying for.

rickair7777

I agree with Wasp, that exemption only applies to part 141.

However...there's a big loophole you can exploit here.

ALL of the limitations on what a CFI can or cannot do usually only apply to specific types of training, usually "training required for a certificate or rating".

This means that the 2-year rule applies only to the ground training and aeronautical experience required for the rating. There is actually very little REQUIRED training for a CFI rating. IIRC it is three hours flight and no minimum on ground training.

This means that you can train the student to proficiency and do all the ground he needs, and then turn him over to a 2-year CFI for a couple final practice flights, ground knowledge check, and signoff.

As a freelancer it's not a bad idea to send the student up with another set of eyes before the checkride anyway. We used to do this all the time.

Actually ANYBODY can give flight training for the purpose of learning (I learned tailwheel from a non-CFI). You just need an appropriate rating to knock out the minimum aeronautical experience, ground training, and signoff/endorsement. Since there is usually no minimum amount of ground training (part 61), anyone can do the training and then a CFI can legally do one comprehensive knowledge check, which when logged, will count as the required ground training. Self-study is the same principle: you are your own teacher, and your CFI checks and signs off on your knowledge level.

jedinein

Not quite. The FAA's National Legal Council closed that loophole through a letter of interpretation several years ago. Outside of part 141, any training for the purpose of the CFI initial must be from an experienced (two year) flight instructor. I'll post the link once I find it.

wmuflyboy

above is true. i talked to my 'best friends' at the FSDO today. however, you guys are also right in the fact that the initial cfi applicant pretty much only needs 3 hours in the last 60 days and a sign off from a cfi who has 2 years/200 dual given.

Ian B

Twin Wasp has it right, there is no loophole! You're guilty of "selective reading" - what about 61.195 (h)(3) which is a prerequisite to even consider 61.195 (h)(3)(ii)...

Part 61.195 (h) (3) (not JUST part (ii)) - you have to comply with ALL of it states:
"(3) A flight instructor who serves as a flight instructor in an FAA-approved course for the issuance of a flight instructor rating must hold a current flight instructor certificate with the appropriate rating and pass the required initial and recurrent flight instructor proficiency tests, in accordance with the requirements of the part under which the FAA-approved course is conducted, and must--
(i) Meet the requirements of paragraph (h)(2) of this section; or
(ii) Have trained and endorsed at least five applicants for a practical test for a pilot certificate, flight instructor certificate, ground instructor certificate, or an additional rating, and at least 80 percent of those applicants passed that test on their first attempt; and......"
Note: IN AN FAA APPROVED COURSE - IE Part 141 school!
Unless you work in a Part 141 school 2 years CFI experience is required, If you do work in a Pt 141 school you may meet EITHER the requirements of 61.195(h)(2) OR 61.195(h)(3)(ii)

(7 year Part 141 instructor, 2 as Asst Chief Instructor, 2,600 hrs CFI time)

rickair7777

I doubt they could enforce that the way the regs are written. Flight training is only FAR flight training when it is used for aeronautical experience requirements. Extra training above the minimum required can be done by anyone, even a non-CFI.

But if they issued a letter, probably best to play it safe.

jedinein

I watched it happen. It was a great front row seat. The Feds were after the school so went after the CFI giving the training for exceeding the privileges of the CFI certificate and invalidated the training received by the CFI applicant. Further, there were two FAA Inspectors giving that CFI applicant his checkride when the guy managed to get training and a signoff from the senior instructor. I wouldn't wish that situation on anyone!