Thanks for the info. Was not aware that a rule change had taken place. In any case, I still find the wording of the regulation ambiguous and in the letter above the FAA counsel admits that the new reg is inconsistent with other FAA publications. As far as the PTS reads, A CFI-I can still be done as the initial, but according to the new reg you wouldn't be able to use it without a CFI-ASEL or CFI-AMEL on your certificate. I don't flight instruct anymore, so it doesn't effect me, but I sure feel sorry for the poor guy who gets pinched by the FAA's inconsistencies. What a bunch of Bozo's.

 

Thanks for pointing that out, although the FAA does not have a legal leg to stand on with this...FAR 61 still appears to allow this, and FAA order 8900.1 (FSIMS) clearly and explicitly says it is OK.

They cannot hold people responsible for fantasy rules which exist only in their own mind, there is no reasonable requirement that every time we want to do something authorized by the regs that we have to go look for FAA interpretations which contradict the regs.

Maybe someday they will all of their ducks in a row.

 

Part 61 doesn't allow it. The most recent change to 61.195 states the following

As such, possessing nothing but a CFII is all but worthless now. You can do ground training and simulator/FTD training. Otherwise, you will have to have at either CFI-ASE or CFI-AME on your flight instructor certificate, as well as the appropriate pilot certificate.

 

Whether one agrees with the result or not, I'm not sure how an interpretation that says that in order to teach in an aircraft you have to have a pilot certificate and instructor certificate with appropriate category and class ratings "contradicts" a reg that says that in order to teach in an aircraft you have to have a pilot certificate and instructor certificate with appropriate category and class ratings (which is exactly what (b) has said for a long time). The CFII issue has always been a matter of interpretation and reconciliation of the language in (b) with the language in (c).

Even before the reg change.

FSIMS is a different issue and, of course, it's not a reg but a "guidance" that is for the purpose of Flight Standards standardization. It changes on the whim of the Flight Standards department. In case of a conflict with the regs, the regs (and as a by product, the Chief Counsel's interpretation of the regs) take precedence.

Although... even 6 months after the reg change, FSIMS has not been amended to reflect the "new" rules. One has to wonder whether the internal battle about this issue continues.

 

Actually I'm OK with the new requirement, even if they just pulled it out of their butts. I don't see it being a big deal either way safety wise...although I suppose it might be nice to have an MEI on board if the student tries to get too slow on a SE approach.

But I don't think the FAA could enforce this until they get the word out...they need to do a new AC and of course get their flight standards people on board.

 

I think you're right about that.

In fact there was an enforcement action brought against an instructor a few years ago involving this issue. From correspondence with the CFI involved, it's my understanding that it was dropped in part because of the conflict in the publicly available FAA documents on the subject.

 

So I'm pretty sure you guys already answered this but just want to double check before filling out my logbook.
We get a multi at our school which model I have 0 time in, I can go up with the chief CFI who isn't an MEI (I am) and I can log it as dual given for the sake of both of us getting familiar with the plane, and then after that 5 hours then we can do training for his MEI, right?