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Old 10-29-2010 | 07:58 AM
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Originally Posted by BeenThere
http://www.faa.gov/about/office_org/...010/Gatlin.pdf

So there we have it. I've also talked to the HNL FSDO, their opinion is that if you are authorized by the Chief Flight Instructor you can in fact conduct sim training under 61 & 141, just like 135 & 121 ops.
Bad Link...
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Old 10-29-2010 | 08:16 AM
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It looks to also be the Gatlin letter that NGDI posted earlier.
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Old 10-29-2010 | 01:39 PM
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Originally Posted by BeenThere
So there we have it. I've also talked to the HNL FSDO, their opinion is that if you are authorized by the Chief Flight Instructor you can in fact conduct sim training under 61 & 141, just like 135 & 121 ops.
The letter posted above by NoyGonnaDoIt is an FAA headquarters legal opinion which was written last month. It says that you CANNOT act as a sim instructor under part 61 with a GI cert.

This opinion itself is reasonable, but their logic in arriving there looks weak. It's basically "This is the way I want it to be, it doesn't matter what the regs say". I'm guessing they won't try to go back and violate anybody who has done this in the past.
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Old 10-29-2010 | 03:42 PM
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We about beat this to death but I'd say the Chief Counsel's letter is straight forward:
1. Here is a list of what GIs can do.
2. Instructing in a sim is not on the list.
3. Therefore, a GI can not instruct in a sim.
That Philosophy of Logic class finally paid off.
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Old 10-29-2010 | 06:10 PM
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A pilots license is not required to posses a GI certificate. Do you really think that someone without a pilots license is qualified to teach someone to fly. I don't care if it's a FTD or a TURD. 'm not buying it. A ground instructor is just that....a ground instructor. They can provide the required training to be signed off for taking a written test. Thats it.
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Old 10-30-2010 | 04:05 AM
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Originally Posted by rickair7777
OK, looks like the FAA changed (or clarified) their position last month.

It was always a bit sketchy but IMO you could make a clear legal trail through the regs to reach the conclusion that it was authorized. That was probably never intended by the FAA, but probably just happened that way.
Some of the instructor privilege issues seem to have always been a bit sketchy with differing interpretations of the same reg - some of them being different depending on which part of the FAA you asked.

Just a sampling of those that have had support for varying views but have finally been "clarified" by FAR changes, Chief Counsel interpretations or both in recent years:
  • Ground instructor can't give loggable flight training in a device.
  • CFI-I with no aircraft instructor rating can't teach in any aircraft.
  • CFI-A without an Instrument-Airplane rating cannot provide instrument training beyond the "flight solely by reference to instruments" training for the private certificate.
  • Neither CFI nor trainee is a passenger, no neither needs to be landing-current.
  • CFI ride does not reset the FR clock.
  • CFIs may log trainee instrument approaches that occur in actual

Some parts of the FAA website are currently down but if you're interested, putting CFI or flight instructor in the search box at http://www.faa.gov/about/office_org/...terpretations/ should help you find all of them
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Old 10-30-2010 | 01:39 PM
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Originally Posted by NoyGonnaDoIt
[*]Ground instructor can't give loggable flight training in a device.
Makes sense.

Originally Posted by NoyGonnaDoIt
[*]CFI-I with no aircraft instructor rating can't teach in any aircraft.
Huh??? When did THAT happen? I trained several CFI initials back in the day...you're saying that they can no longer give flight instruction?[/quote]

Originally Posted by NoyGonnaDoIt
[*]CFI-A without an Instrument-Airplane rating cannot provide instrument training beyond the "flight solely by reference to instruments" training for the private certificate.
I always assumed that.

Originally Posted by NoyGonnaDoIt
[*]CFI ride does not reset the FR clock.
Kind of stupid, but if you pass the ride just ask for a FR endorsement!

Originally Posted by NoyGonnaDoIt
[*]CFIs may log trainee instrument approaches that occur in actual
Maybe not such a great idea...there's a difference between watchning and doing...might be a big difference for some people.
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Old 10-30-2010 | 01:41 PM
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Originally Posted by rdneckpilot
A pilots license is not required to posses a GI certificate. Do you really think that someone without a pilots license is qualified to teach someone to fly. I don't care if it's a FTD or a TURD. 'm not buying it. A ground instructor is just that....a ground instructor. They can provide the required training to be signed off for taking a written test. Thats it.
I have seen it done, essentially a BAI warm-up before the student goes to the airplane with a CFII. But I kind of agree it's not the best idea.
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Old 10-31-2010 | 06:05 AM
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Originally Posted by rickair7777
I have seen it done, essentially a BAI warm-up before the student goes to the airplane with a CFII. But I kind of agree it's not the best idea.
I'll let out some of the cynic I try to keep in check and say that it does not surprise me. I'm sure having a GI do that training is somehow cheaper than using a CFI. Just to save a buck.
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Old 10-31-2010 | 09:16 AM
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Originally Posted by rickair7777
Makes sense.

>>CFI-I with no aircraft instructor rating can't teach in any aircraft.

Huh??? When did THAT happen? I trained several CFI initials back in the day...you're saying that they can no longer give flight instruction?
It's been one of those issues where different arms of the FAA said different things. The reg was "clarified" as part of last October's major revision of Part 61 and the Chief Counsel opinion about it is here:
http://www.faa.gov/about/office_org/.../Grayson-2.pdf
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