I need a little guidance on what instruction an AGI & IGI (but not CFI) can give and sign off in a full-motion AATD under Pt 61 & 91. Regs are pretty clear regarding Pt 135 & 121, but full motion sims (such as Redbird FMX) are relatively new to GA so it isn't clearly spelled out. Any ideas?

 

The privileges of a Ground Instructor are spelled out in part 61.215
§ 61.215 Ground instructor privileges.

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(a) A person who holds a basic ground instructor rating is authorized to
blah blah blah does not apply to the question.
(b) A person who holds an advanced ground instructor rating is authorized to provide:
(1) Ground training on the aeronautical knowledge areas required for the issuance of any certificate or rating under this part except for the aeronautical knowledge areas required for an instrument rating.
So he can give ground school for a written except the Inst.
(2) The ground training required for any flight review except for the training required for an instrument rating.
He can give the 2 hours of ground training for a flight review.
(3) A recommendation for a knowledge test required for the issuance of any certificate or rating under this part except for an instrument rating.
He can sign you off for any part 61 written except the Inst.
(c) A person who holds an instrument ground instructor rating is authorized to provide:
(1) Ground training in the aeronautical knowledge areas required for the issuance of an instrument rating under this part;
He can give the ground school for the Inst written.
(2) Ground training required for an instrument proficiency check;
Well great except when you look in 61.57 under IPC there's no requirement for any ground training.
(3) A recommendation for a knowledge test required for the issuance of an instrument rating under this part.
And he can sign you off for Inst written.

So that's what an AGI/IGI can do. They teach and sign off ground school.

 

Actually it's a little more complicated than that, although part 61 is not crystal clear on how it is spelled out...

61.65 (e) is one example of where sim time is allowed to be used for a rating (IR). It requires that the training be performed by an "Authorized Instructor".

61.1 (2) Defines "Authorized Instructor" as someone conducting ground training in accordance with the privileges of his GI cert.

61.215 Allows a GI to conduct "ground training"

61.1 (b)(6) Defines "Flight Training" as training conducted in an "Aircraft".

1.1 Defines "Aircraft" as device used for flight in the air.

61.1 (b)(8) Defines "Ground Training" as training OTHER THAN FLIGHT TRAINING conducted by an authorized instructor.

So while it doesn't come out say it, by applying all of the above definitions we can conclude that:

1) A simulator is clearly NOT flight training.
2) Therefor it MUST be ground training
3) Therefor a GI should be able to provide sim training

I have seen a IGI's give loggable sim instructor at a large school, although I have never done it myself.

 

Thanks for the replies. We're running it past FAA and I'll post their opinion soon as it comes down.

 

It's already come down. A ground instructor cannot give instruction in a simulator or other flight training device..

http://www.faa.gov/about/office_org/...010/Gatlin.pdf

 

Rick,

61.1(2) allows ground instruction "in accordance with the privileges and limitations" on the GI cert. Section 215 lists those priviledges, "ground training for the knowledge test."

We were through this a few months back on PPRUNE so I'll just cut and paste.

"I got my GI certs under Part 143. In the late 1990s there was a major rewrite of 61 and GI stuff was moved there and 143 went away. One of the things in the NPRM is:

"Section 61.223 Ground Instructor Endorsements and Authorizations

So now if we break down 61.215:

c) A person who holds an instrument ground instructor rating is authorized to provide:

(1) Ground training in the aeronautical knowledge areas required for the issuance of an instrument rating under this part;

Aeronautical knowledge is FAA speak for the written test so an IGI can run a ground school class.

(2) Ground training required for an instrument proficiency check; and

Ok, that's great but when you look up a IPC, there's no requirement for any ground training!

(3) A recommendation for a knowledge test required for the issuance of an instrument rating under this part.

Sign, date and put your cert number on the dotted line.

But nothing about any flight proficiency training. So I'd say to the OP, they could but not for the last 10 years or so."

The Ms. Ruth comment is because someone had posted a Chief Counsel letter from 1980 where the old 61.65 did allow an IGI to give sim training.

 

I have only done it in the 121 and 142 worlds. The training dept/center lists you as an instructor and you are one. Doesn't matter if you have a CFI/IGI or not. 141 does require a CFI for flight training except for Lighter than Air. May well be a case where one part of the regs has not kept pace with another.

 

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.

 

I always get impaled on these legal questions. I don't get in on them like I should, but they are all valid questions. As my old air force mentor used to say, a pilot is one part lawyer.

 

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.