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Military Competency CFI-H to MEI Add-On

Old 11-10-2016, 08:35 PM
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Default Military Competency CFI-H to MEI Add-On

Hey everyone,

I am in a bit of a conundrum at the moment. I currently possess a helicopter CFI/CFII certificate that I received from the FAA through military competency (§61.73(g)). Given that it was my initial flight instructor certificate, all FAR Part 61 regulations governing 'additional flight instructor category/class ratings' would be applicable.

And here within lies the dilemma: I am supposed to take a checkride for the MEI 'add-on' to my instructor certificate this month, but because I do not possess logbook endorsements for my initial CFI (again, my initial was through mil comp), my DPE wants to see all the initial endorsements written up as though my MEI were my 'initial.' Moreover, to complicate matters, he wants my 'initial CFI endorsement' from a 2-year CFI (§61.195(h)) -- though this is not an initial since I already possess a CFI/CFII and my current instructor has had his CFI for less than 3 months. I'd switch to a different MEI to simplify matters for the checkride, except there aren't any 24-month or greater MEIs at my school.

My DPE insisted that this is a gray area and to get all the endorsements "just to be safe," but my gut instinct is that I'm fine. He wasn't entirely sure on whether I needed the endorsements, other local DPEs, and the FSDO do not have an answer as of yet either.

What am I missing here? Shouldn't I be fine to receive all required endorsements for a category & class CFI add-on rating without possessing 'initial' endorsements since I possess a helicopter CFI/CFII earned from military competency? I'm looking for a reference to clarify this once and for all.

V
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Old 11-10-2016, 08:47 PM
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I agree with you but that doesn't mean much! Find another examiner!
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Old 11-11-2016, 04:18 AM
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I feel like this should be a non-issue since the only endorsements that should apply are endorsements for the added category to the CFI certificate, but how I feel and how the FSDO wants things done are a losing battle unless there's something in black and white I can present.
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Old 11-11-2016, 05:41 AM
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Can you find an Army buddy with a CFI-H? Their logic appears flawed! For instance, folks come out of the fixed wing side with a mil comp for commercial instrument airplane single and multi -engine land with a type rating and never received a complex, high performance, spin or pressurized endorsement in their personal logbook and get an ATP and fly for the airlines! Perhaps the airline specific training records cover them for the airline only and they need logbook endorsements if the were to fly under Part 91 (ie: personal airplane)? To me, the fact that you hold the certificate tells me someone at the FAA has reviewed your military records and found you satisfying the regs to get the CFI-H! Perhaps they interpret it that your CFI-H may work if you were a check airman or Instructor at a 135 helicopter operation but if you want to fly part 91 or teach under 61 or 141 you need the endorsements?????

I agree more signatures and endorsements in the log book won't hurt! I guess worse case, there is a starving CFI-H pilot out there you can hire to get the endorsements. You may have to go up in a Bell 47 or R22 and spend a few bucks but it may be worth it! I believe the FAA has an ask a question website, where legal in D.C. interprets your question and posts their opinion on the FAA website. You can also join AOPA and they have a brilliant staff to answer questions as well!

Curious, Why are you going for an MEI first instead of the CFI single?

Last edited by 155mm; 11-11-2016 at 06:17 AM.
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Old 11-11-2016, 12:36 PM
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Originally Posted by Voski View Post
Hey everyone,

I am in a bit of a conundrum at the moment. I currently possess a helicopter CFI/CFII certificate that I received from the FAA through military competency (§61.73(g)). Given that it was my initial flight instructor certificate, all FAR Part 61 regulations governing 'additional flight instructor category/class ratings' would be applicable.

And here within lies the dilemma: I am supposed to take a checkride for the MEI 'add-on' to my instructor certificate this month, but because I do not possess logbook endorsements for my initial CFI (again, my initial was through mil comp), my DPE wants to see all the initial endorsements written up as though my MEI were my 'initial.' Moreover, to complicate matters, he wants my 'initial CFI endorsement' from a 2-year CFI (§61.195(h)) -- though this is not an initial since I already possess a CFI/CFII and my current instructor has had his CFI for less than 3 months. I'd switch to a different MEI to simplify matters for the checkride, except there aren't any 24-month or greater MEIs at my school.

My DPE insisted that this is a gray area and to get all the endorsements "just to be safe," but my gut instinct is that I'm fine. He wasn't entirely sure on whether I needed the endorsements, other local DPEs, and the FSDO do not have an answer as of yet either.

What am I missing here? Shouldn't I be fine to receive all required endorsements for a category & class CFI add-on rating without possessing 'initial' endorsements since I possess a helicopter CFI/CFII earned from military competency? I'm looking for a reference to clarify this once and for all.

V
This makes no sense. You should call the FSDO and explain to them the problem specifically. They are not about making you jump through ridiculous hoops that don't exist, and if they do for some odd reason, you keep going to a higher level (managers, etc.). This is an added rating to your CFI certificate. There is no reason to see other endorsements. I have conducted an MEI added rating checkride recently and one of the areas either required or that I selected was logbook endorsements, as it's important for an MEI to know what you have to do to train and prepare a student for an initial certificate or added rating checkride in a multi engine aircraft, but that's completely separate from the issue of what you need to take the checkride. An added rating MEI is pretty minimal in this regard. The only reason I mentioned the checkride items is some examiners like to combine the endorsements in your logbook with the practical test, but they shouldn't be requiring this of you.

So the answer is found by looking at the regulations.

61.195(h) has nothing to do with this. That is for a flight instructor training a flight instructor. That has nothing to do with you taking a checkride. All an examiner should be doing is verifying that your endorsements and eligibility is good to go. If we were to "investigate" all of the training of every applicant, undoubtedly we'd find "some stuff" from time to time, but it's a ridiculous waste of time and it's not the role of an examiner. Besides, 61.195(h) is talking about an "initial flight instructor applicant", which you are not. It is therefore irrelevant.

This is the path an examiner should be going down:

61.191 is what covers additional CFI ratings. It says to go to 61.183.

61.183 says that you need to receive an FOI endorsement, stating that you've been instructed on the areas of 61.185, but if you got to 61.185:

§61.185 Aeronautical knowledge.

(a) A person who is applying for a flight instructor certificate must receive and log ground training from an authorized instructor on:

(1) Except as provided in paragraph (b) of this section, the fundamentals of instructing, including:

(i) The learning process;

(ii) Elements of effective teaching;

(iii) Student evaluation and testing;

(iv) Course development;

(v) Lesson planning; and

(vi) Classroom training techniques.

(2) The aeronautical knowledge areas for a recreational, private, and commercial pilot certificate applicable to the aircraft category for which flight instructor privileges are sought; and

(3) The aeronautical knowledge areas for the instrument rating applicable to the category for which instrument flight instructor privileges are sought.

(b) The following applicants do not need to comply with paragraph (a)(1) of this section:

(1) The holder of a flight instructor certificate
or ground instructor certificate issued under this part;

(2) The holder of a current teacher's certificate issued by a State, county, city, or municipality that authorizes the person to teach at an educational level of the 7th grade or higher; or

(3) A person employed as a teacher at an accredited college or university.


Some of the other stuff in 61.183 does apply of course, like getting an endorsement on the areas of operation in 61.187(b). There is no written though, so that part does not apply. This is not rocket surgery, it's out there for anyone to see. This DPE needs his head examined, most likely he has never encountered a Mil-Comp pilot before.

Lastly, you are getting an MEI, it is up to you to know and be able to figure out the regulations. You should be able to make a clear case to the FSDO and examiner that is rock-solid. When you know you are right, you don't back down, but this depends upon your knowledge of the regulations. As an MEI, you should have that knowledge. The little "got-chas" I see from time to time are things like not logging flight AND ground training, forgetting endorsements for practical tests (3hrs of training in last 2 months), not actually providing the training required by the applicable regulation (like 61.187(b)), but those are all legitimate paths to go down, because those are the regulatory requirements. What this DPE is doing, is not legitimate.

Get the email of the person you are working with at the FSDO, break this down by regulation and send it to them. If you are not working with someone, call a manager and ask who you can work with.

Hope this helps.

Last edited by JamesNoBrakes; 11-11-2016 at 12:56 PM.
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