No Dumb Questions

Q. I just completed my study and passed checkrides for both a CFI and CFII under the new Part 61 regulations. I agree that Federal Aviation Regulation 61.51(e)(1)(i) and FAR 61.51(g)(1)(i) allow instrument students to log pilot-in-command (PIC) instrument time when they fly with an instrument instructor. And I agree the regulations require instrument rating applicants to receive at least 15 hours of instrument flight training from an "authorized instructor" (a CFII) and that applicants can log the remaining 40 hours of instrument flight training with a CFI or safety pilot.

But, FAR 61.195(c), "Flight Instructor Limitations and Qualifications," seems to say that only CFIIs give instrument training - even in VFR conditions! The regulations appear to allow instrument rating applicants to fly with a safety pilot for the remaining 25 hours of instrument time - but not a CFI. I guess a CFI could act as only a safety pilot, but not as an authorized instructor. Is that really what the FAA intended?

John Loignon, CFI, CFII
via the Internet

A. No. The federal aviation regulations are like a maze, and to make sense of them you have to take them one step at a time. The steps here are the different types of flight time FAR 61.65 requires. First, it requires applicants to have at least 40 hours of "actual or simulated instrument flight [time]" (emphasis added). These 40 hours must include "At least 15 hours of instrument flight training [time] from an authorized instructor in the aircraft category for which the instrument rating is sought" (emphasis added).

FAR 1.1 defines "flight time" as "Pilot time that commences when the aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing." Pilots can log flight time when they fly with anyone (if they meet the currency requirements, of course). When they fly with a CFI or qualified safety pilot, instrument rating applicants can log actual or simulated "instrument flight time" only. Instrument flight time doesn't count as instrument flight training time.

FAR 61.1(b)(6) defines "flight training [time]" as "?training, other than ground training, received from an authorized instructor in flight in an aircraft." Instrument rating applicants can log the required instrument flight training time only with an authorized instructor - the CFII. Instrument flight training time also counts as instrument flight time.

Finally, FAR 61.195(c) itemizes the qualifications for instrument instructors who can train applicants for an instrument rating - or a type rating for an aircraft "not limited to VFR." In other words, if a pilot is training for a type rating in an aircraft that's approved for instrument flight, such as a Learjet, for example, that pilot must receive the instrument training required to earn a Learjet type rating from a CFII who has a Learjet type rating.