Posted 5 years 160 days ago ago by Randy Rowles
So you’ve provided all of the required training to your student. That’s it, they're ready to visit the FAA and apply for that sought after certificate or rating. However, there’s one last thing you have to do: You must certify to the federal government that as an authorized flight instructor you have provided the required ground and flight training, and found the applicant prepared to take the appropriate FAA practical test.
So what defines an authorized instructor? The Federal Aviation Regulations (FARs) define specific training requirements an instructor must meet to provide training for a certificate and/or rating. This definition is found within FAR 61.1: Applicability and Definitions. Most of the time, there is little confusion on this issue. However, over the last few years many regulatory changes and FAA Legal Interpretations are worthy of a closer look.
One such regulation that comes to mind is FAR 61.129(c)(3)(i). The FAA requires an applicant for a commercial pilot certificate with a helicopter class rating to receive at least five hours of instrument training, even though the certificate is limited to visual flight rules (VFR). The purpose of the training is simply to provide the pilot with the basic skills sets to survive an inadvertent IMC encounter. Since this certificate would be limited to VFR, does the instructor providing the instrument training need to hold an instrument rating on their flight instructor certificate? Absolutely yes! But don’t take my word for it; it’s in the regulations.
To verify the answer, you must refer to FAR 61.195: Flight instructor limitations and qualifications (c): Instrument rating. Here it clearly states that the flight instructor must hold an instrument rating on their flight instructor certificate to provide the instrument training toward a commercial pilot certificate. If the flight instructor meets this requirement, that instructor is now an authorized instructor to provide the instrument training for a commercial pilot applicant.
So you’re now the authorized instructor and permitted to provide the instrument training for a commercial pilot, however your applicant already holds a helicopter instrument rating. Does this rating supersede the requirement for the five hours of instrument training required for the commercial pilot certificate? In some cases the answer is: No!
According to FAA Legal Interpretations (Theriault-2010 and Hartzell-2010) if the instrument training was received prior to the student training toward a commercial pilot certificate, the time would not count. However, if the instrument training was received in conjunction (at the same time) with the student’s commercial pilot training and endorsed for training toward both FAR 61.129(c)(3)(i) commercial pilot and FAR 61.65(e) instrument rating requirements, then yes it may be counted. It’s crazy! I didn’t write it, but you need to know it. In this case you may be an authorized instructor, but the regulations define the path and timing of those elements that you are instructing. Make sure you know and follow the regulations or your student may have to do their training all over again. That would not be cool.
Finally, let’s deal with the statement: “I certify….” Last year, the FAA updated Advisory Circular (AC) 61-65E - Certification: Pilots and Flight and Ground Instructors/Change 1. There are several updates within this AC, but I want to draw your attention to endorsement No. 46: Prerequisites for Practical Tests. For years, FAR 61.39(a) was overlooked by instructors when endorsing applicants for FAA practical tests. It wasn’t included in the AC even though it was clear in the FARs. This is the big “I certify...” endorsement and shouldn’t be taken lightly. When you complete all of the required training with your student, you must make this endorsement in their logbook. Note that the AC refers to the instrument rating only, however this endorsement is required any time an authorized instructor is required.
So, what defines an authorized instructor? It’s the unique and time-honored privilege to write the words “I certify.”
About Randy: Randy Rowles has been a FAA pilot examiner for 20
years for all helicopter certificates and ratings. He holds a FAA Gold
Seal Flight Instructor Certificate, NAFI Master Flight Instructor
designation, and was the 2013 recipient of the HAI Flight Instructor of
the Year Award. Randy is currently Director of Training at Epic
Helicopters in Ft. Worth, Texas.