CFI Privileges and Limitations Regarding FTD’s

Can a flight instructor give dual instruction in a simulator, flight training device, AATD or BATD (collectively known as sim)?  Tribal knowledge would state that any flight instructor can teach and give dual instruction in any of those devices and per the regulations the student can apply those dual hours to the requirements of the certificate or rating that they seek.

The question came up about whether a CFI with only an instrument rating on their flight instructor certificate can teach and give dual instruction to instrument students in the sim.  Well, to answer that question we take a look at what the flight instructors privileges and limitation are in §61.195

§ 61.195   Flight instructor limitations and qualifications.
A person who holds a flight instructor certificate is subject to the following limitations:

• (A)  Hours of training. In any 24-consecutive-hour period, a flight instructor may not conduct more than 8 hours of flight training.
• (B)  Aircraft Ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:
         (1)   A pilot certificate and flight instructor certificate with the applicable category and class rating; and
         (2)   If appropriate, a type rating.
• (C) Instrument Rating. A flight instructor who provides instrument training for the issuance of an instrument rating, a type rating not limited to VFR, or the instrument training required for commercial pilot and airline transport pilot certificates must hold an instrument rating on his or her pilot certificate and flight instructor certificate that is appropriate to the category and class of aircraft used for the training provided.

Unfortunately, there is nothing in this regulation that states the instructor can teach in the simulator or whether or not an instrument only flight instructor can teach in the sim.  I have highlighted some of the quote in BLUE.  These blue word are important as it tells the flight instructor they must have an applicable category and class rating on their flight instructor certificate in the aircraft they are going to give dual instruction in.  What is the definition of aircraft in the FARs?

From FAR §1.1

Aircraft means a device that is used or intended to be used for flight in the air.

It becomes apparent that the regulation makes no mention of what a flight instructor can do in the sim.  Those phrases in RED above are highlighted to show that a flight instructor must have an instrument rating on their pilot and flight instructor certificates to teach instrument maneuvers to instrument and commercial students.

Let’s get back to the question.  The question is whether a flight instructor with only an instrument rating (no airplane single engine, airplane multiengine, etc…) can teach and give dual instruction in the sim.  At this point, the only option we are left with is to search for legal interpretations make by the administrative law judges for the FAA.

Fortunately for us, the FAA recently answered this exact question.  In the Beard Interpretation, the FAA has clarified that a flight instructor with only an instrument rating cannot give dual instruction in an aircraft or a sim.  In essence, without an appropriate category and class rating on their flight instructor certificate, they cannot do anything with that piece of plastic.

I would imagine the FAA will revise §61.195 to include specific criteria for sims in a future revision.

Preparation for your Practical Test

Flight Instructors do a very good job teaching their students the intricacies of flight and good aeronautical decision making.  These instructors spend countless hours analyzing how well their students are performing both in their knowledge of aviation and ability to perform with the practical standards.  Only when the instructor feels the student is ready and all aeronautical experience requirements are met, will he allow them to apply for the practical test to earn their new privilege.

One of the keys to this preparation is the Practical Test Standards.  If you haven’t seen this document yet while going through the preparation for the practical test, you need to take a look at it.  This really is the cheat sheet on what the examiner is required to test on; everything from your aviation knowledge, to ability to fly the airplane, to other special areas of emphasis.

How many of the instructors have gone through the front sections of the PTS to show them what it means when a maneuver is acceptable to the examiner or when the examiner is forced to issue a notice of disapproval.

When I was going through my training back in the day, I wasn’t told about the boundaries the examiner has to stay within.  I was under the impression, they could pass or fail a student for anything they wanted.  I was on both the good end and the bad end of that.  Thinking back, there were some maneuvers that I completed that were well within the PTS standards and the examiner failed me while some were not and he didn’t say anything.  If I knew now back then, I would have had a leg to stand on when I disagreed with his decision.

Let’s take a look inside the PTS book to see what it says.  In the Introduction section, one of the very first things it says is that “Adherence to the provisions of the regulations and the practical test standards is mandatory for the evaluation of private pilot applicants.  On page six of the introduction, under the heading Use of the PTS tells the applicant they are required to be evaluated in ALL areas of the PTS, unless otherwise noted (the only PTS that allows this is the CFI PTS… that I know of). 

Page nine lists the responsibilities of the flight instructor.  If your instructor cannot give you the experience and aeronautical knowledge necessary in all areas of the PTS, it is time for a new instructor.  They are required to emphasize your performance in effective visual scanning, collision avoidance procedures, manufacturers procedures and special emphasis areas. 

Page ten lists the examiner responsibility during the practical test.  They are required to determine if the applicant meets the acceptable standards of knowledge and skill of each task with in the PTS.  If something goes wrong, the examiner may require the applicant to repeat the task in the interest of fairness although the examiner has the option to not allow a repeat of a task.

The heart of this blog is the next two sections. 

Satisfactory performance is defined by five things.

1. Perform the Tasks specified in the Areas of Operation for the certificate or rating sought within the approved standards
2. Demonstrate mastery of the aircraft by performing each Task successfully
3. Demonstrate satisfactory proficiency and competency within the approved standards
4. Demonstrate sound judgment and exercises aeronautical decision making / risk management
5. Demonstrate single pilot competence if the aircraft is type certificated for single pilot operations.

Unsatisfactory Performance is defined as these four things

1. Any action or lack of action by the applicant that requires corrective intervention by the examiner to maintain safe flight
2. Failure to use proper and effective visual scanning techniques to clear the area before and while performing maneuvers
3. Consistently exceeding tolerances stated in the objectives
4. Failure to take prompt corrective action when tolerances are exceeded

I really like number three and four.  In the many practical tests that I have taken apart in, the examiners expect nerves to play a part in the applicant exceeding the tolerances.  If the applicant exceeds them once and promptly corrects, it is not a failure.  If it happens twice, probably not.  Three times and you are starting to show consistent behavior to fly outside the standards and that would be unsatisfactory.  Lets take steep turns as an example, you roll into a 45 degree bank and forget to pull back on the yoke, you descend fairly quickly 150 feet below your assigned altitude.  If you stay there, it is a bust; but if you promptly correct and get back within standards it is OK.  If it happens again, well you are starting to show consistency. 

I’ve talked to many pilots who were stressed out over wondering what is acceptable or not to the examiner and what happens if they get outside of standards only once.  The answer is nothing.  The examiner will most likely pass you.  The criteria used is consistency and a lack of prompt corrective action.  The other good thing about the introduction to the PTS it clearly states that the tolerances are established for a good flying day.  If there is a lot of turbulence, you won’t be held to the same standard as when the air is calm.

Hopefully this takes some of the pressure of making yourself perform at your best.  That pressure may make you fly worse than before.  My advice, relax you know what to expect from the examiner and treat them like your very first passenger.

Calculating the Headwind and Crosswind Component

Is there an easy way to calculate the headwind and crosswind component while in the airplane?  What about confirming the planned winds (you did do a flight plan right?)  Is it possible to come close to get this information correct in the airplane?

Absolutely, there is a way to quickly get these numbers using simple math.  For this method, it is important to memorize a couple numbers associated with the 0°, 30°, 45°, 60° and 90° angles.  The other angles can be converted to the closest values.  This will typically yield a very small error for wind speeds below 20 knots or so.  I also remember the power of 60 rule.  This rule states that for every 60 knots of airspeed, the wind speed decreases by 1/2, then 1/3, 1/4, 1/5 etc.  For example, if your true airspeed is 60 knots, there is a direct one to one relationship between the crosswind angle and the crosswind speed.  As the airplane accelerates to 120 knots, there is a one to 1/2 relationship and for every 2 knots of crosswind there is a one degree of crosswind correction.  At 180 knots, a one to 1/3 relationship and so on.  This also works for speeds less than 60 knots but the crosswind correction is opposite.  For a 30 knots true airspeed, there is a one-to-two relationship and at 15 knots (can we fly this slow?) a one-to-three relationship.

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A little example, let’s say you are traveling on a 090° true heading with a true airspeed of 120 knots.  There is a wind coming from 120° at 20 knots.  What is our headwind and crosswind components and crosswind correction?  The headwind component from the chart up there is .9 * 20 or ~18 knot headwind making the groundspeed around 102 knots.  The crosswind component is .5 * 20  or 10 knots.  According to power of 60 rule will will divide the speed by two to get a 5 degree correction to the right.  Thus the true course is 095° cruising at 102 knots.

Notice, it isn’t quite exact but it is definitely close enough for calculations in the cockpit.  One more example, you are cruising at 14,000 feet at 180 knots on a 210°  true heading.  There is a wind outside at 150° at 24 knots.  The same kind of analysis of what the headwind, crosswind and crosswind correction is.  The wind is at 60°  off the left side so we can see that the headwind is 12 knots making the groundspeed 168 knots.  The crosswind component is .9 * 24 ~ 21 knots.  If we take power of 60 rule we will divide that 21 by three and get a 9°  crosswind correction.  Thus our groundspeed is 168 knots and our true course is 201°.  Again, it is not perfect but it will definitely get in into the ballpark.

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What if want to work the numbers a little bit differently and get the wind speed and direction from the other four values.  All we need to do is to work the numbers  backwards.  Let’s say your planned course is 310° with a planned TAS of 90 knots.  We are currently flying a heading of 300° with an actual groundspeed of 80 knots.  What is the wind speed and direction?

Start off by determining the crab angle.  In this case it is 10°.   Applying the power of sixty rule we can see that 90 knots is half way between 60 and 120 so the ratio is 1 to 1.5.  Multiply 10° by 1.5 to get 15 knots of wind.  At this point, find a ratio between 10 knots and 15 knots for the wind angle.  In this case it is around 50°.  Since the heading is lower than the course the wind must be coming from the left so we will subtract 50° from our course of 310° to get a wind of 260° at 15 knots.

Again, the formula isn’t perfect but it is much fairly accurate to confirm whether or not a wind shift has occurred.  We all know that a wind shift indicates that we passed a front so knowledge of wind shifts provide other really important information.

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OK, so why don’t we try some examples:    My answers I got using the formulas are below as well as the mathematically correct answer.

1.

2.

3.

4.

5.

6.

My Answer	Mathematically Correct Answer
1. TH = 50° and GS = 109 knots	TH = 50° and GS = 109 knots
2. TH = 124° and GS = 202 knots  (Tailwind)	TH = 127° and GS = 191 knots
3. TH = 130° and GS = 100 knots (direct Tailwind)	TH = 130° and GS = 100 knots
4. TH = 148° and GS = 134 knots	TH = 148° and GS = 135 knots
5. WD = 060° and WS = 10 knots	WD = 050° and WS = 18 knots
6. WD = 310° and WS = 5 knots	WD = 302° and WS = 7 knots

Like I said, it’s not perfect but it gets us in the ball park and that is what is important.  For a more accurate method pull out the E-6B and do the calculation.  Remember, aircraft control is #1 though.