When is a CFII required to provide instrument training?

Question

61.195(c) states:

(c)Instrument rating. A flight instructor may conduct 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 if the following requirements are met:

(1) Except as provided in paragraph (c)(2) of this section, the flight instructor must hold an instrument rating appropriate to the aircraft used for the instrument training on his or her flight instructor certificate, [...]

So as a CFI with a current instrument rating (but not yet a CFII) it appears I can provide instrument training to students working toward their Instrument Rating. I'm trying to find what limitations to this there are - what regs state when training must be from a CFII?

61.65 - Instrument rating requirements (d)(2) states:

(2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, [...]

Throughout 61.65 it consistently states only "authorized instructor" but there is no definition for "authorized instructor" except only as in 61.1(b) which reads:

Authorized instructor means— (i) A person who holds a ground instructor certificate issued under part 61 of this chapter and is in compliance with §61.217, when conducting ground training in accordance with the privileges and limitations of his or her ground instructor certificate; (ii) A person who holds a flight instructor certificate issued under part 61 of this chapter and is in compliance with §61.197, when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate; or [...]

61.197 is only Renewal requirements for flight instructor certification. So by all this, it seems to me that as a CFI with an instrument rating I'm authorized to provide instrument training. There's definitely something missing here and after hours of digging through regs I just can't find any clearer definitions on this. Can anyone help provide some guidance on where it's defined as to when a CFII is required? Thanks in advance.

Answer 1

No, you cannot provide

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

Unless you hold

(1) Except as provided in paragraph (c)(2) of this section, the flight instructor must hold an instrument rating appropriate to the aircraft used for the instrument training on his or her flight instructor certificate,

Having an instrument rating on your CFI makes you a CFII.

You are confusing a CFII, who is a CFI with an instrument rating on his / her flight instructor certificate, with

someone that has an instrument rating on his / her pilot certificate and who also might hold their CFI.

You must be a CFII to give instrument training, the exception to that would be for private pilot candidates from 61.109

(3) 3 hours of flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments, including straight and level flight, constant airspeed climbs and descents, turns to a heading, recovery from unusual flight attitudes, radio communications, and the use of navigation systems/facilities and radar services appropriate to instrument flight;

a CFI is able to give those 3 hours of instruction. Anything beyond private pilot is the realm of the CFII.

Answer 2

Of the 40 hours required of actual or simulated instrument flight by the instrument student only 15 are required to be with a CFII. See regs published in the question.

Answer 3

The exception to the previous answer would be in the case of someone who is trying to get their Commercial Helicopter rating. The wording for 61.129(c)(3)(i) is as follows:

Five hours on the control and maneuvering of a helicopter solely by reference to instruments using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems. This aeronautical experience may be performed in an aircraft, full flight simulator, flight training device, or an aviation training device;

This leaves this training open to being completed by a CFI, and not requiring a CFII.

Answer 4

As a CFI ie holding a Flight Instructor Certificate with an appropriate category and class rating, you are authorized to provide flight instruction ‘on the control and maneuvering of an aircraft solely by reference to instruments’ (see 61.195(l)). This means for all dual instrument flight training time going towards either a Sport, Recreational, Private, or Commercial, Pilot Certificate that is not associated with 61.195(3)(c), may be given by a CFI.

Dual instruction flight time specifically required for an instrument rating on either a pilot or flight instructor certificate, for a type rating not solely limited to VFR operations, and an instrument proficiency check, must be conducted by an instructor who holds an instrument rating on their flight instructor certificate, a CFII.

I suspect the primary motivation for doing this by the FAA is because initial flight instruction training only really covers and checks a persons ability to provide primary flight training and said applicant has not yet demonstrated the ability to competently teach instrument instruction to a student pilot. Given the added complexities of instrument flight, the FAA requires this in order to instruct new instrument students.