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Instrument Instruction Required for the Commercial Helicopter Pilot Certificateby Randy Rowles


Can the Instrument Instruction required for the Commercial Pilot Helicopter certificate by given by a CFI that DOES NOT hold an Instrument Rating on their CFI certificate?

This is considered a hot and sensitive subject. The first place that I will direct you is to FAR 61.195 (c) where it states , “A flight instructor who provides instrument flight training for the issuance of an instrument rating or a type rating not limited to VFR must hold an instrument rating on his or her flight instructor certificate and pilot certificate that is appropriate to the category and class of aircraft in which instrument training is being provided.”

This would indicate that since the Commercial Pilot certificate is limited to VFR unless an Instrument Rating is added to it , that a CFI could provide such training. Of course the training would not be valid for credit toward the Instrument Training requirements of the Instrument Rating is so desired at a later date by the certificate holder.

Before we make our decision , we should really look further at the other terminology used in 61.129 (c)(3)(i) where it states “10 hours of instrument training in an aircraft.” So to accurately answer this question , we must define Instrument Training. To do this , lets take a look at FAR 61.1 (b)(10) which states “ Instrument training means that time in which instrument training is received from an authorized instructor under actual or simulated instrument conditions.”

To accurately credit any training received for a specific subject matter of task , the FAA uses the term Authorized Instructor. For us to define this term we again look at

FAR 61.1 (b)(2)(ii) which states “A person who holds a current flight instructor certificate issued under Part 61 of this chapter when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate.”

The Privileges and Limitations can be found in FAR 61.193 & .195. After reviewing all of the information with regard to your question , it would seem that a CFI without an Instrument Rating is authorized to provide the Instrument Training as described in 61.129.

BUT , we must look further…..

Now we turn to the FAA and their view on this matter. After reviewing all available information on this subject , I decided to go to the most dependable site on the web. The Frequently Asked Questions (FAQs) of Part 61 at the FAAs website is quite helpful when researching difficult subjects. This site can be found at:


On page 269 of the FAQs , I found this question to Mr. John Lynch. Mr. Lynch works for the FAA at the GENERAL AVIATION CERTIFICATION BRANCH , AFS-840 in Washington D.C. He maintains the FAQ site and answers question with regard to Part 61 and 141.

The following is taken from the FAQs:

QUESTION: §61.129(c)(3)(i) is the rule that requires instrument training for a commercial pilot certificate with a helicopter rating and the rule states “10 hours of instrument training in an aircraft” Does this instrument training have to be given by a CFII?

ANSWER: Yes and the CFII must be for the category and class of aircraft that the training is being given in. For example , if the training is being given in an airplane , then the CFII would have to hold an instrument-airplane rating on his or her flight instructor. If the training is being given in a helicopter , then the CFII would have to hold an instrument-helicopter rating on his or her flight instructor certificate.

Although it would appear that the FARs differ from this opinion , the FAA regards Instrument Training as training conducted by a CFII in all cases.

Posted in: Regulatory


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