CFI (Subpart K) to CFI (Subpart H)
Joined 03/14/2020 - 4 Posts
I hold a Commercial Pilot Rating with Instrument Airplane, Single Engine - Land.  Before Basic Med became law, I was concerned about my blood pressure making me have my Medical denied so I let it expire.  I took and passed the Fundamentals of Instructing written and Flight Instructor Airplane
(Sport Subpart K) written.  After meeting the aeronautical experience requirements and passing my practical test, I was in the air teaching a few Sport Students.  After two years, I did a CFI Refresher Clinic once and renewed the certificate.

For several years I didn't fly and my Sport CFI expired.  When Basic Med became law, I was eligible so I did that and got checked-out in the FBO's 172's.  I bought a PA-38 Tomahawk and have been doing Basic Med ever since.

Now I have a Daughter that wants to get her pilot's license in our Tomahawk.  I need to add-on my CFI Airplane SEL, Subpart H rating so I can teach her.  I DO plan to get a 2nd Class Medical since the FAA is much more reasonable now about a LOT of medical issues that were absolute NO's in years past.

Here's my questions !!
1)  I made 100 on the Fundamentals of Instructing when I got my Sport CFI.  I should not have to take it again, right?
2)  I KNOW I will have to take the CFI Subpart H written, but when I complete the FAA Form 8710-1,   
Do I put an "X" in the INSTRUCTOR Flight box?
Do I put an "X" in the INSTRUCTOR Ground box?
Do I put an "X" in the RATINGS ASE box?
Do I put an "X" in the RATINGS Land box?
Do I put an "X" in the RATINGS Basic box?
Do I put an "X" in the OTHER INFORMATION/REQUESTS Renewal box?
My belief is that upgrading from Subpart K to Subpart H CFI will be a Renewal and NOT an Initial CFI Rating, am I right?
If a renewal, I can do my checkride with a DPE.  If an initial, I will have to fly with a FAA examiner, right?

Bryan Cobb
6 Replies
Joined 06/11/2017 - 699 Posts
First, regarding your medical status, you do not need a Second Class medical either to take the CFI-A practical test or to train your daughter for PP-ASEL in that Tomahawk.  A Third Class would be sufficient.  Even Basic Med would be enough for all of that other than for her required 3 hours of instrument time since you'd be acting as a safety pilot during that portion of her training (which you could get another instructor to do),  That said, having taken my son through solo many years ago, but no farther, I'm not sure training your daughter is going to be good for the father-daughter relationship -- you might consider farming that out to another instructor you know in return for training their son/daughter.

Next, yes, you do NOT have to take the FoI written again.

As for the 8710-1, first of all, since you hold a CFI certificate, albeit expired, but without the rating desired, this is an "additional rating" test, not an initial or reinstatement.  However, per 61.199(a)(2) and 61.427, this additional rating ride reinstates your CFI certificate with an ASE rating (which supersedes the SP rating)..  As to the specific questions check the following boxes:
  1. Certificate: Instructor-Flight
  2. Ratings: ASE and Added Rating
  3. Other: Reinstatement
That said, when you fill out the 8710-1 via IACRA, just answer the questions IACRA asks and the form will fill itself in correctly.

In addition, CFI-Airplane ratings are only ASE or AME.  There is no land or sea class rating applied.  If you have the ASE, you can give training in either/both land/see based on whether you have land/sea ratings on on your Commercial/ATP pilot certificate.  So, even though I've never flown a seaplane in my life, I could go out an add an ASES rating at the CP level to my ATP-ASMEL with just a few hours of seaplane training and a splash-and-dash checkride, and immediately start training folks in seaplanes without doing anything extra to my existing CFI-ASME-IA ticket.  Legal, but probably not too smart.

As to who will do your ride, that's up to the FSDO, but as it's not an initial CFI ride, it will almost certainly be farmed out to a DPE.

See,Vol.5,Ch2,Sec11 for all the details.
Joined 03/14/2020 - 4 Posts
Thank You.
Joined 03/14/2020 - 4 Posts
Mr. Ronald.  In part of your answer you said taking a checkride for Subpart H CFI is a "renewal" of a previously held CFI Certificate.

Then you said later to check the "reinstatement" box in the "Other Information/Request" section.
I think you meant to tell me to check the "renewal" box there?

Some DPE's feel like a Sport CFI Certificate is obtained by completing an 8710-11 and since that license level does not even appear on an 8710-1,
for all practical purposes it should not even be considered to be a "Previously Held Rating" at all when seeking a Subpart H CFI rating.  I have always disagreed with that.
Joined 06/11/2017 - 699 Posts
It is not a renewal because your CFI ticket has expired.  You can renew only an unexpired CFI. 61.197.   An expired CFI ticket cannot be renewed, only reinstated.  You are accomplishing reinstatement by taking an additional rating ride. 61.199.  As for what boxes to check, IACRA will take care of that for you go through that process on line

As for what "some DPE's feel", they should discuss this with their POI at the FSDO rather than rely on feelings.  However, I will double-check everything I wrote when the FAA reopens tomorrow.
Joined 03/14/2020 - 4 Posts
Thanks again.
Joined 06/11/2017 - 699 Posts
Checked with the FAA this morning.

What you want is considered an "additional rating" test, so that's the box which will be checked, not "initial" or "renewal" or "reinstatement".  Per 61.199, completion of an "additional rating" CFI practical test gets you reinstated automatically,  You do get credit for the FOI written you took for your CFI-SP, and as you already know, you will have to take the CFI-Airplane written.

However, in terms of what tasks you must do on that practical test, since the CFI-Airplane PTS Additional Rating Task Table has no provisions for the holder of a CFI certificate with only a Sport Pilot rating, you will have to do all the Areas/Tasks for an initial CFI with ASE rating in the CFI-Airplane PTS, including Area I on Fundamentals of Instruction.  The FAA recognizes the inappropriateness of this, but held off changing the CFI PTS because they were already working on the new CFI ACS to replace it, and this will be covered in the Additional Rating Task Table in the CFI ACS when it comes out -- whenever that is.  But for now, you'll have to do everything in the book that isn't specific only to ASES/AMEL/AMES.

The good news is that since April 2018, the requirement for a complex airplane for the CFI-ASE practical test has been deleted, so you can do that test in the Tomahawk (as long as there's enough useful load available for you and the examiner and enough gas for the ride plus reasonable reserve).

Time to start practicing Chandelles and 8's on Pylons and getting some spin instruction training in the right seat of that Tomahawk.