Can a CFI Instruct from a Jump Seat?
A focused interpretation of FAA Williams (2018) on whether a flight instructor can provide instrument training without occupying a pilot station.
Key Conclusion
The FAA interprets that, in the described scenario, instrument instruction may not be conducted when the instructor is not occupying a pilot station with access to the controls.
Primary Legal Issue
Whether a flight instructor can provide instrument training:
- while not acting as PIC
- while seated in a jump seat or passenger seat
- with a safety pilot occupying the copilot seat
Rule (CFR)
Instructor position requirement
- §61.195(g)(2):
Flight training for a certificate or rating must be conducted in an aircraft with at least two pilot stations
Aircraft control requirement
- §91.109(a):
Aircraft used for flight instruction must have functioning dual controls (or approved equivalent)
FAA Interpretation
1. Meaning of “two pilot stations”
The FAA interprets that:
- The requirement for two pilot stations
- implies one for the student and one for the instructor
→ Otherwise, the regulatory language would have no effect
2. Instructor position and control access
Reading §61.195(g) together with §91.109(a), the FAA interprets that:
- The instructor is expected to provide training from a position
- with access to flight controls
→ This supports intervention and demonstration during instruction
3. Application to jump seat scenario
In the described configuration:
- Instructor is seated in a jump seat or passenger seat
- Safety pilot occupies the second pilot station
The FAA concludes that:
→ This arrangement would not comply with §§61.195(g) and 91.109(a)
4. Medical issue not reached
The FAA states that:
- It is unnecessary to determine whether a medical certificate is required
- because the operation itself is non-compliant
5. Inspector comparison
The FAA distinguishes:
- FAA inspectors observing from a jump seat
- vs instructors providing flight training
→ Observers are not exercising instructor privileges, so the situations are not equivalent
Implication (Limited)
- The interpretation focuses on instructor position and ability to control the aircraft
- The conclusion applies to this specific training configuration under Part 61
- It does not address non-instructional observer roles
Common Misunderstandings
- ❌ “A safety pilot can substitute for instructor control access”
- ❌ “Instructor seating position is flexible if not acting as PIC”
→ The FAA analysis centers on instructional function, not PIC designation
One-Sentence Summary
The FAA interprets that, for instrument training under these conditions, the instructor is expected to occupy a pilot station with control access, making jump seat instruction non-compliant.