August 1, 1997
By John S. Yodice
Every pilot needs to know the recent experience requirements of Section 61.57 of the Federal Aviation Regulations.
We have just been through a major overhaul of FAR Part 61, and there have been some changes to these requirements. Also discussed were some proposals that did not come to pass. Now that the dust has settled and the changes become effective on August 4, this is a good time to set out the requirements as they currently exist for private (noncommercial) operations.
The "general experience" requirement has not changed. Here is the rule: A pilot may not command an aircraft carrying passengers unless the pilot has made at least three takeoffs and landings within the preceding 90 days as the sole manipulator of the flight controls.
If the aircraft to be flown is an airplane with a tailwheel, the takeoffs and landings must have been made to a full stop in a tailwheel airplane. There was a proposal to require that landings in all aircraft must have been made to a full stop. It was considered but not adopted. Also not adopted was the proposal that the landings involve flight in the traffic pattern of an airport and at the recommended traffic pattern altitude for the airport.
The regulation states that the takeoffs and landings must have been in an aircraft of the same category and class (and type, if a type rating is required). These terms have been a source of confusion. Bear with me through this explanation. It's painful but important.
Civil aircraft are grouped into progressively smaller groupings by category, class, type, and particular aircraft. There are five categories of aircraft: airplane, rotorcraft, glider, lighter-than-air, and powered-lift. (The powered-lift category is a new one created in the overhaul of Part 61, but I don't think there are any such aircraft generally available.) Within three of these categories there are classes. The classes of aircraft in the airplane category are single-engine land, single-engine sea, multiengine land, and multiengine sea. The rotorcraft classes are helicopter and gyroplane. The lighter-than-air classes are airship and balloon. There are no classes in glider and powered-lift. The proposal to establish class ratings for "powered gliders" and "nonpowered gliders" was not adopted. The type of aircraft means its basic make and model. A type rating is required in large aircraft and turbojet airplanes, and some others. A type rating is not required in light general aviation aircraft. An individual aircraft, the particular one that you fly, is identified by make, model and serial number, and by its registration "N" number.
Unscrambling all of this, if you have the required number of takeoffs and landings in a single-engine land airplane (single-engine land class), that does not qualify you to carry passengers in a multiengine airplane or in a seaplane (different classes), even if you are licensed in all those airplanes. We will see later that it is different for the instrument recency requirement.
Notice that takeoffs and landings are required only in order to carry passengers. They are not required to act as pilot in command. If a pilot fails to meet the recent experience requirement, he may still fly solo to gain the required experience. This is different from the recent experience required to act as pilot in command under IFR.
The night requirement has not changed either. A pilot may not command an aircraft carrying passengers during a specified nighttime period unless within the preceding 90 days the pilot has made three nighttime takeoffs and landings. The specified nighttime period begins one hour after sunset and ends one hour before sunrise. As with the tailwheel airplane, the required nighttime landings must have been to a full stop.
The instrument experience requirement has changed somewhat. A pilot may not command an aircraft operating under instrument flight rules, or in weather conditions less than VFR, unless within the preceding 6 calendar months the pilot has performed:
The proposal to require recovery from unusual attitudes, which would have required a safety pilot, was not adopted.
The most significant change is the elimination of the requirement for 6 hours of instrument flight every 6 months. Now, only the time necessary to perform the maneuvers cited above is required.
These maneuvers may be performed in flight under actual or simulated conditions. If the maneuvers are performed in flight, they must be performed in the appropriate category of aircraft. They need not have been performed in a specific class of aircraft. For example, if they were performed in a single-engine land airplane, the pilot would also meet the requirement for all other classes of airplane, whether multiengine or sea. The pilot would not meet the currency requirement for rotorcraft, a different category.
The required instrument experience in a glider is different. At least 3 hours of instrument time in flight is required. If no passengers are to be carried, 1.5 hours may be acquired in an airplane or a glider. If a passenger is to be carried, 3 hours of instrument time in a glider is required.
The term instrument proficiency check replaces the term instrument competency check. A pilot who does not meet the recent experience requirement within the prescribed time — or within 6 months after the prescribed time — must pass an instrument proficiency check in order to be current. The check must be in an aircraft of the category in which the pilot will exercise IFR privileges. The rule now explicitly specifies that the check must consist of a representative number of tasks required by the instrument rating practical test. The check must be administered by an instrument flight instructor or other authorized person.
The required takeoffs and landings may be accomplished in an approved flight simulator or an approved flight training device operated by an aviation training center certificated under FAR Part 142. So far as I can determine, there is only a handful of certificated training centers at this time, with perhaps another handful of applications pending. The required instrument approaches and maneuvers may also be accomplished in a flight simulator or flight training device operated by an aviation training center. And the instrument proficiency check may be accomplished in an approved flight simulator or an approved flight training device that is representative of the aircraft category (other than a glider). A personal computer-based aviation training device (PCATD) may not be used to meet recent experience requirements.
All of these experience requirements have a companion logging requirement. Logging the experience time and maneuvers can be as important as the experience itself. Remember, a pilot is required by regulation to present his or her logbook for inspection (not surrender) upon the reasonable request of the FAA, the NTSB, or any federal, state, or local law enforcement officer. (The proposal to overhaul Part 61 had deleted the word reasonable, but on objection by AOPA, it was put back. The FAA said that it had been deleted "inadvertently.") Any incident or accident will usually trigger such a request. When an FAA inspector inspects a pilot's logbook, the inspector will be looking for the entries evidencing any required recent experience, among other things. It will do a pilot little good to say that he or she actually has the required experience though it is not logged. The lack of a logbook entry is a violation in and of itself.
Logging instrument flight time to meet the instrument experience requirement demands special attention. A pilot must record the location and type of each instrument approach accomplished. If a safety pilot is required, the pilot must record the name of the safety pilot. A proposal to require a pilot to record the certificate number of the safety pilot was considered but not adopted.
There are other requirements that a pilot must meet, such as accomplishing a flight review. There are special requirements for complex airplanes, high-performance airplanes, pressurized aircraft, and tailwheel airplanes. We will deal with these in future columns.
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