Pilot Counsel

Recent-experience requirements

November 1, 2004

AOPA counsel John S. Yodice holds a commercial certificate with SEL, MEL, SES, and rotorcraft ratings.

Last month we began a review of some of the general operating and flight rules that pilots tell us they would like to see explained from time to time (see " Pilot Counsel: Seat Belts and Shoulder Harnesses," October Pilot). It is surprising how easy it is to forget some of the fine points of these rules.

This month we'll review the requirements of FAR 61.57. These are the "recent experience" requirements that a pilot must meet before starting out on a typical private — that is, noncommercial — flight. We'll continue next month with some of the other preflight requirements that a pilot must meet, such as the flight review, and the training and endorsement requirements for complex airplanes, high-performance airplanes, pressurized aircraft, and tailwheel airplanes.

General requirement

There is an overall "general experience" requirement. The rule is that a pilot may not command an aircraft carrying passengers unless the pilot has made at least three takeoffs and three 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 landings must have been made to a full stop, and in a tailwheel airplane.

Here is one of the finer points of this requirement that especially bears review. 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. Civil aircraft are grouped into progressively smaller groupings starting with the largest, the "category," then "class," then "type" (the smallest grouping before getting down to the particular aircraft). There are five categories of aircraft: airplane, rotorcraft, glider, lighter than air, and powered lift. 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 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 typical light (technically "small") general aviation aircraft. (The recent sport pilot rulemaking added two new categories: "powered parachute" and "weight-shift control," and "land" and "sea" as classes for these new categories.)

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 certificated in all those airplanes. We will see later that it is different for the instrument recency-of-experience requirement.

These takeoffs and landings are required only in order to carry passengers. They are not required to act as pilot in command (unless it is an aircraft certificated for more than one pilot). So if a pilot fails to meet the recent-experience requirement, he or she may still fly solo to gain the required experience. As we will see, this is different from the recent experience required to act as pilot in command under IFR.

Night requirement

For a "night" flight, that is one that begins one hour after sunset and ends one hour before sunrise, a pilot may not command an aircraft carrying passengers unless within the preceding 90 days the pilot made three takeoffs and three landings to a full stop during such a night period. In order to meet this requirement, the pilot must have been the sole manipulator of the flight controls. A fine point: Notice that this specified nighttime period is different than the definition of night in Part 1 of the FARs ("the time between the end of evening civil twilight and the beginning of morning civil twilight"). Notice, too, that the landings must have been to a full stop.

Instrument requirement

There is a specific requirement for recent instrument experience. A pilot may not command an aircraft (the glider requirement is different) operating under the instrument flight rules, or in weather conditions less than VFR, unless within the preceding six calendar months the pilot has performed at least six instrument approaches, holding procedures, and intercepting and tracking navigation courses.

For you older pilots, notice that the requirement for at least six hours of instrument flight every six months has been eliminated. The current version of the regulation requires only the minimum time necessary to perform these maneuvers.

This requirement applies whether passengers are to be carried or not (different from the general requirement, above). 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, which is a different category.

A pilot who does not meet the recent-experience requirement within the prescribed time — or within six months after the prescribed time — must pass an instrument proficiency check (no longer called an instrument competency check) in order to be current. The check must be in an aircraft of the category in which the pilot will exercise IFR privileges, and it must be administered by an instrument flight instructor or other authorized person.

Logging requirements

All of these experience requirements have associated logbook entry requirements. Even if you actually have the recent experience, not having it logged just invites FAA skepticism. Logging instrument flight 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.

Simulators and training devices

These recent-experience requirements may be accomplished in an approved flight simulator or an approved flight-training device, but only if operated by an aviation-training center certificated under FAR Part 142. A personal computer-based aviation training device (PCATD) may not be used to meet recent experience requirements.

More on preflight requirements next month.

John S. Yodice