May 1, 2007
By John S. Yodice
John S. Yodice owns a Cessna 310, which he uses for business and pleasure. He is the legal counselor for AOPA.
Instrument pilots are aware of the recent experience requirements of Section 61.57(c) of the federal aviation regulations.
We have reviewed them in this column from time to time (" Pilot Counsel: Recent-Experience Requirements," November 2004 Pilot). But, what has sometimes caused uncertainty is the part of the regulation that requires an instrument proficiency check (no longer called an "instrument competency check"). Just recently the FAA issued a notice of proposed rulemaking that has deep within it some helpful language clarifying this uncertainty. The rulemaking itself, which is quite extensive, may not become final for months or years to come. The FAA's clarification is helpful now.
Let's start with the parts of the regulation that are commonly understood by all instrument pilots, though many of us can benefit from refreshing our memories. Under the regulation, a pilot (except an airline pilot under certain circumstances) may not command an aircraft (the glider requirement is different) operating under 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 courses through the use of navigation systems.
There is no requirement for a certain specified amount of recent instrument time. The old requirement for at least six hours of instrument flight every six months was eliminated several years ago. But, there is still an implicit time requirement. The current version of the regulation obviously, but not explicitly, requires the minimum time necessary to perform these specified procedures.
As for the number of procedures required, only the number of instrument approaches is specified — six. There is no specific number of holding procedures required, though the plural (procedures), implies more than one procedure. So, too, there is no specific number of intercepting and tracking procedures required, but the plural indicates that more than one is required. As we will see, the FAA is proposing in the future to make the number of procedures more specific. But not now.
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. As for a common 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. These recent experience requirements, including the instrument proficiency check, 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 now be used to meet recent experience requirements.
Very important, these experience requirements have associated logbook entry requirements. Even if you actually have flown the required procedures, but you didn't log them, not having them logged just invites FAA skepticism. It is after an incident or an accident that the FAA will ask to see your logbooks, and then things become problematic. Also, pilots sometimes miss the requirement that the logbook entry for the instrument approaches needs some specificity — 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.
Understanding these requirements has achieved new importance because the instrument proficiency check has become more rigorous. For many pilots, staying current with recent experience and training is a lot more practical.
Now to the clarification as to when an instrument proficiency check is required. The FAA notice tells us that one is required if a pilot has not complied with the instrument recent experience requirements "within the preceding 12 calendar months." A pilot should first look back to the preceding six calendar months from the date of the flight to see if he or she has performed and logged the instrument recent flight experience. The FAA tells us, "If the pilot has not performed and logged the required instrument recent flight experience within the preceding six calendar months from the date of the flight, the pilot is given an additional six calendar months to perform and log the required instrument recent flight experience. However, during this six-month period, the pilot may not act as PIC under IFR or in weather conditions less than the minimums prescribed for VFR until the pilot performs and logs the required instrument recent flight experience of...? 61.57(c). If during this six-month period, the pilot does not accomplish the required recent instrument flight experience, then the pilot would have to perform an instrument proficiency check to regain his or her instrument currency."
The FAA offers a helpful example. "For example, if a pilot is intending to act as pilot in command under IFR (or in weather conditions less than the minimums prescribed for VFR) on a flight on February 24, 2007, and the pilot has not completed the required instrument recent flight experience of proposed Â§61.57(c), then the pilot would count backwards 12 calendar months from the date of the flight. Thus, the pilot would have to have performed and logged the instrument recent flight experience requirements at sometime between February 24, 2007, and February 1, 2006, to avoid being required to submit to an instrument check."
Notice that this example also clarifies the concept of "calendar month" as applied to the look back. In most instances the concept gives a pilot a grace period. It will usually give the pilot more days than 180 to meet the requirements by looking back to the beginning of the month in which the six-month or 12-month anniversary date falls.
An instrument proficiency check must be administered by an instrument flight instructor or other authorized person. The instrument proficiency check may be accomplished in an approved flight simulator or an approved flight training device, but not a personal computer-based aviation training device (PCATD).
As I mentioned earlier, the FAA is proposing to make the number of required procedures more specific. This may not happen for some time, if ever. However, the proposal, even as a mere proposal, does give us an idea of what the FAA may consider to be best practices, some of which we may want to incorporate into our flying right now; maybe we should even begin to include more information in our logbook entries.
The FAA proposes that in the future the minimum experience be amplified as follows:
The six instrument approaches would be required to consist of both precision and non-precision approaches.
The required holding patterns would need to consist of at least one complete holding pattern at a radio station (such as a VOR) and one complete hold at an intersection or waypoint.
And, in addition to meeting the "intercepting and tracking" requirement with actual experience, a pilot could qualify with "one hour of simulated cross-country practice operation that involves intercepting and tracking courses through the use of navigation systems while performing the various phases of the flight: a takeoff phase, area departure phase, en route phase, area arrival phase, approach phase, and a missed-approach phase of flight." Notice the specificity of the different "phases of flight" that are not in the current regulation. These are some specifics that we may want to assure that we periodically perform while we are routinely accumulating the required experience, and that we may want to log to keep track of.
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