Understanding recent experience requirements
If six months has passed without meeting the currency requirements, a pilot can regain currency in that next six-month period by performing and logging the stated maneuvers. However, if that second six-month period passes with-out performing the currency maneuvers, then FAR 61.57(d) provides that a person may not be PIC under IFR or in weather conditions less than the minimums prescribed for VFR until he or she has satisfactorily accomplished an instrument proficiency check (IPC).
For purposes of staying current, the regulation sets forth specific maneuvers, at a minimum, that must have been performed and logged within the preceding six months of the flight in order to be qualified to act as PIC in instrument conditions. There is no explicit minimum time requirement for performing the maneuvers; only the time necessary to perform the maneuvers is required. The required maneuvers are:
- at least six instrument approaches;
- holding procedures; and
- intercepting and tracking courses through the use of navigation systems.
These maneuvers may be performed in an aircraft or in a flight simulator or flight training device. If done in an aircraft, the aircraft must be of the appropriate category, but not class, of aircraft. For example, if a pilot performs the required maneuvers in a single-engine land airplane, the pilot would also meet the requirement for all other classes of airplane, whether multiengine or sea. However, the pilot would not meet the currency requirement for rotorcraft, which is a different category of aircraft. If maneuvers are performed in a flight simulator or flight training device, it must be one that is representative of the aircraft category for the aircraft to be flown.
A pilot may remain current to act as PIC of a flight under IFR if these maneuvers are performed within six months of the contemplated IFR flight. If that six-month period has passed, the pilot may regain currency in the next six months by performing and logging the required maneuvers.
However, if a pilot is not able to meet these instrument experience requirements within six months of the latest qualifying experience, or within six calendar months after that, then the pilot must pass an IPC before he or she can be PIC on an IFR flight. That is, if a second six-month period has run out without performing and logging the recent instrument experience, the pilot may only become instrument-qualified by successfully completing an IPC in an aircraft of the category in which the pilot will exercise the IFR privileges.
The regulation specifies that this 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.
There are other recent flight experience requirements that must be met before commencing a flight as pilot in command, such as a flight review and three takeoffs and landings within the preceding 90 days (if passengers are carried). It is sometimes hard to keep track of all of these requirements for currency, especially since the dates don't always naturally coincide. Nonetheless, as the person in command of the flight, you are responsible for remaining current, so be sure to accurately and timely complete and log your recent flight experience requirements.
Kathy Yodice is an attorney with Yodice Associates in Washington, D.C., which provides legal counsel to AOPA and administers AOPA's legal services plan. She is an instrument-rated private pilot.
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