by Harold Green
Published in Midwest Flyer – December 2019/January 2020 issue
Recently the FAA changed both the content and the wording of the regulation governing “pilot instrument currency.” Hopefully this discussion will clarify these new requirements. In summary, the changes are mostly positive for pilots. There has been no change to the currency requirements, but there has been a major modification to the means of maintaining currency.
First, consider the currency requirements. There has been a wording change that does not affect the previous requirements, although in first reading the requirements, it seems to eliminate the original six-month grace period. To ensure accurate representation on my part, I did check with various sources. In this process I was presented with a Federal Aviation Regulation (FAR) with which I was unfamiliar. It was given to me as the “secret” regulation and with some minor wording change, it went like this:
“No Federal Aviation Regulation shall be understood by any pilot. In the unlikely event understanding occurs, the offending regulation shall be modified so as to eliminate such understanding.”
This appears to be the case with 14CFR FAR 61.57, which is the principal regulation covering instrument currency requirements. There has been a wording change that the FAA said was made to eliminate confusion.
Attempting to compare the old vs. the new, results in a tortuous discussion that would add nothing to our understanding of the new regulation. Therefore, only occasional references will be made to the old regulation. This discussion focuses on translating the new regulation.
The new wording, apparently intended to clarify, and once one makes a basic change in reference, generally does so. Hence: IFR (Instrument Flight Rules). VFR (Visual Flight Rules).
FAR 61.57 (c)(1)(2) in part says: “A person may act as pilot-in-command under IFR or weather conditions less than the minimum prescribed for VFR only if: (1) Use of an airplane, powered lift, helicopter or airship for maintaining instrument experience. Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered lift, helicopter, airship as appropriate for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view limiting device that involves having performed the following. (i). Six instrument approaches, (ii) holding procedures and tasks, (iii) intercepting and tracking courses through the use of navigational electronic systems.”
As a result of this wording, the pilot is considered to be current any time during this six-month period. Therefore, the non-current period begins after the initial six months. Further, FAR 61.57(d) states: “…a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check.” The key here is the fact that failure to meet the experience requirements begins after the initial six-month period in which the pilot is current by definition. Thus, a full twelve (12) months exist between the initial time and the need for an instrument proficiency check (IPC).
One needs to be aware of the statement “Within the six months preceding the flight.” This means that if you are planning to fly in December, the six months preceding ends in November. This is a change in how the months are counted.
On the positive side of these changes, pilots can now accomplish the required flight experience in an approved flight simulator, flight training device or aviation training device and may do so without an instructor sign off. A direct quote from 61.57(c)(2) is: “A person may complete the instrument experience in any combination of an aircraft, full flight simulator, flight training device or aviation training device providing the device represents the category of aircraft for the instrument privileges to be maintained and providing the pilot performs the tasks and iterations in simulated instrument conditions.”
The pilot must make appropriate logbook entries to document the activity. (We’ll take up the logbook entries later in this discussion.) It is very important to note that there is no requirement for an instructor to sign off these entries.
The pilot must make logbook entries in a manner identical to that required for activities completed in an airplane except the model of the simulator must be spelled out, along with the approaches and holds, just as the pilot would in an airplane. The regulation clearly states that currency may be achieved in any combination of airplane, simulator, flight training device (FTD) or aviation training device (ATD). The definitions of flight simulators, flight training devices and aviation training devices, and the activities for which they may be used, is left for future discussion.
Of course, you can still fly with a “safety pilot” and no discussion would be complete without referring to this individual.
Providing the flight is in visual meteorological conditions, the safety pilot does not need to be instrument rated. The best way to look at this is the fact that the safety pilot must be able to act as pilot-in-command in the aircraft and conditions of the flight. The requirement for logging this time can be found in FAR 61.51 (b). The name of the safety pilot must be included in the logbook entry.
If, despite your best efforts, you wind up needing an IPC, you can expect the same events encountered on your instrument check-ride. The difference is that an authorized instrument instructor (CFII), rather than a designated pilot examiner (DPE) may conduct the IPC. Some pilots find it advantageous to obtain an IPC occasionally just to be sure they are on top of the latest requirements and rust has not entered into their flying.
There is one item that is still puzzling. The portion of the regulation that states that a person may act as pilot-in-command under IFR or weather conditions less than the minimum prescribed for VFR. Why does the regulation say IFR or weather conditions?
Generally, it would be assumed that if the weather conditions were less than the minimums prescribed for VFR, the operation would be conducted under IFR. It will be interesting to see what is made of this in the coming years.
In summary, this new wording makes no significant change to the experience requirements. What has changed is the fact that currency can be maintained using a flight simulator, FTD or ATD and an instructor sign off on such activities is no longer required. In addition, now it is necessary to count the six-month period to conclude in the calendar month before the month of the intended flight.
In my next column, we will explore FTDs, ATDs and full flight simulators and how they can become a regular part of your self-currency efforts.
EDITOR’S NOTE: Harold Green is an Instrument and Multi-Engine Instrument Instructor (CFII, MEII) at Morey Airplane Company in Middleton, Wisconsin (C29). A flight instructor since 1976, Green was named “Flight Instructor of the Year” by the Federal Aviation Administration in 2011 and is a recipient of the “Wright Brothers Master Pilot Award.” Questions, comments and suggestions for future topics are welcomed via email at firstname.lastname@example.org, or by telephone at 608-836-1711 (www.MoreyAirport.com).
DISCLAIMER: The information contained in this column is the expressed opinion of the author only, and readers are advised to seek the advice of their personal flight instructor and others, and refer to the Federal Aviation Regulations, FAA Aeronautical Information Manual and instructional materials before attempting any procedures discussed herein.