IFR Currency Requirements Revisited

by Harold Green
Published in Midwest Flyer – June/July 2020 issue

It seems that once again we need to review the “pilot currency” requirements for instrument flight. That is, how to maintain currency and how to regain it once lost.

The starting point is found in FAR 61.57, Recent Flight Experience: Pilot In Command. The present currency requirements require that within the six (6) months preceding the current month, the pilot will have completed six (6) instrument approaches, navigation by electronic means, and holding procedures. Previously this had to be done in instrument conditions or with a vision limiting device and a safety pilot. Now there is a third option allowing “simulator” use.

The term simulator may be interpreted as including flight training devices (FTD), and aviation training devices (ATD). Please note that the flights can be accomplished solo if in instrument meteorological conditions (IMC), but if in visual meteorological conditions (VMC), there must be a safety pilot!

This reflects two recent changes to these requirements. First, and most important perhaps, is the fact that the pilot may now accomplish this in a simulator and it can be done solo without an instructor sign off. The only catch is that if the simulator in use does not have visuals, the pilot must do a circle-to-land approach in an airplane.

There are some cautions here. First, make sure the simulator that will be used has FAA approval for the intended use. This is evidenced by a letter from the FAA, which should be posted near the simulator and defines the category of simulator and the expiration date of the approval. Second, the definition of the six months prior to the month of the flight means that the six months during which the pilot is current must be counted to the month prior to the proposed flight. That is, if the flight is planned in June, the currency must be counted as of May.

If the pilot does not have the six approaches, etc., within the initial six-month period, there is an additional six months to accomplish them with a safety pilot or in a simulator. The safety pilot only needs to be able to act as pilot-in-command (PIC) in the airplane and weather conditions. Thus, if the flight is in VMC and under the hood, the safety pilot only needs to be a Private Pilot, current in the type of airplane being flown, and have a current FAA medical. If the flight is in IMC, the safety pilot must be instrument rated and current in both instruments and the airplane. If a safety pilot is used, it is necessary to log the name of the safety pilot in addition to logging the approaches by location and type.

If the pilot has not complied with the requirements defined above, the next step is an Instrument Proficiency Check (IPC). This requirement is specified in FAR 61.57 (d). This naturally causes concern on the part of pilots, mostly due to the fact that people don’t really know what is contained in an IPC.

The FAA has published a document, AC 61-98, that provides guidance for the flight instructor conducting the IPC. First, know that the IPC may only be conducted by a Certificated Instrument Flight Instructor (CFII), or a Designated Pilot Examiner (DPE). An instructor not certificated as a CFII may not conduct the IPC. Fundamentally, the IPC is an instrument rating check-ride because AC 61-98 guidelines permit anything in ACS-8, the instrument check-ride requirements, to be included. This includes knowledge questions as one would have on an instrument check-ride. Much is left up to the person conducting the IPC.

From a practical standpoint, what should one expect in an IPC? The following information is based on experience as a CFII conducting IPCs. Other instructors will have different specific approaches, but all should comply with the FAA guidelines and cover the general areas stated herein.

Of course, the pilot to be checked is the first concern of the instructor. The logbook is examined first to determine total time, frequency of flight and type of flight experience. This leads to the ground examination.

Emphasis at first is on mundane things, such as how to file a flight plan, how to pick up clearances, etc. These questions frequently uncover areas that need further exploration, such as emergency procedures, when and under what conditions an alternate airport is needed, and use of the new International Civil Aviation Organization (ICAO) flight plan.

The flight portion focuses at first on determining in what areas the pilot can use improvement. Usually this includes the instrument scan since if there is need for an IPC, the pilot has not been flying instruments frequently. To correct this, time is spent on basic maneuvers, such as canyon approaches* and any other operations, which appear to be appropriate for the pilot. Timed and compass turns are also good exercises to enhance the scan. In addition, the ability to react to unexpected changing conditions, and loss of information due to equipment failure, needs to be examined. After all, most pilots retain the mainstream skills, but with rough edges at times.

Therefore, there are two basic approaches to the flight portion of the IPC depending on the equipment in the airplane to be used. For airplanes with legacy equipment, there is one approach, and for the technically advanced aircraft, there’s another approach.

If the airplane is equipped with GPS, the IPC will include the two-airport sequence described under the technically advanced aircraft (TAA) discussion that follows. Of course, the primary consideration is the capability and attitude of the pilot. For both equipment levels, plan on at least three different types of approaches with one being with failed equipment. In both cases, the goal is not only to ensure that the pilot is capable, but also to stretch the pilot’s ability to handle stressful situations. The underlying assumption is that it is rare to be able to schedule when an emergency will occur. Further, if the IPC can be done in IMC, that is a definite plus. Should you think this is too sadistic, consider that while this is stressful, it is less stressful than a real situation when alone in actual IMC.

For legacy equipment, loss of the vacuum pump(s) provides a very good exercise, and at least one of the three approaches to be flown should be a no gyro approach, and preferably this will be a timed VOR approach. If the aircraft has an autopilot, the pilot should demonstrate the ability to fly both with and without using it, as well as recognizing, and reacting to, an unscheduled autopilot disconnect. If the airplane is equipped with GPS, the pilot must demonstrate the use of non-GPS equipment on the airplane, as well as the ability to make rapid, error-free changes to the GPS program.

For technically advanced aircraft (TAA), the sequence is different, but includes the autopilot issues as with the legacy equipped aircraft. The different approach is because of the level of redundancy available with TAA. Usually, there are so many levels of backup, including redundant and independent electrical power systems, that the probability of the loss of any function other than the autopilot becomes much lower than the probability of pilot error in manipulating the equipment. This statement is the author’s opinion and not substantiated by any formal study. Therefore, the IPC and the final ride before recommending a student for their initial check-ride, consists of an IFR flight from a non-towered airport to the towered airport only nine statute miles away in Class C airspace. At the towered airport, an ILS approach to a miss is followed by a GPS approach back to the home airport. This means the pilot must change destinations on the GPS, select an approach and a waypoint, all while flying the airplane and communicating with approach. To do this the pilot must be familiar with the equipment, including using an autopilot to minimize the workload. If this can be accomplished without significantly annoying approach control, all is good.

In summary, a pilot has six (6) months prior to the month of a proposed flight to execute six (6) approaches, a holding pattern and navigation by electronic means. In the seventh month or thereafter up to a year from the initial date, the pilot must use a safety pilot to complete the initial requirements. The safety pilot must be able to act as pilot-in-command in the airplane and weather in which the practice is accomplished. These approaches can be accomplished in a simulator without a safety pilot or instructor. After the second six (6) months, it is necessary to accomplish an instrument proficiency check or IPC. While a safety pilot is not required to be a Certificated Instrument Flight Instructor (CFII), the person conducting the IPC must be a CFII or DPE. The relevant documents are FAR 61. 57, ACS-8, and AC 61-98.

*A canyon approach is a combination of a timed 360-degree turn and a Vertical S maneuver. The approach is initiated with a standard rate turn, combined with a 500 foot per minute rate of descent. In 2 minutes, the pilot should be 1,000 feet lower and on the original heading. He then initiates a standard rate turn in the opposite direction, combined with a 500 foot per minute climb. In 4 minutes, the pilot should be at the original altitude and on the original heading. In order to accomplish this, the pilot must know the power settings required to achieve the appropriate performance and use them, rather than manhandle the controls. The speed to use on a canyon approach is the speed the pilot would use on a timed VOR approach. If the pilot can do this within 10 degrees, 100 feet and 10 seconds while holding speed within 10 knots, he has done well. A canyon approach makes a pilot a believer in power/pitch flying and results in much smoother flying skills. In fact, many times pilots who are taught how to execute a canyon approach report that their significant others recognize how smooth their flying has become.

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 harlgren@aol.com, 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.

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