I use this scene from Office Space to describe to clients what the recent experience regulations mean to us as pilots. The supervisor in the scene tries to motivate his employee to do more than the base minimum required. Jennifer Aniston's character behaves like many aircraft owners when confronted with their own lack of proficiency training.
When you talk to
people about CFR 14 61.57 you’ll hear a lot of confusion about what a pilot needs to
accomplish from a recent experience perspective to serve as pilot in command (PIC).
This area is widely
misunderstood by a good deal of pilots. This is because the regulation has
changed a bit over a number of years, and quite a few of us older people
interpolate our memories with things we've heard recently- but didn’t pay much
attention to. Paul Simon sang “a man hears what he wants to hear and disregards
the rest” and I can think of many areas of my life where that statement is
applicable; I have no intentions of throwing stones from my glass house.
Subparagraph A states that to serve as PIC in day VFR conditions while carrying passengers, one must, within
the preceding 90 days, perform three take offs and landings as the sole
manipulator of the controls in the same category class and type (if a type
rating is required). Additionally if you want to exercise PIC privileges in a
tail wheel aircraft the take offs and landings have to be in a tail wheel
equipped plane.
Now that is simple enough.
Over the past twelve weeks the federal government mandates that for
you to serve as Pilot in Command (PIC) you must hop into a flying machine
typical to the one that you’re most likely to operate and squeak out three.
Even if you are unable to find the time for one take off and landing every thirty days, after day 91 of inactivity you will
still be able to, largely without time limit, get into your airplane by
yourself and perform the three takeoff and landings specified in the regulation.
Requirement met; once again you’ll be able to command an aircraft carrying
“souls on board”. This will be true until the day after the last day of the
twenty fourth month since your last 61.56 mandated flight review.
All of this is only applies
if you are an aircraft owner. Although totally legal it is highly unlikely that a FBO/Flight School/Flying club would rent
an aircraft to a pilot who wasn't current.
Subparagraph B details
night takeoff and landing experience and similar to Day VFR there is little confusion
as to whether a pilot is current and what is necessary to regain that
status. Once again three take off and landings every ninety days is the magic number. The FAA gets a
bit more specific now that we are reading deeper into the regulation. These
take off and landings must be made to a full stop. Someone in the FAA rightly thinks night
operations differ enough from daytime to require the pilot to go through the
exercise of turning off the runway then taxiing back for takeoff. Night
is also clearly defined to mean one hour after sunset and ending one hour
before sunrise. There is little left for interpretation. Simulator use is
excluded unless the simulator is approved for landings or is used as part of an
approved course conducted by a part 142 operator.
Flying at night is a
surreal experience, one that I don’t do as often as I’d like, but as the owner
of a single engine airplane I really don’t care for how limited my options become should
the only power plant on board decide to take some time off. However, on occasion, I have got caught out
after sunset. This happens with some regularity when you are conducting multi leg
operations, something happens to the airplane or weather delays you. If flying
solo when these transgressions of night currency occur its no harm or
foul. Rather it presents an opportunity to taxi back and take it around the
patch a couple more times and regain your privileges. If you have passengers on
board and the trip ends uneventfully no one would be any wiser if you were to
violate the currency requirements of 61.57b.
Some may think this is an onerous burden
but essentially the FAA is telling us that at least once a month, we need to
fly at night to be legal to fly (kill) someone other than ourselves.
The part of the regulation
that has most people flummoxed is subparagraph C. Titled Instrument Experience
this details what we as instrument rated pilots must perform at the very least
to fly in controlled airspace in weather less than VFR. The regulation
reads
(1) Use of an airplane
powered-lift, helicopter, or airship for maintaining instrument experience. Within six
calendar moths preceding the month of the flight, that person performed and
logged at least the following tasks or iterations in an airplane, powered lift,
helicopter or 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
(2) Use of a flight simulator
or flight training device for maintaining instrument experience. Within six
calendar moths preceding the month of the flight, that person performed and
logged at least the following tasks or iterations in a flight simulator or
flight training device, provided that the flight simulator or flight training
device represents the category of aircraft for the instrument rating privileges
to be maintained and 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
Sections three and four go
into combining aircraft, flight simulators and aviation training devices at
advanced and basic levels and offer a whole host of thing you need to be doing
with them to maintain the 6HIT’s which is online shorthand on a few pilot
forums for six approaches holding intercepting and tracking.
The area drawing the most
confusion is sub paragraph D or the instrument proficiency check. The FAA has
sent out some clarifications on this recently and I have attached an email I
received as a FAA Safety Team Member detailing the requirements in plain
language.
From the day you receive
your instrument rating you must fly six approaches every six months plus hold
and intercept courses if you want to act as PIC in IFR conditions. So if you
received your rating on June 1st in 2011 you would have until
December 31st 2011 to perform these approaches, or simply fly one a
month and you’ll be fine. If by some outside chance you were unable to fly all
of the approaches by that deadline you would have another six months or until
June 30th of 2012 to get them in either with a safety pilot in an
aircraft, or with an instructor in a simulator or flight-training device. On July 1st
2012 should you not comply you would be required to have passed an Instrument Proficiency Check or
IPC to legally fly IFR in the system.
The IPC consists the areas
of operation and instrument tasks required in the Instrument Practical Test
Standards. This check must be in an aircraft that is appropriate to the
aircraft category; or for other than a glider, in a flight simulator or training
device that is representative of the aircraft category. The check must be conducted by
a FAA Examiner, an authorized instructor or a person approved by the
administrator to conduct instrument practical tests.
So to clarify, on day one of month 13, you as an instrument rated pilot must be evaluated by either a FAA examiner, FAA
Designated Pilot Examiner (DPE) or a CFII. Evaluation is different than instruction and deviations to heading altitude or airspeed are graded against the Instrument Pilot Practical Test standard, the same document and process you lived through when you got your rating.
This is why the IPC is so feared and misunderstood. Essentially you are retesting for your rating. But a key thing to remember is that when working with a CFII you cannot fail a proficiency check, rather unacceptable performance is typically logged as dual instruction. The post flight briefing is where your strengths and weaknesses will be discussed in detail, and if necessary, additional time scheduled to remediate deficiencies discovered during the session.
Most pilots have a negative connotation associated with check rides and are reluctant to submit themselves to retest for a skill they were very proud to acquire the first time around. By treating the
This is why the IPC is so feared and misunderstood. Essentially you are retesting for your rating. But a key thing to remember is that when working with a CFII you cannot fail a proficiency check, rather unacceptable performance is typically logged as dual instruction. The post flight briefing is where your strengths and weaknesses will be discussed in detail, and if necessary, additional time scheduled to remediate deficiencies discovered during the session.
Most pilots have a negative connotation associated with check rides and are reluctant to submit themselves to retest for a skill they were very proud to acquire the first time around. By treating the
Our Redbird AATD simulator
cannot be used for a complete IPC as it is not certified for landings. I usually advise pilots not to let their experience lapse to month 13 because of this. However
if an IPC is required either for a lapse or insurance requirements we can complete most of the work required for the check in the
simulator. After satisfactorily completing this, we simply fly a couple of
approaches in the airplane, one with a landing from a straight in and one from a
circling approach. My scenarios have us
depart DXR to OXC via CMK and V384 to Denna Intersection, we can then do the
ILS 36 or the GPS 36 where a landing finishes the approach. We then depart OXC
to DXR via CMK where we execute the VOR/GPS A with the circle to the active runway.
This satisfies the letter
of the law and then those sucessful pilots can return to service as PIC in weather less
than VFR. Noteworthy is Part 135 and 121 Pilots have to perform these checks twice a year regardless of how many approaches they get in during the past six months. Additionally owners of high performance singles and light twins are sometimes required to get an IPC annually as a prerequisite for their insurance policy renewal. Immaterial of your experience level, taking time to fly with an instructor on an yearly basis is a responsible way to show your passengers you care about their safety as well as your own.
These days, most instructor's are available for less cost per hour than the fuel used during the session so flying with one either in an airplane or simulator is probably one of only bargains in aviation. As a full time instructor who has been teaching pilot
These days, most instructor's are available for less cost per hour than the fuel used during the session so flying with one either in an airplane or simulator is probably one of only bargains in aviation. As a full time instructor who has been teaching pilot
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