The Essentials of Maintaining IFR Currency

Source: www.faa.gov/news/safety_briefing, By Jeffrey Smith

For a few weeks you have been planning to take a couple of friends on a cross-country flight to introduce them to flying in a general aviation aircraft and grab some lunch at a nearby airport. The night before you realize there will be some low ceilings at your departure airport the next morning, with an overcast layer at 1,000 feet above ground level. The forecast calls for improving weather at the destination, and by the time you return in the late afternoon the entire flight should be blessed with clear skies and unrestricted visibilities. You are not overly concerned about the forecast clouds at your departure airport, which should be smooth with no expected turbulence. You also know that your friends will enjoy experiencing flight in both visual meteorological conditions (VMC) and instrument meteorological conditions (IMC), and you look forward to sharing that with them. Then you recall that one word that makes you scramble for the regulations and your logbook: currency. Will you be able to file and fly the morning flight, or will the lunch plans have to wait?

It may be difficult to keep IFR experience as your top flying priority, or even keep all of the requirements straight in your head. Therefore, we will use the scenario above to navigate through some of the key regulations that pertain to the instrument rating and keeping your privileges current.

First, although you know you need to have an instrument rating, current privileges, and file an IFR flight plan, let us review the regulations that codify these requirements:

• Section 61.3(e) provides the foundation for holding an instrument rating, stating that “[n]o person may act as pilot in command of a civil aircraft under IFR ... unless that person holds ... [an] instrument rating on that person’s pilot certificate for any airplane, helicopter, or powered-lift being flown.” This regulation also accounts for ATP certificate holders, and offers glider and airship instrument requirements.
• Section 61.2(b) explains the general meaning of currency by stating that “no person may ... exercise privilege of an airman certificate or rating ... unless that person meets the appropriate ... recency requirements of this part.”
• Section 61.57(c) offers, in part, the ‘recency requirements of this part’ referenced by 61.2(b). With limited exception for those that fly for an air carrier (under parts 121 or
  135), this regulation provides the instrument rating currency requirements of a person acting as pilot in command (PIC) of a flight conducted under IFR (or in weather conditions less than VFR).
• Section 91.173 requires any person operating in controlled airspace under IFR to have filed an IFR flight plan and have received an IFR clearance.
  

Section 61.57(c) compels you as the PIC to review the preceding six calendar months of your instrument activity prior to a flight under IFR. This means looking back six months, and then to the beginning of that month, from the date of the intended flight. For example, if you planned the lunch sortie for October 21, 2015, you would look back at your activity starting on April 1, 2015. There is an exception to this six calendar month time period. If you are solely using an authorized Aviation Training Device (ATD) for currency, the time frame is two calendar months preceding the month of the flight.

Section 61.57(c) also describes the maneuvers and procedures that you must have completed. For example, if you performed your recent experience requirements in an aircraft (other than a glider), section 61.57(c)(1) applies and requires “six instrument approaches ... holding tasks and procedures ... and intercepting and tracking courses through the use of navigational electronic systems” within the preceding six calendar months. Procedures and maneuvers that are necessary when using a full flight simulator or flight training device (collectively referred to as Flight Simulation Training Devices, or FSTD), ATD, or combination of aircraft and devices, are described in 61.57(c)(2), (3), (4) and (5). Maintaining instrument recent experience in a glider is covered by section 61.57(c)(6).

On the subject of maneuvers and procedures, recall that they must be recorded in order to count. A quick read of section 61.51, in particular 61.51(g), will help make certain that you are completing your logbook entries with the required information. A safety pilot is required when operating in simulated conditions and the name of the safety pilot must be included in the logbook entry. The safety pilot must hold at least a private pilot certificate with the category and class rating applicable to the aircraft being flown. You can find other requirements for using a safety pilot in section 91.109(c).

If you are using an FSTD or authorized ATD to acquire recent experience, an authorized instructor must be present to observe the use of the device. The instructor must also sign your logbook, noting the time and the content of the training session (i.e., the maneuvers and procedures that you performed).

Getting back to our example flight, what happens if you have not logged the items required by 61.57(c) within the preceding six (or two) calendar months? The answer depends on the last date that you were able to act as PIC of an aircraft under IFR. If it has been less than 12 calendar months from when your currency lapsed, you may still get yourself current again. Using the October 21, 2015 date, if you were current sometime between October 1, 2014 and September 30, 2015 then you may regain your currency using one of the options listed in section 61.57(c). Review the items you have done within the preceding six calendar months (or two months if you plan to only use an ATD), and then, at a minimum, complete any additional items needed.

What if the last time you were current was greater than 12 calendar months ago? This means, with limited exception, you will need an Instrument Proficiency Check (IPC). For an October 21, 2015, flight, if you were last current September 30, 2014, or prior, an IPC will be needed to regain instrument currency. Although examiners and other individuals can provide IPCs, most pilots elect to receive the check from an authorized instructor. Note that at the election of the authorized instructor conducting the IPC, you can combine the check with the requirements in section 61.56 for a flight review.

While section 61.57(d) provides the regulatory basis for the IPC, the Instrument-Rating Practical Test Standards (PTS) specify additional information. For example, the minimum areas of operation that you must perform during an IPC are part of the “Rating Task Table.” You can complete certain tasks in an FSTD or authorized Advanced ATD; these tasks are listed as part of the appendices in PTS.

The FAA has previously clarified that an IPC, as well as a practical test for an instrument rating, “resets” the clock on instrument currency. Therefore, if you have completed your instrument checkride or an IPC within the preceding six calendar months you can consider yourself current with respect to 61.57(c). Also, keep in mind that the instrument currency requirements must be maintained separately for each instrument rating, so completing maneuvers and procedures in an airplane will not grant you currency for your instrument-helicopter rating.

This article has thus far focused on the regulatory minimums necessary to exercise one’s instrument rating privileges. However, responsible pilots understand there is a difference between being current and being proficient. You should always make an assessment of your knowledge and skills to determine if you are able to competently conduct the flight. For example, ask yourself if you were performing to instrument rating standards when you last flew an aircraft without outside visual references (or operated a training device using only the instruments). Do you have experience with the installed avionics and/or your electronic flight bag equipment? Are you comfortable with the departures, arrivals, and approaches you may be cleared for during the flight?

Consider the flight not only in terms of everything going right but also in terms of the unexpected happening. What if a primary flight instrument fails, your GPS or multi-function display screen goes blank, or you lose radio communications while in the clouds? Would you be comfortable in handling those scenarios? These questions are only examples and while you cannot anticipate every possibility that may occur, you should be sure in your ability to handle abnormal and emergency situations.

For additional information, check out the Instrument Proficiency Check Review Guide (ALC-38) found at www.FAASafety.gov. This course provides a structured guide to reviewing IFR rules and procedures, in addition to containing information on establishing personal minimums and weather related decision-making.

In consideration of the opening scenario, you may conclude that you are current with respect to the regulation, in addition to being proficient. If so, great, and you can enjoy the IFR flight with your friends and hopefully a tasty lunch. However, if decide you are not instrument current or proficient, do the responsible thing and cancel the flight until you can correct the situation. You can always reschedule the lunch mission for another day, or postpone until VFR conditions prevail and grab an early dinner instead.

Jeffrey Smith is the manager of the FAA’s Airman Training and Certification Branch. He holds an ATP certificate, is a flight and ground instructor, and is certificated as an A&P mechanic.