Regain FAA instrument currency with foreign license (for dual IR holders)

4 Answers

1. 
   

   
   

   John D Collins on Feb 28, 2014

   Scenario 1: If by not fulfilling the FAA IR currency requirements in the last 6 calendar months, you mean that in the month you wish to take the flight, you were not current for the previous 6 calendar months, then 61.57 ((d) states:

   “Instrument proficiency check. Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check.”

   I would interpret this to mean what it says and it only provides a single method of obtaining currency, you must complete an instrument proficiency check. Time ran out for you to obtain currency by other means.

   If you meant that you had you not lapsed currency for the 6 calendar month period and did not yet require an IPC, your US IFR privileges have expired, but you can still use a safety pilot to regain currency without needing an IPC.

   In this case, your FAA currency has lapsed, but not your UK currency and you were within the 6 month calendar period for the FAA currency, even though you could not act as an FAA PIC in IMC conditions. The way I read the regulation is that the tasks including approaches, holds, and navigation using Intercepting and tracking courses through the use of navigational electronic systems could count towards reestablishing FAA currency. FAR 61.3 states:

   “a) Required pilot certificate for operating a civil aircraft of the United States. No person may serve as a required pilot flight crewmember of a civil aircraft of the United States, unless that person:

   (1) Has in the person’s physical possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or authorization—
   (i) A pilot certificate issued under this part and in accordance with § 61.19;
   (ii) A special purpose pilot authorization issued under § 61.77;

   (v) When operating an aircraft within a foreign country, a pilot license issued by that country may be used.”

   This suggests that you have to be in the UK if you are using your UK pilot license in lieu of your FAA certificate and could not do so in the US.

   Scenario 2: If you need an IPC, it is the only means offered to regain FAA currency.

   I hope Mark comments on this as he is an expert on the regulations. This is probably only an academic question.

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2. 
   

   
   

   Zonker on Mar 01, 2014

   Thanks for your detailed answer, John.

   To be sure there’s no misunderstandings, I want to clarify the core of my question again:

   If you have only an FAA IR, and you’re out of currency, then all you can do is to go with a safety pilot (in the “grace period”), or complete an IPC (after the “grave period”). Scenario 1 above was referring to being within the “grace period”, and scenario 2 after the “grace period”. (Sorry if that wasn’t clear enough.) Now, if you’re in the “grace period”, but you are legal to fly IFR as PIC by some other means (e.g., under another IR outside of the USA), then the following interesting situation arises:

   If I use my foreign IR to fly 6 approaches etc. abroad (which is legal), then FAR 61.57(1)(c) seems to suggest that my FAA IR current again. It only talks about logging the approaches etc. in the last 6 calendar months preceding the month of the flight to be current, never about
   losing currency. So if you have some other way to legally log these approaches etc., then you seem to fulfill currency requirements again. To me it seems that the legislators didn’t consider this corner case. (On the other hand, the wording is “for the instrument privileges to be maintained”, which suggests continuity.)

   As for scenario 2, I agree now that the only way to regain currency after the “grace period” is an IPC, since this is spelt out explicitly. But scenario 1, regaining currency in the grace period, is still unclear to me.

   I agree that this is a mostly academic question, but perhaps of some interest to foreign private pilots with an FAA IR. Instrument flying is very expensive in many countries, and maintaining several instrument ratings with different currency policies (all of which might require some sort of IPC) can be a pain if not flying IFR very regularly. Being able to fly IFR in a temporal pattern that optimize the maintenance costs might be helpful in that case (if safety is still considered, of course).

   ———————————————————————————————————-

   FAR 61.57(c)(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, 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–

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3. Best Answer
   
   

   
   

   John D Collins on Mar 01, 2014

   Using your terminology, in the grace period there is no prohibition on regaining currency by using your UK privileges. The main prohibition is on using your FAA licence to act as PIC in IMC. So, for example, if there is another pilot on board that has IMC privileges and is acting as PIC, but you are the sole manipulator of the controls on an IFR flight conducted in IMC, you can log any approaches, holds, etc. and these count towards your currency requirements. The other pilot in this case is not a safety pilot, he is acting as PIC. In your scenario, you are not using your FAA certificate to fly IFR in IMC and any approaches would count towards FAA currency. IOW, it doesn’t matter how you completed the requirements in the grace period, as long as the flight was legal and you performed the approaches. For the FAA license to be used to regain currency, another pilot is required, either a safety pilot or a current pilot. Using your UK licence privileges should work.

   As an aside, there is an FAA general counsel opinion that if the flight is conducted in IMC and there is an instrument instructor providing instruction to a pilot who is the sole manipulator of the controls, any approach conducted by the pilot counts towards their currency and towards the currency requirements of the instrument instructor CFII.

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4. 
   

   
   

   Zonker on Mar 01, 2014

   Great, that clarifies it for me. Thanks a lot, John!

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