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6 Answers

61.57 wording re: instrument currency (first 6 months, second 6 months)

Asked by: 3028 views , , , ,
FAA Regulations, General Aviation, Instrument Rating

I've been through some of the other questions regarding instrument currency in the regs, and I gathered the information together and dumbed down the regulation so even I can understand it, so I'd like to run it past the readers here and see if I thoroughly understand how the regulation is interpreted.  We all know from our IFR training how to be legal to fly under IFR we need to have done 6 approaches, holding, and intercept/tracking within the last 6 months, and if that lapses we then have another 6 calendar months to get that experience in the air with a safety pilot or on the ground in an approved simulator.  But it's that second 6 months that seems so hard to find in the regs.  For reference: 61.57 (c) Instrument experience. Except as provided in paragraph (e) of this section, a person may act as pilot in command under IFR or weather conditions less than the minimums prescribed for VFR only if:

  • (1 thru 6) Within the six calendar months preceding the month of flight [the experience needed within the last 6 calendar months in an aircraft, simulator, glider, etc.]
61.57(d): 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.   Here's what I got.  Paragraph (c) refers to the block of time with the status of the pilot being current for IFR, ie. either the present day or the final day of instrument currency (if currency is expired) spanning back to when the requirements for that currency were first met.  The six calendar months that paragraph (d) refers to would then be the span of time where the pilot is trying to get back into that status of being current as specified in (c).  So basically, paragraph (d) is saying, "here's what you need to do if you take more than 6 calendar months to get back into that block of time where you're current like it says in (c)."   So, is that the correct way for the regulation to be interpreted in order to find the source of the first and second 6-month block for gaining currency before an IPC is needed?  To make sense of it I had to draw a picture with arrows.   I tell ya', it was a lot easier to figure out in the old regs.  The edition of 61.57 (d) from 1999 says, "...a person who does not meet the instrument experience requirements of paragraph (c) of this section within the prescribed time, or within 6 calendar months after the prescribed time, may not serve as pilot in command under IFR..."  That's a lot easier to understand!

6 Answers



  1. Mark Kolber on Jan 16, 2016

    But it would be wrong. You cannot act as PIC under IFR during the second 6 months. Your rewrite sounds like you can.

    The only thing the second 6 months does is allow us to regain currency without an IPC.

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  2. davidgrantcfi on Jan 16, 2016

    I was just reviewing this section the other day. The first section is about maintaining currency, and Mark Kolber is correct; the second six month is merely for regaining currency, and none of those holds, approaches, tracking and intercepting can be accomplished in IMC. You need a safety pilot, or in a simulator a CFII.

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  3. John D Collins on Jan 17, 2016

    David,

    If one does not meet the currency requirements, but does not yet require an instrument proficiency check. the prohibition is only on acting as PIC while operating under IFR or IMC. The point is, there must be a pilot who can act as PIC under these circumstances, but the non current pilot can be the sole manipulator of the controls and perform the necessary approaches and holds that count towards currency. So pilot A has lapsed IFR currency, but does not require an IPC as the only means of meeting currency. Pilot B is IFR current and acts as PIC for the flight. An IFR flight is conducted where Pilot A is the sole manipulator of the controls and makes an approach under actual instrument conditions. Pilot A can count the approach towards meeting their currency requirements.

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  4. Skyfox on Jan 18, 2016

    Funny, when I wrote this question I had all the formatting looking correct in the preview, but now that it\’s published everything is jumbled and makes it hard to read. Oh well.

    Mark, my rewrite never implied acting as PIC in IFR during the second 6 months, or at least I didn\’t intend that meaning when I wrote it. I did note in the first paragraph how it\’s common knowledge that a safety pilot is needed in the second 6 months. My rewrite (which I put together in my mind as a way of figuring out where they get the second 6 months) basically reduces the regulation to saying, \”You\’ve gone past part A [the block of being current], so you have part B [the second 6 months for flying with a safety pilot] in order to return yourself to part A before you are required to move on to part C [the IPC].\” Like I said, I had to really dumb it down for myself.

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  5. Mark Kolber on Jan 18, 2016

    John is correct. The only prohibition during the second six months is that we may not act as PIC on a flight under IFR. That leaves a lot of choices including flying with a CFI, flying under the hood under VFR, even flying under IFR and in the clouds with a friend who agrees to act as PIC.

    Mark, my rewrite never implied acting as PIC in IFR during the second 6 months, or at least I didn\’t intend that meaning when I wrote it.

    I guess that’s the problem with rewrites. What you think makes sense might not be as obvious to others. And yes, I agree with your basic premise that the FAA messed up when it rewrote a reg that most folks understood in order tho clarify it. In fact, the FAA pretty much admits it – the 2012 Whistman Interpretation is one that was written to calrify the clarification. 🙂

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  6. Skyfox on Jan 21, 2016

    Thanks for the reference to that interpretation letter, Mark, but it actually seems to confuse matters more. It says:

    This letter of interpretation makes clear that the correct interpretation of the language of
    §61.57(d) is that a pilot must perform the instrument recent flight experience required by §61.57(c) within 12 calendar months of the last date that the pilot was able act as PIC under IFR or weather conditions less than the minimums prescribed for VFR.

    That makes it sound like there is a 12 month window where someone can go up with a safety pilot to get current because up until the end of the initial 6 months that pilot is still able to act as PIC under IFR and/or in IMC. It takes some alert reading to notice that 61.57(c) includes simulated instrument flight, which means under the hood with a safety pilot, but it still doesn’t make a distinction between being a pilot who’s legal to fly PIC in IFR/IMC, who happens to be going up for some practice under the hood with a safety pilot, and a pilot who is expired on currency and has only the option of simulated instrument with a safety pilot (or using a FTD, etc.) because there is no legal option of going up for actual IFR in actual IMC. It’s that distinction I’m trying to find in the regs so I (well, we all) have the ability to understand and describe it clearly. We know it’s there since it’s in the training and is spelled out in the Instrument Flying Handbook (FAA-H-8083-15B), but in the regs it’s very elusive.

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