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8 Answers

Another question regarding Instrument Currency – 61.57

Asked by: 5637 views , ,
FAA Regulations

I know this type of question has been asked many times, but hopefully, someone can clarify a portion of the 61.57 regulation that is a bit confusing to me.

Timeline:

Feb - 1 IAP

Mar - 2 IAPs

Apr - 1 IAP

May - 1 IAP

Jun - 1 IAP, Holding, Intercept & Tracking

Jul - No flying

Aug - No flying

I'm current to be IFR/PIC until Aug. 31st.

Beginning Sept. 1, I am no longer current to be IFR/PIC

Question:  If on Sept. 5th I conduct and log 3 IAPs with a safety pilot, will I be current under FAR 61.57 to conduct an IFR/PIC flight on Sept. 6th?

Discussion: If I look back the 6 calendar months (Aug, July, Jun, May, Apr, Mar)   "preceding" the month of the flight, which is planned for Sept. 6th, I have completed only 5 IAPs. Therefore,  the regulation [61.57 (c) & (d)], seems clear that I can't act as PIC under IFR even though I completed 3 IAPs with a safety pilot on Sept. 5th.

Additionally, it appears that I can't benefit for the purpose of regaining 61.57 IFR/PIC currency from the 3 IAPs I conducted with a safety pilot on Sept. 5th until October 1st. On October 1st, looking back the "preceding" 6 calendar months (Sept, Aug, July, Jun, May, April), I will have conducted 6 IAPs, plus the holding and intercept/tracking requirements.

I would appreciate a response to my question above as well as feedback on whether my understanding from the "Discussion" above is correct.

Thanks

 

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8 Answers



  1. Mark Kolber on Nov 17, 2018

    So, based on your read, if you do 8 IAPS and a hold on Seotember 5, you are not current until October.

    Why do people over-analyze simple phrases like “Within the 6 calendar months preceding the month of the flight” into nonsense?

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  2. R. Anderson on Nov 17, 2018

    Mark,

    I believe there is still confusion over this aspect of the rule because, based on the example in my question, there would be no way of the pilot becoming current for IFR/PIC in the month of September no matter how many IAPs, Holds, etc. he/she did with a safety pilot.

    Since the 6 month “look back” begins in the preceding month (which is Aug), Sept. IAPs can’t remedy a shortfall in currency requirements that occur prior to the month of the planned IFR/PIC flight.

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  3. Mark Kolber on Nov 17, 2018

    “I don’t personally understand” does not mean there isn’t a clear answer.

    The lookback doesn’t “begin in” the preceding month. The reg does not say that. It says you have to have accomplished certain tasks “within ” the preceding six calendar months. In English, that means beginning right now.

    Of course, if you want to read it that way for yourself and sit it out you are welcome to. You can also skip flying an airplane until the month after its delayed annual inspection, not fly until the month after your delayed medical, and wait until the month after your delayed flight review, since they all use the same “within the preceding” language. Don’t forget you also can’t hop into an airplane with passengers until the day after you reestablish passenger currency either.

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  4. Anderson on Nov 17, 2018

    Mark,

    61.57 (c.) (1.) states: \”…Within the 6 calendar months preceding the month of the flight…\”

    You say in your response \’…“within ” the preceding six calendar months. In English, that means beginning right now. \”

    The regulation says \”…preceding the month of the flight…\” This does not exactly say [to everyone anyway] that means \”beginning right now.\”

    In my question I was looking for some insight from others who may have addressed this specific issue. Your rather terse and cavalier response seems a bit inappropriate considering I was just looking for some reasonable feedback.

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  5. Mark Kolber on Nov 18, 2018

    I’m not sure how pointing out I think the language is pretty clear and giving examples of how your read would affect other regulations in the same unreasonable way is unreasonable.

    But if you think that having to wait a month after establishing currency to use it (in your and my examples) is a reasonable reading if the regulations, I guess we’ll have to agree to disagree.

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  6. Anderson on Nov 18, 2018

    Mark,

    I was asking a question and looking for feedback from others who may have pondered this same point. I am not advocating for an specific outcome or else I would not have felt the need to ask the question in the first place. The last sentence in my question is the basis for my inquiry.

    I personally don’t think it is reasonable (in my example) to be required to wait until the end of the month before the pilot would be legal for IFR/PIC under 61.57. But the paradox or ambiguity is rooted in the exact wording of the rule [61.57 (c) (1)]: Specifically, “Within the 6 calendar months preceding the month of the flight,…”

    (from my example) Suppose it’s Sept 1 and a pilot wants to take an IFR/PIC flight on Sept. 6. But when he looks back (counting the 6 calendar months preceding the month of the flight) he determines he is no longer IFR/PIC current because he has not accomplished 6 IAPs within that period (Aug – Mar).

    The very wording of the regulation that requires him to consider “Within the 6 calendar months preceding the month of the flight…”
    creates the ambiguity. Because, if he goes out and completes some IAPs with a safety pilot on, for example, Sept. 5th and then on Sept. 6th plans an IFR/PIC flight, the test of whether or not he is current is found in the same regulation. That is, looking at [61.57 (c) (1)], “Within the 6 calendar months preceding the month of the flight ….” Since the IFR/PIC flight is planned for Sept 6, and considering the 6 calendar months preceding the month of the flight, (the exact wording in the regulation), then the count going backwards would start in August, (which is the month preceding the month of the planned flight – Sept.).

    Finally, the look back count beginning in Aug. would yield the same insufficient number of IAPs (in my example) that made him non-current begining Sept. 1 in first place.

    Again, I don’t believe that the intended consequences of following 61.57 would result in a pilot having to wait until (in my example) Oct. to be IFR/PIC current again. But the exact wording of the regulation seems to lead to that interpretation for some. How to read and interpret it differently is the reason for my question.

    Thanks for taking the time to respond.

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  7. Russ Roslewski on Nov 18, 2018

    I’m with Mark.

    Of all the ambiguous regulations, this is not one of them. Although you say you are “not advocating for a specific outcome”, you sure are trying hard to contort the words of the regulations into that outcome.

    You say that “the exact wording of the regulation seems to lead to that interpretation for some.” Who are these “some” people? I’ve been flying for 25 years and have been a CFI for 6. I participate on many aviation forums, FB groups, and in-person events, and I have NEVER heard this “interpretation”, from anybody. And while that doesn’t mean I’ve heard all the questions possible, it does lead me to believe that you’re really trying hard here to make a question where none exists.

    I get it – you think the phrase “within the 6 calendar months preceding the month of the flight” means that the flights must be within those prior months, not within the current month. But, aside from being ridiculous, this is is clearly not what is intended. Otherwise, don’t you think that there would be all kinds of enforcement actions against practically every instrument-rated pilot?

    So, I’m not really sure what answer you’re looking for here. If you’re just looking for someone to agree with you that the wording is ambiguous, well, that won’t be me.

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  8. Anderson on Nov 18, 2018

    Russ,

    I will move on and this will be my last post on this subject.

    The wording of the regulation 61.57 [(c) (1)] prompting my question has been around for a while. Two of my colleagues brought this question up recently and that is what generated my specific interest in seeking input from others. I’m quite confident there have been other discussions, perhaps not many, in the aviation community regarding the particular wording I discuss in my question.

    Also, on this site (askacfi.com), I did a search before I posed my question and noted that a number of years ago a similar question addressing the same wording was asked. The person asking the question had reached the same conclusion about the wording of the regulation. Further, someone who responded also acknowledged that the wording indicated the same point I was raising in my question.

    The post I’m referring to above is entitled “Wording of Instrument Currency in 61.57,” and it is from March of 2012.

    Anyway, thanks for taking the time to respond.

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