Maintaining Instrument currency in the USA

[boofhead]

Tried this in the Flight Instructors forum but it died before I got an asnwer. Try again here?

Re FAR 61.57 (c) Instrument experience.

There is a new regulation. I am trying to see what it means. So far as using an airplane is concerned I see no change, you still need, within the last 6 months, the required approaches, holds and tracking. However I always thought that if you went more than 6 months you would need to do some training with a CFII in an airplane to become current again, and if you went more than 12 months you would need an instrument proficiency check ride. The way I read this, you could go 11 months and still regain your instrument experience by doing the approaches in an airplane on regular IFR flights, or with a safety pilot, then be good for another 6 months, never seeing a CFII. Am I right?

The next query is when using an ATD to maintain instrument experience. The new reg says that you can do this by flying 3 hours in the ATD, plus 6 approaches, a holding pattern, tracking plus four unusual attitude recoveries, all within the last 2 months. So if you were only using an ATD, you would have to do this every 2 months to remain current? And the ATD is not specified so any ATD would work for this (not necessarily a BATD for example, since this is not so specified in this regulation). True?

I also do not see any requirement to have a safety pilot or CFII when using the ATD, since this also is not specified. I remember the discussion last year and this point was raised then; if you don't need to have a CFII in an airplane, why would you need one in an ATD? I know that one is required when logging time in an FTD, but there is no such requirement for an ATD in the regs that I have found (if there is, please point me to it).


Then the final part that interests me, using a combination of airplane and ATD. I read that as being the easiest, in that one approach in the airplane and six in the ATD (plus the hold, tracking and UA training) will do you for 6 months.

How does this work? I guess that if I am going to fly IFR and see I don't have the required approaches and holds, I can go to my local ATD and fly the approaches, holds and tracking and be good to go. No CFII or minimum ATD time required.

Or have I missed something?

[411A]

The way I read this, you could go 11 months and still regain your instrument experience by doing the approaches in an airplane on regular IFR flights, or with a safety pilot, then be good for another 6 months, never seeing a CFII. Am I right?

Yes.

Can`t answer the rest, as I have never used an ATD...except a full motion simulator in airline training.

[MarkerInbound]

It seems the left hand and the right of the FAA do not talk to each other. What's new?

Buried in the final rule of 61.57 in the Federal Register:

A person would not need a flight instructor or ground instructor present when
accomplishing the approaches, holding, and course intercepting/tracking tasks of Sec. 61.57(c)(1)(i), (ii), and (iii) in an approved flight training device or flight simulator. Only when a person is required to
submit to an instrument proficiency check must a flight instructor or ground instructor be present.
The rationale is that a person is not required to have a flight instructor or ground instructor present when performing the approaches, holding, and course intercepting/tracking tasks in an aircraft. If the person is using a view-limiting device (i.e., hood device) when performing the approaches, holding, and course intercepting/tracking tasks in an aircraft, only a safety pilot is required to be present. If a person is performing approaches, holding, and course intercepting/
tracking tasks in an aircraft in IMC, it is permissible to log the tasks without a flight instructor being present.
Therefore, a person who is instrument current or is within the second 6-calendar month period (See Sec. 61.57(d) for currency) need not have a flight instructor or ground instructor present when accomplishing the approaches, holding, and course intercepting/tracking tasks of Sec. 61.57(c)(1)(i), (ii), and (iii) in an approved flight training device or flight simulator.


So I think you would need an instructor for the upset events since it just says you don't need one for the approaches and holding. (It's come up before that while you're shooting an approach, you are tracking a course.)

And yet 61.51 tells us an instructor must verify your ATD time for currency.

Pilot logbooks.

(g) Logging instrument time.
(4) A person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session.

[boofhead]

Too true. I always thought that under the old rules you would not need a CFII to sign off sim time since all you were logging is the approaches and not the time. Now you need to log the time if using an ATD.
The new rules (thanks for the info) make it simple and I see that a CFII is required to sign off any ATD work, time or approaches.

[MarkerInbound]

I'm not sure it would have to be a II. And the FAA gives guidance as to what having an instructor present means. They give examples of one instructor monitoring several students or even the instructor leaving the room for short period of time. (I can just see it, "Do the procedure turn to the ILS, miss and go the published hold. Your EFC will be when I get back.")