Guidance for FAA IR currency requirements?

[Contacttower]

I wonder if someone could help me with the interpretation of the FAA's IR currency requirements?

It's not so much that I don't understand the requirements but more that I want to make sure that not only do I meet the requirements but that I have all the necessary records in my logbook to say so...

For instance with the six approaches the FARs state that they must be conducted in simulated or actual conditions; now many approaches involve passing through actual at some point of another but rarely do they involve being in actual all the way to 200ft...I know this sounds pedatic but how much actual do you think the FAA thinks you need in order for the approach to qualify?

Also if you are flying on your own how do the FAA know you have done the approaches during a particular flight you say you have? I did some ILS approaches under the hood with an instructor a while ago and got him to sign my logbook and I also wrote in the runway number and approach type as a record to say that I had done these approaches during the flight. But does the FAA require this and if not how else are you supposed to record your currency?

I'd be very greatful if someone could just provide some general guidance on this.

[IO540]

This one has done the rounds of U.S. pilot forums many times.

To be legal, you have to comply with the wording of the FARs - that's it!

Some things are not well defined. For example, one could read the reg as requiring a hold to be flown each time. That is meaningless in practice because one rarely gets to fly a hold, and if you asked for a hold every time to fly to Big Airport X they would get a bit miffed.

Obviously, to be safe, you need to practice in realistic conditions, but how exactly you do that is up to you, and it will depend on the plane and the equipment. For example, I hand fly approaches if in IMC, for the practice, but approaches in VMC I always fly coupled, on autopilot, to regularly ensure that the gear all works, because in any tight spot one would sure as hell use all automation at one's disposal. Manual flight under real-life pressure or an emergency is for fools, and checkrides :)

[Contacttower]

Thanks IO. What are the names of some of the US forums that it's been discussed on?

[IO540]

It was thrashed in Usenet, years ago. I guess google groups might index it up. Rec.aviation.*

But in the end, the law is the FARs (http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgFAR.nsf/MainFrame?OpenFrameSet).

[chrisbl]

As you have to pay for approaches in this country I get the airport to detail the approaches done on the landing fees invoice - name of pilot, aircraft reg etc. I just keep the invoices proving the six approaches with my log book and remove the oldest as I do a new one.


If ever there was a ramp check, independent invoices is a good backup to entries in the log book.

It is not that difficult in the UK. In the US it is more difficult as you dont pay for anyhting there is very little proof.

[IO540]

I would think that any airport with ATC (and any IAP needs ATC at present, in the UK) would keep logs anyway.

Occassionally, the Inland Revenue attacks a pilot for proof of flights put down to his business. He then has to approach the airports for the logs.

I don't claim to fly anywhere near as many hours as some do ;) - do about 150/year average - but I still manage to clock up about 4x to 5x the required 6/6 currency. So this would not be a problem for most people flying regularly, I would guess.

[englishal]

It is not really a problem anyway. Even if you fell out of currency in the UK but had a UK IMCr (2 year validity) you could revalidate yourself in IMC in a G reg in thmonths 6-12 Or take a safety pilot and do it in VMC or failing that and you went over 12 months, find an FAA CFII and either do the approaches in the aeroplane or on a sim.

Once per year when I go to the USA I do an FAA IPC for my own benefit, which also has the benefit of revalidating my IMCr when I get home.....

[Cusco]

I have had problems keeping the 'rolling six approaches in six months' in the past:

If I run out of currency I do an IPC which then re-boots the IR.

If I go to US, most FBOs demand an IPC (andBFR) anyway.

I tend to keep my IMC rating (which I gained independently eons before the FAA/IR) current in its own right by the biennial check as I've never bothered to 'link' it with the IR.

Would be easier I guess if I was based at a commercial airport with its own ILS etc..

Cusco

[S-Works]

SAt here idly musing. A question I have not thought off before, but holding dual IR's would a JAA LPC serve to reset the FAA IR currency?

[IO540]

I tend to keep my IMC rating (which I gained independently eons before the FAA/IR) current in its own right by the biennial check as I've never bothered to 'link' it with the IR.I don't think the IMCR is ever linked as such to the FAA IR.

All that happens is that, if you have an FAA IR, and also have a UK/JAA PPL and a CAA Class 1/2 medical, you can send

- evidence of an FAA IR IPC within past 2 years, and

- a cheque for some £70 or so

to the CAA and they issue you with an IMCR.

I believe that IMCR is then a real IMCR in every way which you can renew either with the usual 25-monthly check flight, or by following the above 2-step procedure again.

The catch is that many N-reg owners have let their old CAA PPL/medical lapse (no longer needed) and they cannot get the IMCR that way.

The other catch is that the CAA disregards the FAA IR 6/6 rolling currency so if you want the IMCR you have to do the FAA IR IPC, with an FAA CFII. Given that so many UK based FAA IR holders did once have the IMCR, it is a vaguely interesting debate whether keeping the IMCR valid with the above 2-step route (which implies having to get an FAA CFII for the IPC, and if you pay him, and do it in an N-reg you need the DfT permission) is easier than simply revalidating the IMCR which I believe can be done with any JAA instructor (or perhaps even with a PPL/CRI which are common but cannot charge for the flight).

[S-Works]

which I believe can be done with any JAA instructor (or perhaps even with a PPL/CRI which are common but cannot charge for the flight).

Nearly right, but just to clarify.

The IMCR is revalidated by an examiner at the 25 month test. This examiner can be a CRE or FE. The CRI is not a PPL qualification, just like the FI it can be held by PPL or CPL. For a CRI to be a CRE they must hold or have held a Professional Licence.

[Cusco]

I don't think the IMCR is ever linked as such to the FAA IR.


IO:

Perhaps I could have put it more clearly:

What I meant was I keep the 'revalidations' of IMCR and FAA/IR entirely separate i.e. I don't try (because I don't even know if it's possible) to use a recent FAA IPC as a means of revalidating the IMCR as I approach the end of the 24/5 months.

Equally, when re-validating FAA/IR and doing my 6 approaches I am flying my G reg on my FAA/Piggy back PPL/IR not my UK CAA/PPL/IMCR.

If that makes sense.

Complicated , innit?

Cusco.:ugh:



Cusco

[IO540]

There appears to be no doubt that flying the 6/6 approaches in some G-reg, solo, using the privileges of the IMCR, will keep the FAA IR valid.

The FARs do not require an N-reg plane for anything whatsoever (of relevance).

There also appears to be no doubt that flying the 6/6 approaches in some G-reg, under the hood, with an instructor or with a safety pilot, in VMC, thus avoiding the need to have any then valid instrument qualification, will also keep the FAA IR valid. (Actually the FAA IR is itself valid for IFR in a G-reg (ref ANO art 26) but only at a Class G airport).

So one could play it in different ways.

It's definitely worth not running out of the 6/6 rolling currency because then you get this hassle.

I know some FAA PPL/IR holders who rarely fly (no plane, no money, etc) and who do a combined BFR+IPC every 2 years. The problem with that is that they aren't legit for IFR in the last 18 months of those 2 years.

[chrisbl]

Going back to the OP - just keep your landing charge invoices.

[Contacttower]

Many thanks to all those who have contributed. The keeping of invoices sounds like a good idea, although as it happens the airport that I'm often using doesn't charge for ILS approaches if you're a club member.

I keep all flying invoices anyway....and in the absence of those I suppose a logbook entry will have to do. Although as IO540 points out ATC will keep logs as well.

I think I'm happy. :)

[S-Works]

What's up with just doing it as required and making the entry in your logbook?

It is very British to create a problem where non exists.

All the FAA requires is for you to enter the approach details in your log book.

I have never had an entry in my log book questioned nor have I felt the need to question the entries in anyone else's logbook.

The laws against falsifying a logbook entry are sufficient to prevent abuse. I seem to recall with the CAA it's something like a grand a line for a false entry?

[IO540]

Inventing logbook entries is very bad. Very very bad. Exceedingly poor form.

Which is why it would be best to not suggest anybody might be doing this, because the mods here sure as hell won't be deleting a thread as quickly as the mods elsewhere did a month or ago ;) ;) ;) ;)

[youngskywalker]

Just to be clear, in the UK, ATC will only keep a record of your flight details for 3 months - The paper flight strips are then binned. It's possible that the airport authority will keep a record for charges, but for how long I'm not sure.

At NATS airports you wont even get a mention the the 'logbook' unless you have an 'incident!'

[S-Works]

Inventing logbook entries is very bad. Very very bad. Exceedingly poor form.

Which is why it would be best to not suggest anybody might be doing this, because the mods here sure as hell won't be deleting a thread as quickly as the mods elsewhere did a month or ago

I don't think anyone has suggested that anybody might be doing this, if you read my comment I am making the point that all you need to do is record the entries in your logbook as required under regulation. Nothing more is needed as the penalty for falsifying a logbook entry is so steep.

The laws against falsifying a logbook entry are sufficient to prevent abuse. I seem to recall with the CAA it's something like a grand a line for a false entry?

[Julian]

What's up with just doing it as required and making the entry in your logbook?

It is very British to create a problem where non exists.

All the FAA requires is for you to enter the approach details in your log book.


Fully agree Bose, otherwise you would end keeping every receipt for every flight you had ever made.

Just make the logbook entry. I do an IPC every year no matter how many approaches have made and never had anyone raise questions on my logbook because of no receipts!

J.

[n5296s]

It's worth bearing in mind that the FAA operates in the US, and in the US the whole concept of paying for approaches is completely unheard of. You can fly the ILS at SFO or JFK all day long and not pay a cent, as long as you go missed at DA each time round and never land. (Although I expect approach at some point would figure out what you were up to and start refusing you). And if you go to a more GA-reasonable airport you can fly the approaches AND LAND all day long and not pay a cent. The controllers will like you for it because you're increasing their traffic and hence potentially their income. (I doubt that places like Stockton would even have a tower if they weren't so popular for instrument training).

So the FAA certainly isn't going to ask to see your receipts, because they'd fall off their chairs if they even heard that such a thing existed.

As many others have said, just put it in your logbook and sign the bit at the bottom about being a truthful record. I don't think you can be fined in the US for a false logbook entry, but you can certainly be busted and lose your licence - it has happened several times.

n5296s