IFR Currency 61.57(c) - No Grace Period Anymore?

[Transsonic2000]

Hi there,

as the headline states, I remember in the past, if one allowed his IFR currency to lapse in the first 6 month, it was possible to get current again in the following 6 month (grace period) with a safety pilot by shooting 6 approaches, holding etc. under the hood (simulated IFR). But I just discovered that the current Regs. 61.57(c) don't mention anything about a "grace period" anymore? Does this mean there is no "second" six month period anymore, instead one needs to do an IFR proficiency check? Appreciate any infos in this regard! Thanks!

Source: http://www.ecfr.gov/cgi-bin/text-idx?SID=7402a2ba131a29f8774424d213729cfc&mc=true&node=se14.2.61_157&rgn=div8

[peekay4]

The 6-month "grace period" is still there.

Suppose you last did approaches in December, 2014. Then you are current for the following 6 calendar months, until midnight June 30, 2015.

On July 1, 2015, you are not current anymore. For the next six months (until December 31, 2015) you can regain currency by doing approaches, holds, etc., with a safety pilot. This is the "grace period": you have six months to regain your currency.

But if you didn't renew your instrument currency by December 2015, then on January 1, 2016 you've been out of currency for 6 months (since July 1, 2015). It's now more than 12 months since you last did approaches. In this case, per 61.57(d) you must now pass an Instrument Proficiency Check to become current again.

[Transsonic2000]

Hi and thanks for your reply so far!

You're referring to 61.57 (d) the current regs say:
(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.

Source: eCFR ? Code of Federal Regulations (http://www.ecfr.gov/cgi-bin/text-idx?SID=7402a2ba131a29f8774424d213729cfc&mc=true&node=se14.2.61_157&rgn=div8)

I happen to have an old FAR/AIM (2009) and it said:
(d) Instrument proficiency check. Except as provided in paragraph (e) of this section, a person who does not meet the instrument experience requirements of paragraph (c) of this section within the prescribed time, or within 6 calendar month after the prescribed time, may not serve as PIC under IFR or in weather conditions less than the prescribed minimums for VFR until that person has passed an instrument proficiency check...

The addition of "or within 6 calender month after the prescribed time" is not stated in the current regs anymore, this makes me think/believe that there is no additional 6 month (grace period) to get current again with a safety pilot? Perhaps somebody can shed some light on this, or please correct me if I'm completely mistaken.

[MarkerInbound]

The wording changed from when you can renew your currency without the IPC to when you need an IPC. Before "within the prescribed time or within 6 calendar months after..." you could get yourself current with a safety pilot. Now if you have "failed to meet the instrument experience requirements ... for more than 6 calendar months" you must have an IPC. There is no requirement for an IPC if you are only out of currency 5 months. You can still go up with a safety pilot and log the required approaches and hold or do the other sim/FTD means of getting current.

[peekay4]

The rule has not changed. The wording was changed to clarify the rule, as people were misinterpreting them. Of course it's easy to also misinterpret the new wording...

In the old wording, "within the prescribed time" means within the time you are current. In my example above, it's from December 2014 to June 2015.

After "the prescribed time" (after you are no longer current), you have 6 months to work with a safety pilot. In the above example, from July 2015 to December 2015. This is the "grace period".

Otherwise, if you are no longer current for more than 6 months, you have to take an IPC.

Here's the FAA guidance on the new wording (the "grace period" in bold):

In this technical amendment, the FAA
is revising the language in paragraph (d)
to clarify the intent of the rule. The
revised language makes it clear that a
pilot who has failed to maintain
instrument currency for more than six
calendar months may not serve as pilot
in command under IFR or in weather
conditions less than the minimums
prescribed for VFR until completing an
instrument proficiency check. A pilot
whose instrument currency has been
lapsed for less than six months may
continue to reestablish instrument
currency by performing the tasks and
maneuvers required in paragraph (c).

http://www.gpo.gov/fdsys/pkg/FR-2011-12-16/pdf/2011-32333.pdf