Recent experience required for IFR
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Recent experience required for IFR
Under the Japanese regulation, the required minimum recent flight experience for IFR is 6 hours of instrument flight experience (including simulator flight) over the 180 days preceding the date of flight maneuvers.
In these awful days, because of the lack of flights this binding is becoming a concern for us.
Long time ago at the ground school I was taught these regulations were adapted from FAA. However I found FAA no longer require 6 hours, instead it requires experiences of 6 instrument approaches, holding and etc nowadays.
Could anyone please teach me the history and/or background of change of this requirement?
I am also curious about other countries' equivalent requirements.
Thanks in advance,
In these awful days, because of the lack of flights this binding is becoming a concern for us.
Long time ago at the ground school I was taught these regulations were adapted from FAA. However I found FAA no longer require 6 hours, instead it requires experiences of 6 instrument approaches, holding and etc nowadays.
Could anyone please teach me the history and/or background of change of this requirement?
I am also curious about other countries' equivalent requirements.
Thanks in advance,
Last edited by firstmrj; 27th Jun 2020 at 14:40.
I don't know the reason that the Japanese use six hours of flight time, doing what? I just think that in those cases like you are presenting here that, quite simply, the law is the law and the law is an ass!
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https://www.govinfo.gov/content/pkg/...ml/97-7450.htmRecent Instrument Experience
Summary of proposal/issues: The FAA proposed to revise the
instrument recency of experience requirements of Sec. 61.57 by
eliminating the requirement for 6 hours of flight in actual or
simulated instrument conditions every 6 months. For aircraft other than
gliders, the proposal required that a pilot, within the preceding 6
calendar months, perform and log at least six instrument approaches;
holding procedures; intercepting and tracking of very high frequency
omnirange (VOR) radials and nondirectional beacon (NDB) bearings;
recovery from unusual flight attitudes; and flight by reference to
instruments. The preamble to the NPRM stated that these maneuvers and
procedures would not be required to be performed in actual or simulated
instrument flight conditions.
Comments: More than 385 comments were received on this issue. The
comments reflect widely disparate opinions. More than 200 comments
express clear opposition to the proposal. Nearly as many comments take
issue with parts of the proposal, and propose variations to it.
Approximately 60 comments agree with the proposal. Some commenters
indicate that they believe the proposal would make it more difficult
and costly to remain current for operations under IFR. One commenter,
however, says he believes the proposal will permit pilots who do not
fly as frequently to stay current and
[[Page 16227]]
continue to have access to the IFR system.
GAMA supports the elimination of the minimum hour requirement for
instrument currency. GAMA, however, believes that a minimum of 50
percent of the time spent performing maneuvers should be in actual or
simulated instrument flight conditions, or in an approved flight
simulator or flight training device.
In its comment, ALPA expresses concern regarding several aspects of
the proposed instrument currency requirements. According to ALPA, the
requirement for the use of NDBs may not be practical because NDBs are
being removed from service. The commenter also believes that there
should be an option to allow operations using the global positioning
system (GPS). Although ALPA agrees with the need for unusual attitude
training, the commenter states that there needs to be FAA guidance on
practice methods and procedures. ALPA also contends that recency of
experience maneuvers should be performed in either instrument or
simulated instrument conditions.
NAFI opposes specifying the use of any particular equipment, such
as VORs and NDBs, for instrument currency and suggests the requirement
should simply be for ``navigation by reference to instruments.'' It is
NAFI's position that unusual attitude training is appropriate for
flight reviews, not currency requirements, and should not be performed
without a safety pilot.
NATA opposes several aspects of Sec. 61.57. The commenter contends
that unusual attitude maneuvers belong in instrument training and BFR
requirements, not in instrument currency requirements. NATA also
believes that the requirement that VORs and NDBs be used for several
tasks is too restrictive. NATA recommends that the tasks be performed
``with the available navigational technology.'' NATA, however, supports
requiring six approaches rather than the 6 hours for currency.
In its comments, NBAA recommends that the number of approaches for
currency purposes should be left at 6 rather than 12, as noted in the
preamble to the NPRM. NBAA also contends that references to VORs and
NDBs should be deleted because these navigational aids are rapidly
becoming obsolete. In addition, the commenter opposes unusual attitude
training.
AOPA comments that the elimination of the 6 hours of required
instrument time will benefit general aviation economically. The
commenter also finds the requirement for six approaches to be an
acceptable minimum for proficiency. With regard to holding procedures,
the association has no strong objection to the proposal but questions
the need for such a requirement. AOPA states there is no current safety
problem in this area and, except for airline pilots, holding procedures
are rarely encountered. Also, according to AOPA, it is not appropriate
to specify the types of navigational aids that should be used for
instrument currency because of the transition to newer technologies
such as GPS. AOPA also points out that many aircraft are not equipped
with an ADF receiver. The commenter objects to the requirement for
unusual attitudes currency for the same reasons expressed by NAFI. Like
ALPA and GAMA, AOPA believes that the instrument currency procedures
should be performed in either actual or simulated conditions. The
commenter states that if the FAA does not intend to require flight in
actual or simulated conditions, Sec. 61.57(c)(2) should be clarified to
prevent varying interpretations of the rule. AOPA also strongly
supports the use of simulators and flight training devices, including
some PC-based simulators, for currency and proficiency.
Like many of the other commenters, HAI objects to the requirement
for recovery from unusual attitudes. The commenter also states that
commercial or corporate pilots will not be able to maintain currency in
the normal course of flight because of the proposals. HAI supports
eliminating the 6 hours of instrument time for currency, but proposes
deleting holding procedures and unusual altitude currency, and changing
the requirement to track VORs radials and NDB bearings to
``intercepting and tracking electronic navigation aids.''
Comments from individual commenters, for the most part, agree with
the positions advanced by the associations.
FAA Response: After consideration of the comments, the FAA has
decided to withdraw the requirement for recovery from unusual
attitudes. The FAA agrees with commenters who point out that practicing
these maneuvers would require a safety pilot and increase the cost of
maintaining instrument proficiency with only questionable safety
benefits.
In addition, the FAA has determined that the requirement for
intercepting and tracking VOR radials and NDB bearings should be
modified. The final rule requires pilots to intercept and track
``courses through the use of navigation systems.'' As noted by the
commenters, advances in air navigation technology support deleting the
reference to specific navigation systems. The FAA maintains that
requiring completion of specific training tasks, such as intercepting
and tracking courses and holding procedures, provides a safety benefit
by improving operational currency and the proficiency of pilots. For
this reason, the final rule includes the requirement for holding
procedures. The proposed requirement for six approaches also is
incorporated into the final rule.
The FAA has decided to retain the current requirement that the
tasks to meet recent instrument experience requirements be performed
and logged under actual or simulated instrument conditions. This
requirement can be met in an aircraft of the appropriate category, in
an approved flight simulator, or a flight training device that is
representative of the aircraft category.
As proposed in the NPRM, the final rule will not include a minimum
hour requirement to meet instrument currency. The elimination of this
requirement will provide pilots economic relief by permitting currency
requirements to be completed in less time.
Other proposed changes to Sec. 61.57 are discussed in the section-
by-section analysis of Sec. 61.57.
Summary of proposal/issues: The FAA proposed to revise the
instrument recency of experience requirements of Sec. 61.57 by
eliminating the requirement for 6 hours of flight in actual or
simulated instrument conditions every 6 months. For aircraft other than
gliders, the proposal required that a pilot, within the preceding 6
calendar months, perform and log at least six instrument approaches;
holding procedures; intercepting and tracking of very high frequency
omnirange (VOR) radials and nondirectional beacon (NDB) bearings;
recovery from unusual flight attitudes; and flight by reference to
instruments. The preamble to the NPRM stated that these maneuvers and
procedures would not be required to be performed in actual or simulated
instrument flight conditions.
Comments: More than 385 comments were received on this issue. The
comments reflect widely disparate opinions. More than 200 comments
express clear opposition to the proposal. Nearly as many comments take
issue with parts of the proposal, and propose variations to it.
Approximately 60 comments agree with the proposal. Some commenters
indicate that they believe the proposal would make it more difficult
and costly to remain current for operations under IFR. One commenter,
however, says he believes the proposal will permit pilots who do not
fly as frequently to stay current and
[[Page 16227]]
continue to have access to the IFR system.
GAMA supports the elimination of the minimum hour requirement for
instrument currency. GAMA, however, believes that a minimum of 50
percent of the time spent performing maneuvers should be in actual or
simulated instrument flight conditions, or in an approved flight
simulator or flight training device.
In its comment, ALPA expresses concern regarding several aspects of
the proposed instrument currency requirements. According to ALPA, the
requirement for the use of NDBs may not be practical because NDBs are
being removed from service. The commenter also believes that there
should be an option to allow operations using the global positioning
system (GPS). Although ALPA agrees with the need for unusual attitude
training, the commenter states that there needs to be FAA guidance on
practice methods and procedures. ALPA also contends that recency of
experience maneuvers should be performed in either instrument or
simulated instrument conditions.
NAFI opposes specifying the use of any particular equipment, such
as VORs and NDBs, for instrument currency and suggests the requirement
should simply be for ``navigation by reference to instruments.'' It is
NAFI's position that unusual attitude training is appropriate for
flight reviews, not currency requirements, and should not be performed
without a safety pilot.
NATA opposes several aspects of Sec. 61.57. The commenter contends
that unusual attitude maneuvers belong in instrument training and BFR
requirements, not in instrument currency requirements. NATA also
believes that the requirement that VORs and NDBs be used for several
tasks is too restrictive. NATA recommends that the tasks be performed
``with the available navigational technology.'' NATA, however, supports
requiring six approaches rather than the 6 hours for currency.
In its comments, NBAA recommends that the number of approaches for
currency purposes should be left at 6 rather than 12, as noted in the
preamble to the NPRM. NBAA also contends that references to VORs and
NDBs should be deleted because these navigational aids are rapidly
becoming obsolete. In addition, the commenter opposes unusual attitude
training.
AOPA comments that the elimination of the 6 hours of required
instrument time will benefit general aviation economically. The
commenter also finds the requirement for six approaches to be an
acceptable minimum for proficiency. With regard to holding procedures,
the association has no strong objection to the proposal but questions
the need for such a requirement. AOPA states there is no current safety
problem in this area and, except for airline pilots, holding procedures
are rarely encountered. Also, according to AOPA, it is not appropriate
to specify the types of navigational aids that should be used for
instrument currency because of the transition to newer technologies
such as GPS. AOPA also points out that many aircraft are not equipped
with an ADF receiver. The commenter objects to the requirement for
unusual attitudes currency for the same reasons expressed by NAFI. Like
ALPA and GAMA, AOPA believes that the instrument currency procedures
should be performed in either actual or simulated conditions. The
commenter states that if the FAA does not intend to require flight in
actual or simulated conditions, Sec. 61.57(c)(2) should be clarified to
prevent varying interpretations of the rule. AOPA also strongly
supports the use of simulators and flight training devices, including
some PC-based simulators, for currency and proficiency.
Like many of the other commenters, HAI objects to the requirement
for recovery from unusual attitudes. The commenter also states that
commercial or corporate pilots will not be able to maintain currency in
the normal course of flight because of the proposals. HAI supports
eliminating the 6 hours of instrument time for currency, but proposes
deleting holding procedures and unusual altitude currency, and changing
the requirement to track VORs radials and NDB bearings to
``intercepting and tracking electronic navigation aids.''
Comments from individual commenters, for the most part, agree with
the positions advanced by the associations.
FAA Response: After consideration of the comments, the FAA has
decided to withdraw the requirement for recovery from unusual
attitudes. The FAA agrees with commenters who point out that practicing
these maneuvers would require a safety pilot and increase the cost of
maintaining instrument proficiency with only questionable safety
benefits.
In addition, the FAA has determined that the requirement for
intercepting and tracking VOR radials and NDB bearings should be
modified. The final rule requires pilots to intercept and track
``courses through the use of navigation systems.'' As noted by the
commenters, advances in air navigation technology support deleting the
reference to specific navigation systems. The FAA maintains that
requiring completion of specific training tasks, such as intercepting
and tracking courses and holding procedures, provides a safety benefit
by improving operational currency and the proficiency of pilots. For
this reason, the final rule includes the requirement for holding
procedures. The proposed requirement for six approaches also is
incorporated into the final rule.
The FAA has decided to retain the current requirement that the
tasks to meet recent instrument experience requirements be performed
and logged under actual or simulated instrument conditions. This
requirement can be met in an aircraft of the appropriate category, in
an approved flight simulator, or a flight training device that is
representative of the aircraft category.
As proposed in the NPRM, the final rule will not include a minimum
hour requirement to meet instrument currency. The elimination of this
requirement will provide pilots economic relief by permitting currency
requirements to be completed in less time.
Other proposed changes to Sec. 61.57 are discussed in the section-
by-section analysis of Sec. 61.57.
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Check Airman,
Thanks a lot.
This is exactly I wished to know.
It is a shame our regulatory body hasn't kept up with any of these amendments for a few decades.
And I think it's nonsense for us to suffer from these meaningless requirement.
Very pity consequences of the bureaucracy and the evil virus.
Thanks a lot.
This is exactly I wished to know.
It is a shame our regulatory body hasn't kept up with any of these amendments for a few decades.
And I think it's nonsense for us to suffer from these meaningless requirement.
Very pity consequences of the bureaucracy and the evil virus.
