New and improved instrument currency question--now with graphics!

Jim_R

Jim_R

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Jim
So I went back and re-read FAR 61.57(c), and I think I had misunderstood the timing requirements.

So I want to make sure I understand properly. The two graphics below represent two pilot logbooks. To keep it simple, let's assume that neither pilot has allowed their IR currency to lapse for more than 6 months such that an IPC is required, and that all approaches / holds were done per 61.57(c).1 (i.e., in an airplane, either in actual IMC, or in simulated IMC with a safety pilot).

The first picture below is the simple case...the "git 'er dun" way to stay legally current. There's no controversy there, right?

The second is some poor GA pilot who's trying to get a few approaches here and there, and occasionally lapses out of currency and climbs back in.

So: Is the second picture correct?

(I have a couple of follow-on questions once I'm sure I've got this part right, but I'll hold those for now.)
 

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I would say yes. Since the currency requirements are based on a period of 6 calendar months per 61.57, you have up until the end of the sixth month (in this case July).
 
Just think lookback rather than expiration and you'll see #2 is also good to go for holding and approaches on Oct 31. IOW, on Oct 31, Pilot 2 can look back through the six preceding calendear months and find six approaches and holding. However, what I do not see in either example is any entry of the performance of interception and tracking of nav courses, which per a Chief Counsel interpretation not long ago must also be explicitly logged.
 
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Ron Levy said:
However, what I do not see in either example is any entry of the performance of interception and tracking of nav courses, which per a Chief Counsel interpretation not long ago must also be explicitly logged.
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How does one fly any approach without intercepting and tracking a nav course?
 
Okay, you got me. But if that's your answer, then why is it not sufficient to log "flew RNAV 13" or "ILS 27"? Those approaches require intercepts and nav tracking...there's no way to accomplish them otherwise.
 
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Ron Levy said:
Jwhich per a Chief Counsel interpretation not long ago must also be explicitly logged.
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I would think that simply logging an approach at my home field would count. The only published approaches available are either GPS or ILS
 
I agree with both of the above, and that's the way everyone was doing it for many years. Then someone decided they needed to have it in writing and asked the Chief Counsel, and the Chief Counsel said otherwise.

Moral of the story: If you can't stand the answer, don't ask the question.
 
Jim_R said:
Okay, you got me. But if that's your answer, then why is it not sufficient to log "flew RNAV 13" or "ILS 27"? Those approaches require intercepts and nav tracking...there's no way to accomplish them otherwise.
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I think the answer to that is an insight into "legal documentation".
Your example would require the specific technical knowledge that "ILS", or "VOR" means, or assumes, interception and tracking.
The required entries should indicate completion of a requirement in absolute black-and-white legible print with your legible signature, without any "assuming", or "figuring".
Most legal experts would agree that most of our normal logging procedures fall way short of "courtroom evidence".
We've just been gettin away with it,..until someting happens.
 
Ron Levy said:
I agree with both of the above, and that's the way everyone was doing it for many years. Then someone decided they needed to have it in writing and asked the Chief Counsel, and the Chief Counsel said otherwise.
Click to expand...
Reference? I can only find one Chief Counsel opinion that even has intercepting and tracking referred to, and that one discusses the need for a CFII when using a device.
 
nosehair said:
I think the answer to that is an insight into "legal documentation".
Your example would require the specific technical knowledge that "ILS", or "VOR" means, or assumes, interception and tracking.
The required entries should indicate completion of a requirement in absolute black-and-white legible print with your legible signature, without any "assuming", or "figuring".
Most legal experts would agree that most of our normal logging procedures fall way short of "courtroom evidence".
We've just been gettin away with it,..until someting happens.
Click to expand...

And there's always the possibility that someone could come up with a new angle that had not been previously considered. For example, it would be possible to log an ILS without intercepting a course if ATC gave you no-gyro vectors to get you on course and pointed in the right direction, and then you tracked the approach course to completion on your own. That would satisfy the tracking requirement without satisfying the interception requirement.
 
Okay, so I went down the rabbit hole and allowed my own thread to drift full-deflection away from the needle-centered focus I wanted it to have: Ensuring that I understood the timing requirement correctly.

Dismissing the no-doubt-important nuances of exactly how to write all this stuff down in the logs (eventually, I might want to get back to that), I now want to explore the question of what else besides flight in an aircraft satisfies the currency requirements.

First, I am going to create a definition:

this combination of symbols: 6AH+INTT
shall mean for the remainder of this thread, "6 approaches, holding procedures and tasks, and intercepting and tracking courses through the use of navigational electronic systems"

So when I read 61.57(c), it seems that I can do 6AH+INTT either (1) all in an airplane, (2) all in a flight simulator / flight training device, or (3) all in an ATD (plus some additional requirements that I don't care about because I won't use an ATD). So far, there's no discussion of mix-and-match.

But then parts (4) and (5) attempt to talk about options for mix-and-match, but they don't make any sense to me.

Part (4) seems to say if I want to use a combination, then I have to do 3 x 6AH+INTT: once via airplane, once via flight sim or FTD, and once via ATD! There's no "or" between the parts (i), (ii), and (iii) in part (4)!

Similarly, part (5) looks like 2 x 6AH+INTT, once with a flight sim/FTD, and once with an ATD (plus some extra stuff).

So, if I do 3 approaches (plus int and nav tracking) in the plane in actual IMC, then do 3 more approaches and a hold in an approved flight training device with a CFII, I can't confidently point to the FAR and say I'm legally current.

Am I missing something here?
 
That part of 61.57(c) is currently under FAA review to make it easier to understand. Beyond that, good luck.
 
Hah! Well, okay...at least that tells me I'm not the only one who's unsure. Thanks.
 
You're not, Jim. I'm one of those who doesn't buy into the "the regs never make sense" thing. But from the first reads on it when it first went into effect, they really messed it up. A number of people noticed exactly what you did. Between that, the currency "clarification" about the second 6 months, and the "forgotten reg" on the need for a CFII when doing currency in a device, one almost has to wonder what the author of the instrument currency revisions was doing when he should have been writing and thinking.
 
midlifeflyer said:
You're not, Jim. I'm one of those who doesn't buy into the "the regs never make sense" thing. But from the first reads on it when it first went into effect, they really messed it up. A number of people noticed exactly what you did. Between that, the currency "clarification" about the second 6 months, and the "forgotten reg" on the need for a CFII when doing currency in a device, one almost has to wonder what the author of the instrument currency revisions was doing when he should have been writing and thinking.
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Whatever he was thinking, he has since retired.
 
thats how its always been . . . I'm not seeing any confusion -

within the last 6 calendar months not counting this one, you need to satisfy the recency of experience rules - they need to make it harder - like no use of autopilots in the hold . . etc
 
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comanchepilot said:
I'm not seeing any confusion
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Oh, good. Then you can explain to me the purpose of 61.57(c), parts (4) and (5).

I.e., why would I want to satisfy the currency requirements via part (4) by flying 18 approaches and 3 holds in three different contraptions, when parts (1) and (2) let me satisfy the requirements with only 6 approaches and 1 hold in one contraption?
 
Part of the reason might be that some contraptions are more expensive to operate than others.
 
But when (4) makes you fly all the contraptions, it'll always be cheaper to choose (1) or (2) that only make you fly one of the contraptions.
 
midlifeflyer said:
Reference? I can only find one Chief Counsel opinion that even has intercepting and tracking referred to, and that one discusses the need for a CFII when using a device.
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I'd like to see that reference too, because I'd like to be able to cite it.
 
I suspect Ron made a mistake on that. But that said, when a reg specifies certain tasks as a requirement, it is generally the better practice to include it in the logged information.
 
midlifeflyer said:
I suspect Ron made a mistake on that. But that said, when a reg specifies certain tasks as a requirement, it is generally the better practice to include it in the logged information.
Click to expand...
I'm working on it. However, it may have been a Regional Counsel rather than the Chief Counsel. But as Mark notes, it is plain language in the reg.
 
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