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And one other thing to keep in mind. Looking at paragraph (c), unlike landing currency that references 90 days, this paragraph uses calendar months. So if you flew an approach on July 1st, and then one approach each month Aug to Dec, you are current through Jan 31st, not Jan 1st.

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What to take away from this thread: Just because an instructor says something does not mean it is correct. (says the CFII)

Folks, as one who just completed an IPC (I was still current by the way), it is actually easier to take an instructor up and do the IPC than it would be to cram in 6 approaches!  Couple of reasons.  1

Correct.  “In summary, this new wording makes no significant change to the experience requirements. What has changed is the fact that currency can be maintained using a flight simulator, FTD or ATD

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58 minutes ago, HXG said:

If you look online at the FAA electronic FARs, the more recent list of date changes are not included  at the end of FAR 61.57 for some reason. But, changes were clearly made since then. The actual FARs text is current, updated and correct. 

My ASA Paper copy FAR AIM 2020 has a much longer list of changes with dates from April 4, 1997 thru June 27, 2018. I like that the ASA paper copy has vertical bold lines adjacent to updated text for easy identification. 

OK, I looked at this again. I got the citation from eCFR which should have the most current text of the regulation: https://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title14/14tab_02.tpl

However, upon looking again, I found this footnote after the revision history: 

Editorial Note: For Federal Register citations affecting §61.57, see the List of CFR Sections Affected, which appears in the Finding Aids section of the printed volume and at www.govinfo.gov.

I've never seen that before in a reg (but then I've never looked this closely either). I prowled around www.govinfo.gov a bit and found several citations that all seemed to be minor editorial changes or corrections. Maybe someone on MS has a better understanding of how this works.

But, the fact remains that you have 6 calendar months to reestablish currency before you need an IPC. You can do this with an instructor or with a safety pilot so long as you are not pilot in command under IFR or in IMC (because you are not current).

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15 hours ago, Joe Larussa said:

Okay, I must be brain dead. My last IPC check was July 18th 2019. Plane was down for 3 months between annual and new paint job, so not much flying period. Not one approach. Do I need an IPC check or can I go out with a safety pilot and get it done?

Joe, you have until the end of June to regain your currency with a safety pilot (or CFI or CFII if you choose). If you haven't regained currency by the end of June, you will need an IPC to regain currency. In any case you may not file IFR as PIC until you are current again.

Hope that helps clarify.

Cheers,
Rick

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7 minutes ago, Joe Larussa said:

Okay, I must be brain dead. My last IPC check was July 18th 2019. Plane was down for 3 months between annual and new paint job, so not much flying period. Not one approach. Do I need an IPC check or can I go out with a safety pilot and get it done?

I'd say you can go out with a safety pilot while VMC, fly 6 approaches, and get at least one hold to become current. If you wait until July then you will need another IPC.

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4 minutes ago, Bob - S50 said:

I'd say you can go out with a safety pilot while VMC, fly 6 approaches, and get at least one hold to become current. If you wait until July then you will need another IPC.

That’s what I was hoping for. Not afraid of an IPC check but had something already lined up and CFII’s are getting hard to find that work weekends that aren’t slammed.

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9 minutes ago, Joe Larussa said:

Okay, I must be brain dead. My last IPC check was July 18th 2019. Plane was down for 3 months between annual and new paint job, so not much flying period. Not one approach. Do I need an IPC check or can I go out with a safety pilot and get it done?

The IPC makes you IFR current for the next 6 Calendar months. But, you will need to meet the instrument experience in paragraph (c) to be current to fly IFR after that. So, if you haven’t met the 6 approaches etc. or simulator requirements in the past 6 months and another 6 months has lapsed since your experience met the requirements, an IPC (as apposed to simulator or safety pilot approaches) is your only option to regain IFR currency.  

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12 hours ago, Bob - S50 said:

 

And one other thing to keep in mind. Looking at paragraph (c), unlike landing currency that references 90 days, this paragraph uses calendar months. So if you flew an approach on July 1st, and then one approach each month Aug to Dec, you are current through Jan 31st, not Jan 1st.

 

I believe this to be correct.  July thru December is the the 6 calendar months “preceding”.  You would lose currency January 31st. 

“Within the 6 calendar months preceding the month of the flight,”

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18 hours ago, Joe Larussa said:

I had an instructor today in no uncertain terms tell me " The six month grace period no longer exists" 

If you are no longer current due to going passed your six months, you must have an IPC check, period!

That instructor is, in no uncertain terms, wrong. See the quote above from the FAA Chief Counsel opinion "clarifying the clarification."

Edited by midlifeflyer
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On 1/31/2020 at 2:08 PM, Joe Larussa said:

Good question!

The changes were about two years ago. I did an article on them in the September 2018 IFR Magazine. Looks like one of those available without a subscription.

http://www.ifr-magazine.com/issues/34_9/features/Finally-Revised-REGs_1487-1.html

 

Edited by midlifeflyer
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3 hours ago, HXG said:

Incorrect.  July thru December is the the 6 calendar months “preceding”.  You would lose currency January 1st. In typical FARs fashion, subtle changes can be confusing.

“Within the 6 calendar months preceding the month of the flight,”

The way I read that is this.  I'm flying in January.  The month preceding the month of my flight is December.  Looking back 6 months is July to December.

Guess we need a lawyer to interpret that part for us.

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16 minutes ago, Bob - S50 said:

The way I read that is this.  I'm flying in January.  The month preceding the month of my flight is December.  Looking back 6 months is July to December.

Bob, I think you are correct. That was my original understanding, but the article I quoted below confused me on that point with their commentary in the last paragraph I quoted below. 
 

“FAR 61.57 (c)(1)(2) in part says: “A person may act as pilot-in-command under IFR or weather conditions less than the minimum prescribed for VFR only if: (1) Use of an airplane, powered lift, helicopter or airship for maintaining instrument experience. Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered lift, helicopter, airship as appropriate for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view limiting device that involves having performed the following. (i). Six instrument approaches, (ii) holding procedures and tasks, (iii) intercepting and tracking courses through the use of navigational electronic systems.”

As a result of this wording, the pilot is considered to be current any time during this six-month period. Therefore, the non-current period begins after the initial six months. Further, FAR 61.57(d) states: “…a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check.” The key here is the fact that failure to meet the experience requirements begins after the initial six-month period in which the pilot is current by definition. Thus, a full twelve (12) months exist between the initial time and the need for an instrument proficiency check (IPC).

One needs to be aware of the statement “Within the six months preceding the flight.” This means that if you are planning to fly in December, the six months preceding ends in November. This is a change in how the months are counted.“

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12 hours ago, Bob - S50 said:

And one other thing to keep in mind. Looking at paragraph (c), unlike landing currency that references 90 days, this paragraph uses calendar months. So if you flew an approach on July 1st, and then one approach each month Aug to Dec, you are current through Jan 31st, not Jan 1st. 

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11 minutes ago, HXG said:

Bob, I think you are correct. That was my original understanding, but the article I quoted below confused me on that point with their commentary in the last paragraph I quoted below. 
 

“FAR 61.57 (c)(1)(2) in part says: “A person may act as pilot-in-command under IFR or weather conditions less than the minimum prescribed for VFR only if: (1) Use of an airplane, powered lift, helicopter or airship for maintaining instrument experience. Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered lift, helicopter, airship as appropriate for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view limiting device that involves having performed the following. (i). Six instrument approaches, (ii) holding procedures and tasks, (iii) intercepting and tracking courses through the use of navigational electronic systems.”

As a result of this wording, the pilot is considered to be current any time during this six-month period. Therefore, the non-current period begins after the initial six months. Further, FAR 61.57(d) states: “…a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check.” The key here is the fact that failure to meet the experience requirements begins after the initial six-month period in which the pilot is current by definition. Thus, a full twelve (12) months exist between the initial time and the need for an instrument proficiency check (IPC).

One needs to be aware of the statement “Within the six months preceding the flight.” This means that if you are planning to fly in December, the six months preceding ends in November. This is a change in how the months are counted.“

Ya, nothing like government lawyers to keep us guessing.  Lots of ways to read something.  Specific words and even punctuation can make a difference.  There is nothing like an example to make things more clear.

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8 minutes ago, Volare said:

I wonder how Continuing Qualification programs under Part 121 fit into this discussion? I would assume they meet the requirements since this is a Part 61 issue and everyone has to conform, until Part 91 stuff which might not apply. Any ideas?


(d) Instrument proficiency check. (1) Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check. 

e) Exceptions. (1) Paragraphs (a) and (b) of this section do not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 125 when the pilot is engaged in a flight operation for that certificate holder if the pilot in command is in compliance with §§125.281 and 125.285 of this chapter.
(2) This section does not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 121 when the pilot is engaged in a flight operation under part 91 or 121 for that certificate holder if the pilot in command complies with §§121.436 and 121.439 of this chapter.
(3) This section does not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 135 when the pilot is engaged in a flight operation under parts 91 or 135 for that certificate holder if the pilot in command is in compliance with §§135.243 and 135.247 of this chapter. 

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Thanks for that PT20J.

So my understanding of what you posted above, if you work for an Air Carrier, you can do Part 91 and 121 stuff for them using the pilot proficiency requirements of §§121.436 and 121.439 and ignore the Part 61 stuff.

But if you are playing around in your Mooney on your days off, that 121 stuff doesn't really apply. And you'll have a whole other set of Part 61 currency requirements to concern yourself with.

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Thank goodness for that John Collins link! Thanks Bob!

I just did 6 approaches in a ATD to regain my currency in the grace period...had me worried for a minute but since my IPC was in June '19, I am good to go!

Here's that response from John Collins...

    The regulation reads in part:

“Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane”

On June 16 you are still current, in fact you are current until midnight on June 30. What are the six calendar months “preceding the month of a flight on June 30” or for that matter any day in June. They are (counting backwards) May, April, March, February, January, and December. You have six approaches in that period, in fact, you could have done them all on December 1, and you would still be current on June 30.

Quoting again from the regulation in part “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.”

If you did not fly any further approaches, July 1 would be the first day you weren’t current. So if you didn’t get yourself current by flying simulated approaches, you would accumulate 6 calendar months since you were last current in July, August, September, October, November, and December. So you could regain currency up until December 31 by flying simulated instrument approaches. On January 1, you will need an IPC to regain currency if you haven’t done so using the simulated instrument approaches in this scenario as you have for more than 6 calender months failed to reestablish instrument currency."

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1 hour ago, Captain Bash said:

Thank goodness for that John Collins link! Thanks Bob!

I just did 6 approaches in a ATD to regain my currency in the grace period...had me worried for a minute but since my IPC was in June '19, I am good to go!

Here's that response from John Collins...

    The regulation reads in part:

“Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane”

On June 16 you are still current, in fact you are current until midnight on June 30. What are the six calendar months “preceding the month of a flight on June 30” or for that matter any day in June. They are (counting backwards) May, April, March, February, January, and December. You have six approaches in that period, in fact, you could have done them all on December 1, and you would still be current on June 30.

Quoting again from the regulation in part “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.”

If you did not fly any further approaches, July 1 would be the first day you weren’t current. So if you didn’t get yourself current by flying simulated approaches, you would accumulate 6 calendar months since you were last current in July, August, September, October, November, and December. So you could regain currency up until December 31 by flying simulated instrument approaches. On January 1, you will need an IPC to regain currency if you haven’t done so using the simulated instrument approaches in this scenario as you have for more than 6 calender months failed to reestablish instrument currency."

I don’t understand why some are so confused by this regulation. Maybe it’s because 61.57 is so long. Maybe it’s because the requirements for currency and IPC are in separate sections. Maybe it’s the term “calendar months.” 

Anyway, at the risk of prolonging the discussion :), I will point out that if you only flew 6 approaches in the ATD, you are still not current. You must perform and log the following:

(i) Six instrument approaches.
(ii) Holding procedures and tasks.
(iii) Intercepting and tracking courses through the use of navigational electronic systems.

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Just now, PT20J said:

I don’t understand why some are so confused by this regulation. Maybe it’s because 61.57 is so long. Maybe it’s because the requirements for currency and IPC are in separate sections. Maybe it’s the term “calendar months.” 

Anyway, at the risk of prolonging the discussion :), I will point out that if you only flew 6 approaches in the ATD, you are still not current. You must perform and log the following:

(i) Six instrument approaches.
(ii) Holding procedures and tasks.
(iii) Intercepting and tracking courses through the use of navigational electronic systems.

Skip

Thanks, yeah I did the hold on a missed and tracking accomplished tracking from a VOR to an intersection.

:)

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8 minutes ago, ilovecornfields said:

FIFY

 

17B41ECC-08D4-4D41-AA8F-E052FD2782A5.jpeg

I'm studying for my Commercial ACS right now.

Explaining the difference between currency and proficiency has made that image even funnier!

:lol:

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34 minutes ago, Captain Bash said:

I'm studying for my Commercial ACS right now.

Explaining the difference between currency and proficiency has made that image even funnier!

:lol:

I have a commercial oral prep sheet I’d be happy to share if you want to send me a PM. I think the real value was in making it but it might serve as a good starting point if you want to make your own.

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