New FAA currency requirements

MSmith

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Mark Smith
What do you think of the newly proposed FAA instrument currency requirements?

  • 6 approaches, at least one precision and one non-precision
  • a complete holding pattern at a radio station
  • a complete holding pattern at an intersection or waypoint
  • One hour of simulated (or actual?) cross country practice operation that involves intercepting and tracking courses through the use of navigation systems while performing a takeoff phase, area departure phase, enroute phase, area arrival phase, approach phase, and a missed approach phase of flight.

If you use a simulator or authorized pc device (approved, with trained instructor), you also have to do:

  • one steep 180-degree turn in each direction
  • 2 "usual altitude" maneuvers in a descending Vne condition
  • 2 "usual altitude" maneuvers in an ascending stall speed condition
  • 6 precision approaches
  • 6 non-precision approaches

You can combine a simulator with an airplane, but then you have to do the entire requirement for the simulator PLUS one hour in the plane.
 
Interesting. I am wondering why the big emphasis on holds? Has there been a bunch of hold errors that have resulted in incidents? The XC idea is interesting.
 
What do you think of the newly proposed FAA instrument currency requirements?
  • 6 approaches, at least one precision and one non-precision
  • a complete holding pattern at a radio station
  • a complete holding pattern at an intersection or waypoint
  • One hour of simulated (or actual?) cross country practice operation that involves intercepting and tracking courses through the use of navigation systems while performing a takeoff phase, area departure phase, enroute phase, area arrival phase, approach phase, and a missed approach phase of flight.
Hmm. Can I use WFDK (or whatever the AM station is) to do an NDB hold? It's a radio station, after all.

All told, this isn't too onerous. When I do my currency flight, I generally visit at least three airports, so I get the cross-country practice in as well, even if they're not that far apart. I wonder if having your safety pilot/CFII acting as ATC and giving you home-made missed approach instructions would meet the letter of the rule here, or if they expect you to follow a published procedure.
 
It's not all that surprising, given the number of folks who boggle up the IFR system on a regular basis -- and I've heard it happening on the radio more times than I can remember. It's going to be a lot trickier to keep track of in your log than the old requirements, and it does make much clearer the FAA's real intent on the "intercepting and tracking" item, one which engendered a great deal of mirth over the years -- like, how can you fly an approach without intercepting and tracking a course, so why have the requirement in addition to the six approaches? Now we know what they really wanted.
 
Looks like there are gonna be a lot more pilots getting IPCs.
 
Interesting. I am wondering why the big emphasis on holds? Has there been a bunch of hold errors that have resulted in incidents? The XC idea is interesting.


Yeah, it seems to me if you can do an intersection hold, you can do a hold over a station.
 
I hate to say it, but there really are too many people out there who goof up when the weather gets low. Most of the time they manage not to kill themselves or others, but in the best case they do, as Ron says, "...boggle up the IFR system...". In the worst case, they mangle lots of aluminum (or plastic) and people.

Personally I plan to stay on my every six months comp check plan. I've been alternating between the airplane and a Frasca FTD with the large field of view visual display to get the best of both worlds. Keeps me sharp, it's more fun than just making a hamburger run to warm up the oil, and it's easier to track currency that way!

Jay
 
Looks like there are gonna be a lot more pilots getting IPCs.

That's the glass-is-half-full view.

I wonder if it won't mean more non-current IFR pilots in the system? Your average pilot seems to be so cheap that an extra hour of CFI time is like the cost of the gold in Fort Knox. How many will say "Oh forget it, I can handle it!"

I was out with a CFI on Tuesday. I wasn't pleased with my performance (not bad, I just know I can do better.) Forget every 6mos, I'm going to shoot for every 2months, regardless of currency.
 
That's the glass-is-half-full view.

I wonder if it won't mean more non-current IFR pilots in the system? Your average pilot seems to be so cheap that an extra hour of CFI time is like the cost of the gold in Fort Knox. How many will say "Oh forget it, I can handle it!"

I was out with a CFI on Tuesday. I wasn't pleased with my performance (not bad, I just know I can do better.) Forget every 6 mos, I'm going to shoot for every 2 months, regardless of currency.
I'm not surprised this came up given the number of accidents and deaths from botched approaches. Most of the time, investigations reveal the pilot was not current. Over Christmas weekend alone, there were four in Charleston, SC; Atlanta, GA and Chattanooga, TN resulting in thirteen deaths.

I got a call today from a guy asking me to be safety pilot for him on Sunday. I'll have to ask if this might have prompted him.

I don't have a problem with the requirements. If you're not going to remain proficient, what good was getting the ticket?
 
Here's the link to the full NPRM:
http://www.aopa.org/whatsnew/newsitems/2007/070207part61-nprm.pdf or
http://edocket.access.gpo.gov/2007/pdf/E7-1467.pdf
and the press release:
The Federal Aviation Administration (FAA) has issued a notice of proposed rulemaking (NPRM) that would amend the training, qualification, certification, and operating requirements for pilots, flight instructors, ground instructors, and pilot schools. These amendments have been proposed in order to clarify, update, and correct existing federal aviation regulations. These amendments are intended to ensure that flight crewmembers have the training and qualifications to enable them to operate aircraft safely. One significant proposal under this notice involves pilot and flight instructor training and qualifications for operating with night vision goggles.
Comments are due on or before May 8, 2007, and should be identified by the docket number FAA-2006-26661. Comments may be submitted on the DOT Docket Web site at http://dms.dot.gov/, by mail, or hand delivery at Docket Management Facility, U.S. Department of Transportation, 400 Seventh Street SW, Nassif Building Room PL-401, Washington, D.C. 20590-0001, or by facsimile at 202-493-2251. For further information contact Mr. John Lynch, of the FAA’s Certification and General Aviation Operations Branch, by telephone at (202) 267–3844, or email at john.d.lynch@faa.gov.
The name of the contact is somewhat familiar! :)
 
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The only issue I see is the enroute phase. A lot of my flights are direct from here to a long ways away. Since I do DPs and STARs from my home airport all the time; those are a non-issue. There aren't many cross country areas to which I fly where I need to be on airways. Some of the STARs and DPs go pretty far out. I don't understand the need to be fly on airways to be proficient; the skill set for the STAR and DP takes the same set of skill and is much more demanding. I don't understand two holds either, but it shouldn't be a big deal. I've never been given an actual hold; all have been in the sim or under the hood.

Still, I understand the need for more than in the current system. There are a lot of folks that just don't seem sharp on instruments and with their radio procedures. I sat behind a guys a while back that just couldn't get his clearance down. Several of us just sat as the guy blundered back and forth with ground trying to get it right. When he did depart in front of me, he didn't make proper calls and departure had to go back and forth with him several times while we all waited to make our routine calls. After my flight I called the tower chief and suggested he ask a guy to stand by if he couldn't get his departure after a couple back and forths so all the rest of us didn't have to burn fuel while ground taught school.

Best,

Dave
 
Wow. This is a comprehensive rewrite. Rewriting the section on adding a type to an ATP certificate in an a/c not capable of instrument flight....this one will take a while to digest.
 
While I may not agree or disagree with most of it, I can see what they're after - except for the holds on a radio station. A hold is a hold is it not? I don't understand this one unless there is a different definition of a "radio station".

P.S. I'm sitting in an airport waiting for my flight and don't have full access.
 
While I may not agree or disagree with most of it, I can see what they're after - except for the holds on a radio station. A hold is a hold is it not? I don't understand this one unless there is a different definition of a "radio station".

P.S. I'm sitting in an airport waiting for my flight and don't have full access.

If they are planning to shut down the VORs and NDBs relying on GPS for most enroute navigation, will there even be any "radio stations" to hold over?
 
First, they ain't gonna shut down the VOR's before the next Part 61 rewrite comes out in 2015.

Second, holding at the station is definitely different than holding at an intersection, primarily due to the dramatic difference in CDI sensitivity and response close to and over top of the station.

Third, the part I don't understand is the requirement that you get "simulated cross-country practice." As I read it, just flying IFR (even in the weather) doesn't count, and that doesn't make sense.
 
First, they ain't gonna shut down the VOR's before the next Part 61 rewrite comes out in 2015.

Probably right, though it doesn't seem to make much sense to make changes that ignore GPS now.

Second, holding at the station is definitely different than holding at an intersection, primarily due to the dramatic difference in CDI sensitivity and response close to and over top of the station.

If you are flying with a GPS there's really no difference at all. The proposed regulation doesn't seem to preclude that.

Third, the part I don't understand is the requirement that you get "simulated cross-country practice." As I read it, just flying IFR (even in the weather) doesn't count, and that doesn't make sense.

The actual proposed rule (vs the explanation that preceeds the rules) doesn't include the "simulated cross-country flight" phrase. That phrase does show up in the proposed rules for meeting the currency requirements in simulators, FTDs, and PCATDs.
new 61.57 c 1 (iii):
FAA said:
One hour of cross-country flying that involves intercepting
and tracking courses through the use of navigation systems, performing
a takeoff, area departure, enroute, area arrival, approach, and missed
approach phase of flight.
The rule itself also doesn't seem to require that all those tasks be performed in one flight like the explanation does. Hopefully the rule is closer to the intention than the explanation WRT both issues.

This requirement seems pretty useless to me given that it appears in the section on meeting currency requirement in a simulator, FTD, or PCATD. With the possible exception of a true full motion simulator, none of these are realistic enough to make unusual attitude training at all beneficial IMO. And what exactly is a "usual altitude recovery" anyway? I assume that is supposed to be unusual attitude but I can't help thinking the person writing these down doesn't have a clue what they were writing about. Also while it is possible to be in an ascending, stall speed condition for a little while I think that part needs a lot of work as well.
new 61.57 c 4 (ii) E:
FAA said:
Two usual altitude recoveries while in a descending,
Vne airspeed condition and two usual altitude recoveries
while in an ascending, stall speed condition.
And here's my favorite bit of nonsense:
new 61.57 c 5 (ii): (or is it 'g' 5?)
FAA said:
Three hours of instrument experience using a view-limiting
device in a flight simulator, flight training device, or a personal
computer aviation training device
Why in the world would anyone need a view limiting device in a sim? To prevent peeks at the floor?

On the holding thing, I still don't get why the FAA thinks people need to log holds. For one thing, nothing says the practice needs to be done well. And every practice hold could be done on the radial you are currently flying inbound to the station/waypoint on making the entry and hold so simple that you might as well not even bother doing it.

So now I need a new logbook with a column for holds over "radio stations" and another for holds over intersections. And would it count if the "radio station" was off the air and I was using GPS?

Given the convoluted requirements if you elect to fly some of this in a PCATD and some in an airplane, I have to wonder if the real goal of the change is to make it far more likely that pilots will end up inadvertently flying without being legally current.
 
The new emphasis on holds is because that is what you will be in while they copy down your credit card number before your clearance to land is issued.
 
If you are flying with a GPS there's really no difference at all. The proposed regulation doesn't seem to preclude that.
Ron Levy said:
Second, holding at the station is definitely different than holding at an intersection, primarily due to the dramatic difference in CDI sensitivity and response close to and over top of the station.
Maybe requiring a user-programmed waypoint if GPS is used?

Fly safe!

David
 
First, they ain't gonna shut down the VOR's before the next Part 61 rewrite comes out in 2015.

Second, holding at the station is definitely different than holding at an intersection, primarily due to the dramatic difference in CDI sensitivity and response close to and over top of the station.

Third, the part I don't understand is the requirement that you get "simulated cross-country practice." As I read it, just flying IFR (even in the weather) doesn't count, and that doesn't make sense.

As we've seen in the past, what the intent of the regs are (John Lynch does a good job with this) and what the regs actually say (whoever translates this into the gobbledygook we end up with sucks at it) are two different things.

Like you, I read this as requiring IFR pilots to go do dedicated flying for proficiency in sim instrument conditions, even if they spend all their flying time in actual IMC.

Unless John's completely lost his mind, I don't think that's what it's supposed to say.
 
As we've seen in the past, what the intent of the regs are (John Lynch does a good job with this) and what the regs actually say (whoever translates this into the gobbledygook we end up with sucks at it) are two different things.

Like you, I read this as requiring IFR pilots to go do dedicated flying for proficiency in sim instrument conditions, even if they spend all their flying time in actual IMC.

Unless John's completely lost his mind, I don't think that's what it's supposed to say.

One more time: The actual proposed reg doesn't require simulated anything for currency, that language appears in the "explanation" of the proposed regs and in the paragraphs that apply to the use of sims and the like to meet currency.

There is no requirement for simulated instrument flying to meet currency, you can do it all in an airplane in actual IMC per the proposed regs.
 
some of us out in the boonies will have to do some traveling to get to a precision appr... no biggie.
Honestly, I think adding more rules wont result in less crashes, but it will result in more pilots who are not legal. That's their job, they have to do something however.
 
Well like I said above I get an IPC every 6 months regardless. I think its actually less expensive and you get more out of it than just going up to do the currency work. Ed Guthrie turned me on to this. Nuthin like getting with your CFII twice a year!!
 
What do you think of the newly proposed FAA instrument currency requirements?
  • 6 approaches, at least one precision and one non-precision
  • a complete holding pattern at a radio station
  • a complete holding pattern at an intersection or waypoint
  • One hour of simulated (or actual?) cross country practice operation that involves intercepting and tracking courses through the use of navigation systems while performing a takeoff phase, area departure phase, enroute phase, area arrival phase, approach phase, and a missed approach phase of flight.

Sounds pretty much like what I do for my training anyway. Take off from 9D9, GPS at Y70, 2 GPS at 6D6 the second one with a hold, VOR 17 at GRR, ILS 8R, 26L, or 35 at GRR, VOR 12 with a hold at the VOR back to 9D9. Hood/Foggles go on while on the runway, and I tip my head just enough to see two stripes. Hood/Foggles don't come off until I am on short final at the home drome. Takes about 1.5 hours to do it, and of course all of them are a missed except the last one.

Sounds like I don't need to do anything else than I normally do.
 
Sounds pretty much like what I do for my training anyway. Take off from 9D9, GPS at Y70, 2 GPS at 6D6 the second one with a hold, VOR 17 at GRR, ILS 8R, 26L, or 35 at GRR, VOR 12 with a hold at the VOR back to 9D9. Hood/Foggles go on while on the runway, and I tip my head just enough to see two stripes. Hood/Foggles don't come off until I am on short final at the home drome. Takes about 1.5 hours to do it, and of course all of them are a missed except the last one.

Sounds like I don't need to do anything else than I normally do.
Ed, PLEASE tell me you have a safety pilot with you! There's no mention of one in your scenario.
 
I think they're missing something: A circle to land. As Tony noted in the other thread, it is "an often botched manuever in actual conditions."
 
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