Part 61 changes

flyingcheesehead

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iMooniac
Just wondering if anyone's had a chance to review the proposed changes to Part 61 yet?

A few things caught my eye: (item number, reg number)

15) 61.31(d)(2) This reg is odd, and looking at the FAA's proposal to delete it, shouldn't even exist in the first place. "Supervised PIC?"

26) 61.51(e)(1)(iv) Yet another way to log PIC... By performing the duties of PIC while under the supervision of a qualified PIC. When I first read the summary, I thought maybe that would allow someone doing the "supervised solo" under 61.129(b)(iv) to log PIC but that doesn't appear to be the case. It looks like some kind of non-CFI training type of thing that won't really apply to us little guys.

30,31) 61.57 c,d,f,g

I can't really tell what the change is for when you need an IPC, or the currency period itself. :dunno: The rest of the changes are being discussed in "Cleared for the approach."

37) 61.65 d-f

10 hours of the 50 XC PIC time for an instrument rating must be in the category of aircraft for which an instrument rating is sought. For instance, if I was going to add Instrument-Helicopter I'd have to do at least 10 more hours of XC PIC in a helicopter instead of just counting airplane time. Makes sense.

57) 61.129(a)(3)(i) Clarifies what types of instrument training are required for commercial students but actually specifies a "view-limiting device." I may send a comment in on this, as training in actual IMC kicks the crap out of any view-limiting device.

62) 61.129(a)(3)(iii) et al This one's a biggie. It would allow the dual commercial cross countries to be performed either IFR or VFR, whereas right now they're required to be done VFR. I bet Ron Levy will chime in on this one! I dunno if I agree with their reasoning either (that many students are working on IR/Comm concurrently, so let them do the XC's IFR :dunno:). Odd.

64) 61.129(a)(4) et al would allow the solo XC requirements for all categories and classes to be CFI-"supervised" solo similar to how the multi requirements are now. They're claiming that insurance requirements have made this necessary, but IMHO any insurance carrier that demands an instructor aboard for a cross country needs to die, now.

73) 61.195(c) 1-2 would require any instrument training for commercial and ATP certificates be given by a CFII. Currently, a CFII is only required for doing instrument ratings.

What say y'all to these and the rest of the changes?
 
I think that last one is more of a clarification than something new, at least on the Commercial end. It's been the standard for quite a while that anything denominated as "instrument training" in Part 61 needs to be done by a CFII.

But my favorite is the one that will finally let ATPs log PIC time when only exercising private or commercial privileges. :D
 
I think that last one is more of a clarification than something new, at least on the Commercial end. It's been the standard for quite a while that anything denominated as "instrument training" in Part 61 needs to be done by a CFII.

But my favorite is the one that will finally let ATPs log PIC time when only exercising private or commercial privileges. :D

Huh? What stopped an ATP from logging PIC when flying his own airplane before? As I understand it, an ATP can log PIC the same as everyone else, PLUS when acting as PIC on an operation requiring an ATP, such as being a 121/135 Captain.
 
Huh? What stopped an ATP from logging PIC when flying his own airplane before? As I understand it, an ATP can log PIC the same as everyone else, PLUS when acting as PIC on an operation requiring an ATP, such as being a 121/135 Captain.

It was a boo-boo in the regs - it required that the person logging PIC time hold "a private certificate or a commercial certificate".
 
It was a boo-boo in the regs - it required that the person logging PIC time hold "a private certificate or a commercial certificate".
Yup. here's the current wording:
==============================
(e) Logging pilot-in-command flight time.
(1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person...

(2) An airline transport pilot may log as pilot-in-command time all of the flight time while acting as pilot-in-command of an operation requiring an airline transport pilot certificate.
==============================

It sounded like the only time an ATP could log PIC was when acting as an ATP.

Its probably taken care of by another reg (61.167(a)) that gives ATPs all privileges of a commercial pilot, but it was a funny omission that made for the odd discussion topic.
 
I'm still scratching my head about the one requiring the use of a view-limiting device when logging instrument time in a PC-ATD. I'm also surprised that only "simulated cross-country practice" counts towards the new version of the IFR currency rule -- as it appears, it seems actually flying under IFR doesn't count.
 
I'm still scratching my head about the one requiring the use of a view-limiting device when logging instrument time in a PC-ATD. I'm also surprised that only "simulated cross-country practice" counts towards the new version of the IFR currency rule -- as it appears, it seems actually flying under IFR doesn't count.

Huh? Head scratching is right -- anyone actually review these things for common sense before they're finalized?
 
I'm still scratching my head about the one requiring the use of a view-limiting device when logging instrument time in a PC-ATD. I'm also surprised that only "simulated cross-country practice" counts towards the new version of the IFR currency rule -- as it appears, it seems actually flying under IFR doesn't count.

Ditto on the first issue, the second doesn't actually appear in the rule itself. See my comment with quoted sections of the proposed rule in the other thread on this topic.

BTW why are there two threads going on it? Somebody want to merge them?
 
BTW why are there two threads going on it?

'cuz someone started one on the instrument currency only in the instrument forum. I moved the rest of the discussion here so the non-cloud-headed folks would get a chance to participate. ;)
 
I think that last one is more of a clarification than something new, at least on the Commercial end. It's been the standard for quite a while that anything denominated as "instrument training" in Part 61 needs to be done by a CFII.

... Except for the 3 hours required for private. Right? :dunno:
 
Oops, I misread this to think it was like the "Rewrite Part 91" thread. Maybe I'll start a new one instead...
 
Huh? Head scratching is right -- anyone actually review these things for common sense before they're finalized?
That's what the whole NPRM process is about - run it past us so we can point out all the problems, then clean up 80-90% of it in response to our comments, and make the remaining 10-20% even weirder.
 
'cuz someone started one on the instrument currency only in the instrument forum. I moved the rest of the discussion here so the non-cloud-headed folks would get a chance to participate. ;)

That would be me. Feel free to merge them.
 
That's what the whole NPRM process is about - run it past us so we can point out all the problems, then clean up 80-90% of it in response to our comments, and make the remaining 10-20% even weirder.
They're not supposed to be that messed up even in the NPRM (I've red plenty from a variety of agencies). The discussion is supposed to be about the policy decisions to require or not require certain things. We shouldn't be trying to figure out whether, to use one of Ron's examples, IFR currency would require

actual or simulated instrument flight on a simulated cross country (you don't have to do a real cross country, just all of the phases of one)

or

simulated instrument flight on a "real" cross country where you have to land an an airport other than where you started.

That's just sloppy - like there was a rush to get this out there.
 
... IFR currency would require

actual or simulated instrument flight on a simulated cross country (you don't have to do a real cross country, just all of the phases of one)

or

simulated instrument flight on a "real" cross country where you have to land an an airport other than where you started.

That's just sloppy - like there was a rush to get this out there.

Where is that in the proposed rule? I only see the confusing wording in the "explanation" that precedes the actual proposed rules.
 
Where is that in the proposed rule? I only see the confusing wording in the "explanation" that precedes the actual proposed rules.
The propose rule is (just the relevant portion):
(c) Instrument experience. Except as provided in paragraph (e) of
this section, no person may act as pilot in command under IFR or
weather conditions less than the minimums prescribed for VFR unless:
(1) Use of an airplane, powered-lift, helicopter, or airship for
maintaining instrument experience. Within the 6 calendar months
preceding a flight, that person performed and logged at least the
following tasks, iterations, and flight time in an airplane, powered-
lift, helicopter, or 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
performing the following--
(iii) 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.

So, it appears "simulated" isn't part of the reg other than in subparagraphs (2) and (3) pertaining to simulators/FTD's and PC-ATD's. Thus, any XC in actual instrument weather would cover you except for the missed approach.
 
does the proposed rule totally replace the current currency rule? If so does the proposed rule still include the glider IFR currency rules from the last writing?
 
does the proposed rule totally replace the current currency rule?

No, it's an edit. IIRC at the beginning of the summary they explain that this is a mid-cycle edit and that the next full rewrite is due for 15 years out from the last one, which I believe would be 2012.
 
Did this stuff go through now? It looks like 61.129 no longer specifies VFR for the commercial solo cross country...
 
Did this stuff go through now? It looks like 61.129 no longer specifies VFR for the commercial solo cross country...
As I mentioned in the other thread it has been written that way, sans VFR for the long XC, for at least three years. Actually I guess longer than three years as I got my commercial three years agoi and it was like that when I started.
 
As I mentioned in the other thread it has been written that way, sans VFR for the long XC, for at least three years. Actually I guess longer than three years as I got my commercial three years agoi and it was like that when I started.
Much longer than that. I did mine 14 years ago and that part has never changed.

Cheese, The issue with VFR was with the dual cross countries, not the long solo one.
 
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