61.58 type rating annual proficiency check due dates

[RussR]

I earned a type rating (my first and only) in January 2019. For various reasons, I am not using it currently but hope to in the near future.

61.58 requires an annual proficiency check.

61.58i says that if you take it the month before or the month after it is due, it counts as being done in the month it was due for purposes of determining when the next one is due.

So, if I go to recurrent training in December 2019, that's effectively the same as doing it in January 2020, and my next one would still be due in January 2021. Okay, this seems to reflect the FAA's acceptance that sometimes scheduling is hard and people who do it early shouldn't be punished by then having it due earlier the next year. That's nice.

If I do it in January 2020, of course, that's right on time.

I can also do it in February 2020. Now, I believe that for the purposes of acting as PIC, I would still be non-current as of Feb 1st, so wouldn't be able to act as PIC until I finished recurrent that month. But then my next recurrent would still be due in January 2021. Notice this is different than almost every other recurring requirement like flight reviews and annual inspections (like the popular 13-month annual).

1. I am curious as to the history of why this is. Any ideas?

Now, as mentioned I am not using my type rating as PIC right now. So if I wait until March 2020 to do my recurrent, that then falls outside of the provisions of 61.58i. I of course could not act as PIC until I went through recurrent, BUT I assume that the due date would then be reset for the next year, and it would not be due until March 2021.

2. Do I have this right?

Thanks all. New to this type rating stuff.

 

[Clip4]

Scheduling a annual proficiency check isn’t like completing a flight review. One has to coordinate with the person providing the check and the FAA basically provides a 90 day window.

 

[MauleSkinner]

I earned a type rating (my first and only) in January 2019. For various reasons, I am not using it currently but hope to in the near future.

61.58 requires an annual proficiency check.

61.58i says that if you take it the month before or the month after it is due, it counts as being done in the month it was due for purposes of determining when the next one is due.

So, if I go to recurrent training in December 2019, that's effectively the same as doing it in January 2020, and my next one would still be due in January 2021. Okay, this seems to reflect the FAA's acceptance that sometimes scheduling is hard and people who do it early shouldn't be punished by then having it due earlier the next year. That's nice.

If I do it in January 2020, of course, that's right on time.

I can also do it in February 2020. Now, I believe that for the purposes of acting as PIC, I would still be non-current as of Feb 1st, so wouldn't be able to act as PIC until I finished recurrent that month. But then my next recurrent would still be due in January 2021. Notice this is different than almost every other recurring requirement like flight reviews and annual inspections (like the popular 13-month annual).

1. I am curious as to the history of why this is. Any ideas?

It’s the same as 121 & 135 checks, and other “professional pilot” requirements. I assume that, as you said, scheduling issues can come into play that make the +/- window advantageous. The wording of the reg is that you are considered to have done it in your due month, so you can fly in February prior to your 61.58 just like you could if you had actually done it in your due month.

That does get into the whole issue of “what if I fly in February and don’t get my 61.58 done?” We had an interpretation (I don’t know at what level) for Part 135 that even if we didn’t get the checkride done we were still ok, as the late grace month would be treated as the due month in all respects.

As far as getting the check done in your late grace month, assuming you actually get it done,
Now, as mentioned I am not using my type rating as PIC right now. So if I wait until March 2020 to do my recurrent, that then falls outside of the provisions of 61.58i. I of course could not act as PIC until I went through recurrent, BUT I assume that the due date would then be reset for the next year, and it would not be due until March 2021.

2. Do I have this right?

Yes on resetting the due date. See above for how long you can fly prior.

 

[IK04]

Does this apply to a privately operated aircraft requiring a type rating flown under part 91?

I don't see a reference in 61.58 or subpart K...

 

[flyingron]

What do you mean by "this." 61.58 is pretty clearly applicable to part 91 operations. You get a month forward grace if you take it early.

If you mean the 90 day window, then you're right, it doesn't apply to part 91 (other than if you're using certain simulators).

 

[MauleSkinner]

Does this apply to a privately operated aircraft requiring a type rating flown under part 91?

I don't see a reference in 61.58 or subpart K...

61.58(b): “This section does not apply to persons conducting operations under subpart K of part 91, part 121, 125, 133, 135, or 137 of this chapter...”
What’s largely left are privately operated aircraft requiring a type rating flown under Part 91.

The reason it doesn’t apply to the regulations listed is that most of them (I’m not familiar with the requirements of 133 or 137) have identical provisions in the applicable section.

If you mean the 90 day window, then you're right, it doesn't apply to part 91 (other than if you're using certain simulators).

Where are you seeing that?

 

[flyingron]

(g)(3)(ii)

 

[IK04]

61.58(b): “This section does not apply to persons conducting operations under subpart K of part 91, part 121, 125, 133, 135, or 137 of this chapter...”
What’s largely left are privately operated aircraft requiring a type rating flown under Part 91.

The reason it doesn’t apply to the regulations listed is that most of them (I’m not familiar with the requirements of 133 or 137) have identical provisions in the applicable section

OK, so this is simply a substitute for the recurrent and line check requirements for those commercial (non-part 91)operators. Only subpart K of part 91 has separate provisions.

I've always been under public use laws per DoD for my annual evals per 61.58(d)(4), so as a private, non commercial operator, in order to act as PIC in a civil registered aircraft that requires more than one pilot flight crewmember, I would need to find someone who operates that aircraft, or hire another pilot to act as both a copilot and a "person authorized by the Administrator" to conduct the eval per subpart K.

 

[MauleSkinner]

OK, so this is simply a substitute for the recurrent and line check requirements for those commercial (non-part 91)operators. Only subpart K of part 91 has separate provisions.

I've always been under public use laws per DoD for my annual evals per 61.58(d)(4), so as a private, non commercial operator, in order to act as PIC in a civil registered aircraft that requires more than one pilot flight crewmember, I would need to find someone who operates that aircraft, or hire another pilot to act as both a copilot and a "person authorized by the Administrator" to conduct the eval per subpart K.

Subpart K (fractional ownership operations) is also treated as an air carrier. For private operations you could just find a DPE who has 61.58 authority for the type (assuming you have the type rating on your FAA certificate. If you don’t have the type rating, that’s another version of the same checkride.)