Instrument Currency

[M20K]

Has this ever had any no-kidding (adverse) impact on someone and, if so, how? What I mean is, say there’s an “event” that prompts the FAA to dig into the background of a pilot (maybe like they busted mins so bad on a procedure that ATC felt compelled to give them a phone number - I don’t know). How would currency come up in the review? How would the FAA know if an approach was only logged when meeting the requirements? (Maybe by the threat of perjury?). And more importantly, has “inaccurately” logging an approach ever actually resulted in more than a disagreement with a CFII during a discussion?

Sure, say you busted some Airspace and the FAA called and asked you to stop by for a friendly chat. They're going to ask you to bring your Logbook(s).

Same with if you really did something bad with ATC or you just happened to bust minimums at an airport the FAA happened to drive out to that day to do Ramp Checks. Is it a frequent thing, I doubt it. You don't hear much about it, but then if the FAA ever called me in, I don't know that I'd be posting it all over the place. So that may be why we don't hear much about it.

But one thing I've read from multiple people, if you are contacted by the FAA, don't start off adversarial. Usually they just want info. My only real experience with the FAA was when I lost a cylinder over the water south of JFK and landed at JFK. I got a call from a guy in the JFK FSDO who was a little miffed since I stopped all the traffic at JFK why he didn't already have X, Y and Z forms!!!!!!!!! Took him a minute to hear what I was saying that I wasn't an air carrier. He finally just said to call him back when the mechanic figured out what happened.

 

[M20K]

Bottom line, though, is that it IS written FAA guidance for checkrides, contrary to @M20K ’s assertion.

Well.. Feel free to show me the correct quote then. What you posted was about ATC not being able to give you another Clearance until you've done a full circuit in the Hold. If you're going to say I'm wrong, at least quote something that is related to what I said about Holds for currency.

And as someone else posed, they DO NOT do what you say is required in their 135 training. So as I said, it may be company related, but the Regs do not call for a full circuit in the Hold. Now someday they may clarify that so that we do have to do a full circuit. But that's not what the Reg says at the moment. (But again, it isn't a bad thing to do in training if you want to.)

 

[MauleSkinner]

Well.. Feel free to show me the correct quote then. What you posted was about ATC not being able to give you another Clearance until you've done a full circuit in the Hold. If you're going to say I'm wrong, at least quote something that is related to what I said about Holds for currency.

I posted a link to the FAA document for conducting checkrides, which, as I said, is how 135 pilots maintain instrument currency. If you choose not to read or understand, that’s not my problem.

 

[MauleSkinner]

Quoting the dictionary definition isn't necessarily adequate for government documents, which sometimes have their own definitions of words. In government speak, of which I've had the pleasure to be immersed in my whole adult life, "should" simply means "should". Not mandatory.

Good news is I never said it meant mandatory.

 

[midlifeflyer]

Quoting the dictionary definition isn't necessarily adequate for government documents, which sometimes have their own definitions of words. In government speak, of which I've had the pleasure to be immersed in my whole adult life, "should" simply means "should". Not mandatory.

I'm trying to find it in the Fed's Plain Language guide, but I did find it in the ATC handbook, 7110.65BB:

Chapter 1. General​

Section 2. Terms of Reference​

1-2-1. WORD MEANINGS​

As used in this order:

1. “Must” means a procedure is mandatory.
2. “Must not” means a procedure is prohibited.
3. “Should” means a procedure is recommended.
4. “May” or “need not” means a procedure is optional.
5. “Will” means futurity, not a requirement for the application of a procedure.

Okay, here it is in the Federal Government's Plain Language guide:

Familiar terms

Using words that readers know helps them to understand.

digital.gov

Instead of using “shall,” use:

• “must” for an obligation
• “must not” for a prohibition
• “may” for a discretionary action
• “should” for a recommendation

"Should" can also establish a standard of conduct, which, while technically not mandatory, can ultimately make fine semantic distinctions irrelevant.

In the case of the guidance for a complete turn in the holding pattern, it's interesting. It's located in three places in Order 8900.1 (and applies as much to the ATP checkride as the 135 stuff). It is the conduct expected by the FAA from it's employees and contractors. Just like the 7110 is the employee manual for ATC.

 

[M20K]

I posted a link to the FAA document for conducting checkrides, which, as I said, is how 135 pilots maintain instrument currency. If you choose not to read or understand, that’s not my problem.

Still waiting for the quote you claim to have found. But if you can't produce it, well....

 

[MauleSkinner]

Try actually reading post 29 and it’s attachment.

 

[midlifeflyer]

Try actually reading post 29 and it’s attachment.

To be fair, if you check, the link doesn’t go to any of the three specific documents which contain the statement. The one for airplanes is para 5-831.B of Order 8900.1 here.

“At least the initial entry and one complete turn in the holding​

pattern should be completed before another clearance is issued.”

 

[M20K]

Try actually reading post 29 and it’s attachment.

Sorry, if you have a legitimate document, quote it and provide the Reg you say it's coming from (not some training document). You posted a link to a site that has a lame search engine and I *believe* I'm right and you're the one claiming I'm wrong. So if there's something in there, provide a link to the exact reg or admit you're wrong or were mistaken.

Other Pt 135s here have said they do what 61.57 requires, which is not an extra loop around. If you're training requires it, fine. If you have an actually FAA requirement that differs from 61.57 or a Legal Interpretation, I'd love to know about it, as it wouldn't be the first time the FAA has said two totally different things. But so far you've been all smoke and mirrors. If you have something show it. If you were miss informed by some training pilot or misinterpreted some document, fess up. I have no problem doing the same if you can prove me wrong.

And to be clear, we are talking about Instrument Currency. Not when ATC can give you a second clearance after entering a Hold, not if it is better in training to make extra turns in the Hold, not how to enter a Hold, not some company policy. We're taking about the bare minimums the FAA requires to be Current to file and fly on an IFR Flight Plan.

If you'd like a direct link, take a look at this one:
https://www.ecfr.gov/current/title-14/chapter-I/subchapter-D/part-61/subpart-A/section-61.57

 

[MauleSkinner]

To be fair, if you check, the link doesn’t go to any of the three specific documents which contain the statement. The one for airplanes is para 5-831.B of Order 8900.1 here.

“At least the initial entry and one complete turn in the holding​

pattern should be completed before another clearance is issued.”

Ah, apparently it only links directly on the device I used to link it.

 

[M20K]

Ah, apparently it only links directly on the device I used to link it.

I had missed @midlifeflyer's link. If that is the page you were trying to point out, it has nothing to do with Currency.

Note the title is 5-831 CLIMB, EN ROUTE, AND DESCENT EVENTS. And I'm guessing your referencing B. Holding. That would be a task to confirm the applicant (this is for Checkrides right?) is proficient in Holds. It is not the FAA requirements for Instrument Currency.

 

[midlifeflyer]

I had missed @midlifeflyer's link. If that is the page you were trying to point out, it has nothing to do with Currency.

Ummm. If you are going to argue against someone, it usually helps to argue against what they actually said.

In my world, the Feds tell us that for a Part 91 operator the entry counts as a hold on a checkride, but for a 135 operator it doesn’t.

That whole section is about “Oral and Flight Test Events in Airplanes for ATP Applicants Engaged in Operations Under 14 CFR Part 121, 135, or 91 Subpart K.”

 

[Tools]

Uh… is all this to say “fly what ya want and log what ya need” is NOT legitimate?

Ruh roh

 

[MauleSkinner]

I had missed @midlifeflyer's link. If that is the page you were trying to point out, it has nothing to do with Currency.

Note the title is 5-831 CLIMB, EN ROUTE, AND DESCENT EVENTS. And I'm guessing your referencing B. Holding. That would be a task to confirm the applicant (this is for Checkrides right?) is proficient in Holds. It is not the FAA requirements for Instrument Currency.

You missed a lot of things. I’ll just let you keep missing them, and I’ll keep spending 2/3 or more of my career flying IFR without being current (according to 61.57)

Have a good day.

 

[M20K]

Ummm. If you are going to argue against someone, it usually helps to argue against what they actually said.

Did I miss read something on the page that you posted? Does it say it has to do with "currency" or is it about proficiency in the task of Holding for the Checkride? And does the comment at the end just say that the examiner may not give another task until the applicant (pilot?) makes at least one additional circuit.

You missed a lot of things. I’ll just let you keep missing them, and I’ll keep spending 2/3 or more of my career flying IFR without being current (according to 61.57)

I have to admit I don't know the ins and outs of Pt 135 or 121, but you're telling me Pt 61 does not apply to you?
CORRECTION: I just read 61.57(e) and get that it does not apply to you.

 

[jayhawk74]

Did I miss read something on the page that you posted? Does it say it has to do with "currency" or is it about proficiency in the task of Holding for the Checkride? And does the comment at the end just say that the examiner may not give another task until the applicant (pilot?) makes at least one additional circuit.

I have to admit I don't know the ins and outs of Pt 135 or 121, but you're telling me Pt 61 does not apply to you?

Correct Part 61 currency doesn't apply to Part 121 and some 91K and 135 operators.
For example under 121 there is no requirement for currency for night landings. You can go years between night landings and still be legal to carry passengers at night. For Instrument currency you just have to pass your annual checkride, which could be 14 months apart.
At the 91K/135 Company I flew for we were night current for Part 91, 91K and 135 flying if in the past year we had done 10 night landings in a full motion simulator, which we did over the 1 day of training and the 1 day checkride. For Instrument currency Captains just had to pass their annual recurrent checkride and the semi-annual checkride, which could be 8 months apart.
Now if a pilot flies for a 91K, 121 or 135 company is night or instrument current under their companies OpSpecs but wanted to fly on their own under Part 91 then they would have to be current under Part 61.

 

[WDD]

Flashing back to the initial question for a moment....


The purpose of instrument currency, "6 in 6", is to make sure you have the proficiency to fly an instrument approach, which includes holds. Flying something that resembles a hold - whether it's a procedure turn or what not - requires the same skill sharpening as a "real hold". Call it a "simulated hold"?

Address the real world first, and then argue about how many angels can dance on the head of a pin when at home. Do what practice you need to be proficient, as reality tends to be somewhat important.

 

[midlifeflyer]

Correct Part 61 currency doesn't apply to Part 121 and some 91K and 135 operators.
For example under 121 there is no requirement for currency for night landings. You can go years between night landings and still be legal to carry passengers at night. For Instrument currency you just have to pass your annual checkride, which could be 14 months apart.
At the 91K/135 Company I flew for we were night current for Part 91, 91K and 135 flying if in the past year we had done 10 night landings in a full motion simulator, which we did over the 1 day of training and the 1 day checkride. For Instrument currency Captains just had to pass their annual recurrent checkride and the semi-annual checkride, which could be 8 months apart.
Now if a pilot flies for a 91K, 121 or 135 company is night or instrument current under their companies OpSpecs but wanted to fly on their own under Part 91 then they would have to be current under Part 61.

For anyone who wants to see it, the exceptions are in 61.57(e). For example...

61.57(e)(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.​

 

[midlifeflyer]

The purpose of instrument currency, "6 in 6", is to make sure you have the proficiency to fly an instrument approach,

You know better than to equate currency with proficiency.

I'll also disagree that the hold requirement is necessarily related to flying an approach. You can fly 1,000 published HILPTs using GPS and an autopilot and have absolutely no idea how to deal with ATC instructing an unpublished "hold SW of FXNAM on the 060 inbound course..."

 

[WDD]

You know better than to equate currency with proficiency.

I'll also disagree that the hold requirement is necessarily related to flying an approach. You can fly 1,000 published HILPTs using GPS and an autopilot and have absolutely no idea how to deal with ATC instructing an unpublished "hold SW of FXNAM on the 060 inbound course..."

OK, the "intent" of the currency is to be proficient. We agree that the goal is "proficient". Some folks need more than six, so they need to do what they need to do.

Does being proficient in flying an approach also require you be proficient in flying a hold? I do procedure turns, so yeah, the skills of doing a hold do help so I will practice them.

I've had a real hold once in 4 years of flying. Untowered field, and ATC had to make a hold for me until the guy in front cancelled his IFR, was on the ground, etc.

And yeah, it's good to practice these things by hand vs auto pilot so you get to think about what is going on. But, also need to mix in a few AP approaches as well just to keep sharp on what buttons to push, etc.

 

[midlifeflyer]

We agree that the goal is "proficient". Some folks need more than six, so they need to do what they need to do.

Goal, yes. But currency, whatever the intent of the regulation, is about numbers and checking boxes. Proficiency takes more. I'm still not going to give them any equivalency. One can be current without being proficient. I'll go a step further. One can be proficient without being current.

 

[RussR]

At the 91K/135 Company I flew for we were night current for Part 91, 91K and 135 flying if in the past year we had done 10 night landings in a full motion simulator, which we did over the 1 day of training and the 1 day checkride.

There are a few other requirements, such as you must be day current (3 in the last 90 days), and you have to have flown at least 15 hours in type in the last 90 days, and a few other minor details, but yes, overall you're correct. I also read in 135.247 that it's 6 landings in the sim, not 10. Could that have been a function of your company training requirements?

I didn't know Part 121 had no night requirements, but based on your post I looked it up and sure enough you're correct!