New instrument currency

[gprellwitz]

I'm reviewing the new instrument currency rules and trying to determine how they would apply if I wanted to meet them with a combination of Frasca 141 (Flight Training Device) and airplane time. We do not have an "Aviation Training Device" (which isn't defined in the FAR 14.61, but instead in AC 61-136).

They seem to cover the following options in the reg:
1) aircraft in actual or view limiting device (VLD)
2) Flight Simulator (FS)/Flight Training Device (FTD)
3) Aviation Training Device (ATD)
4) aircraft and FS/FTD and ATD
5) FS/FTD and ATD

So it appears as if I could not do three of the approaches in the aircraft and three in the FTD (plus holds and tracking) to meet the requirements. They all need to be done in one type of device unless I also want to track down a device certified as an ATD and use that too. Am I reading this right?

Plus, a I think Tim has noted before, if I were to do them in the FTD, I'd have to do the standard 6 approaches, track and hold (14.61.57(c)(2)), and they would be good for 6 calendar months. But, if I were to do them in either a BATD or AATD, which can be more advanced than a legacy FTD, and I didn't also fly in an airplane, I would also have to do four unusual attitude recoveries, and would only be good for two calendar months.

8. AUTHORIZATIONS FOR PREVIOUSLY APPROVED DEVICES (“GRANDFATHERING”).
a. An operator may continue to use a device, as originally approved, to substitute for aircraft flight training or airman certification. These uses must not be for aircraft type specific training or for an aircraft type rating. The device may only be used if it was originally approved and
continues to meet the criteria set forth for:
(1) PCATD;
(2) Level 2 or Level 3 FTD; or
(3) A device categorized as a Level 1 (“conferred status”) FTD.
b. Devices approved prior to this AC will not qualify for the new approval as a BATD or AATD.

(c) Instrument experience. Except as provided in paragraph (e) of this section, a person may act as pilot in command under IFR or weather conditions less than the minimums 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, 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 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.

(2) Use of a flight simulator or flight training device 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 a flight simulator or flight training device, provided the flight simulator or flight training device represents the category of aircraft for the instrument rating privileges to be maintained and 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.

(3) Use of an aviation training device for maintaining instrument experience. Within the 2 calendar months preceding the month of the flight, that person performed and logged at least the following tasks, iterations, and time in an aviation training device and has performed the following—
(i) Three hours of instrument experience.
(ii) Holding procedures and tasks.
(iii) Six instrument approaches.
(iv) Two unusual attitude recoveries while in a descending, Vneairspeed condition and two unusual attitude recoveries while in an ascending, stall speed condition.
(v) Interception and tracking courses through the use of navigational electronic systems.

(4) Combination of completing instrument experience in an aircraft and a flight simulator, flight training device, and aviation training device. A person who elects to complete the instrument experience with a combination of an aircraft, flight simulator or flight training device, and aviation training device must have performed and logged the following within the 6 calendar months preceding the month of the flight—
(i) Instrument experience in an airplane, powered-lift, helicopter, or airship, as appropriate, for the instrument rating privileges to be maintained, performed in actual weather conditions, or under simulated weather conditions while using a view-limiting device, on the following instrument currency tasks:
(A) Instrument approaches.
(B) Holding procedures and tasks.
(C) Interception and tracking courses through the use of navigational electronic systems.
(ii) Instrument experience in a flight simulator or flight training device that represents the category of aircraft for the instrument rating privileges to be maintained and involves performing at least the following tasks—
(A) Instrument approaches.
(B) Holding procedures and tasks.
(C) Interception and tracking courses through the use of navigational electronic systems.
(iii) Instrument experience in an aviation training device that represents the category of aircraft for the instrument rating privileges to be maintained and involves performing at least the following tasks—
(A) Six instrument approaches.
(B) Holding procedures and tasks.
(C) Interception and tracking courses through the use of navigational electronic systems.

(5) Combination of completing instrument experience in a flight simulator or flight training device, and an aviation training device. A person who elects to complete the instrument experience with a combination of a flight simulator, flight training device, and aviation training device must have performed the following within the 6 calendar months preceding the month of the flight—
(i) Instrument recency experience in a flight simulator or flight training device that represents the category of aircraft for the instrument rating privileges to be maintained and involves having performed the following tasks:
(A) Six instrument approaches.
(B) Holding procedures and tasks.
(C) Interception and tracking courses through the use of navigational electronic systems.
(ii) Three hours of instrument experience in an aviation training device that represents the category of aircraft for the instrument rating privileges to be maintained and involves performing at least the following tasks—
(A) Six instrument approaches.
(B) Holding procedures and tasks.
(C) Interception and tracking courses through the use of navigational electronic systems.
(D) Two unusual attitude recoveries while in a descending, Vneairspeed condition and two unusual attitude recoveries while in an ascending, stall speed condition.

 

[TMetzinger]

Ron has noted that this rewrite is "under review". The AATD stuff is sort of expected and discussed in the NPRM language, but the rest of it was totally unexpected.

I was expecting to see any combination of airplane/sim/FTD time being ok, just like in the past, with AATD currency counting for a little less.

We'll see what happens. For now, I'm just going to do the currency in an airplane.

 

[bbchien]

Grant, if you were a training operator, you would have to be nuts to spend $$s based on the current reg. It's clear as gobbledygook.

 

[TangoWhiskey]

IFR magazine just had a good article on this... if you subscribe or know somebody that does, see if they can share the article with you.

 

[gprellwitz]

Grant, if you were a training operator, you would have to be nuts to spend $$s based on the current reg. It's clear as gobbledygook.

Glad to see I'm not the only one to think it's less than logical.

IFR magazine just had a good article on this... if you subscribe or know somebody that does, see if they can share the article with you.

"New Options for Currency" by Jeff McNamee in the January 2010 issue, p20 - 22. I just re-read that article, but it doesn't mention what I saw about apparently requiring time in all three types of devices that I described above. (To be frank, I had forgotten I'd read it when I was looking at the regs; I just remembered that they had changed.)

 

[TangoWhiskey]

Glad to see I'm not the only one to think it's less than logical.
"New Options for Currency" by Jeff McNamee in the January 2010 issue, p20 - 22. I just re-read that article, but it doesn't mention what I saw about apparently requiring time in all three types of devices that I described above. (To be frank, I had forgotten I'd read it when I was looking at the regs; I just remembered that they had changed.)

I think it's covered by option 4, but as is usual with the FARs, it is poorly worded. I think they meant that option 4 covers the mix of training in an aircraft AND any one of the following three items. You'll notice they DO use the word "OR" further in the same paragraph, though the ", and" further complicates their grammar. Confusing; you'd think it would have been caught and corrected during the NPRM comments period.

(4) Combination of completing instrument experience in an aircraft and a flight simulator, flight training device, and aviation training device. A person who elects to complete the instrument experience with a combination of an aircraft, flight simulator or flight training device, and aviation training device must have performed and logged the following within the 6 calendar months preceding the month of the flight—

To make that clear, it should read something like this (pseudo code):

(4) Combination of completing instrument experience (in an aircraft) AND (a flight simulator, flight training device, OR aviation training device). A person who elects to complete the instrument experience with a combination of an aircraft with a flight simulator, flight training device or aviation training device must have performed and logged the following within the 6 calendar months preceding the month of the flight—

 

[gprellwitz]

I think it's covered by option 4, but as is usual with the FARs, it is poorly worded. I think they meant that option 4 covers the mix of training in an aircraft AND any one of the following three items. You'll notice they DO use the word "OR" further in the same paragraph, though the ", and" further complicates their grammar. Confusing; you'd think it would have been caught and corrected during the NPRM comments period.

Note also under (4) that the ATD requires six approaches, just to further complicate things. And the three subparagraphs under (4) aren't separated with "or."

 

[poadeleted20]

I agree with Troy -- I think subparagraph (4) was intended to cover this, requiring a total of six approaches in whatever combination of platforms you choose to use, but they worded it badly. I'll pass that on to JL to see what he says.