Where Is The "6 Month Grace Period" Spelled Out?

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M20K

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Besides all the other "mysteries" of the FARs, here's another one I haven't been able to resolve yet.
AND I AM LOOKING FOR DOCUMENTATION... NOT THAT MY CFII TOLD ME OR I READ IN SOME ARTICLE (unless it actually have a reference to the FARs)

So you are IFR Current and you let it go 9 months. WHERE does it state there is a 6 month grace period to get your currency back?

61.57 states in (d) Instrument proficiency check.
(1) Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check.... (and it continues)

But that specifically calls out that an IPC is required if you let it go 13 months. It does not say in the 6 months after you let your currency laps you can go out yourself in IMC or with a Safety PIC to get current again (or use a Sim).

So anyone have a reference to a different reg that could be used to say 61.57 implies that? Anyone have a reference to a Legal Interpretation that clarifies this? Again, an FAA reference would be appreciated, we've all sat through seminars, webinars and read it in articles. But so far I've found no hard FAA reference.
 
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It says nothing about 12 months. It says if you have not been instrument current (failed to meet the instrument experience requirements) for 6 months, you must do an IPC.

In other words, say I log an approach a month, along with holding, intercepting, and tracking, but take a break from flying for a month, and I cease to be instrument current on July 1. I can still grab a safety pilot and log approaches to get current again any time in the next 6 months, but I can’t act as PIC under IFR until I satisfy the requirements. Starting January 1, after 6 months of not being current, I have to do an IPC to regain currency.
 
It’s so funny. Everyone understood this and then the FAA decided to tweak the reg to “clarify” it. Each clarification was met by pilots insisting the FAA took It away, requiring intercession by the Chief Counsel. (Maybe some regulitis involved?)

Me, I see it in the reg, others might need to read the Whistman letter.
 
(c)(1) established time period 1. (d)(1) allows 6 more months if you fail (c)(1) to get the experiance before an IPC is required.

(c)(1) Within time period 1 that person performed and logged at least the following tasks and iterations in an airplane,

(d)(1) a person who has failed to meet the instrument experience requirements of time period 1 of this section for more than six calendar months may reestablish instrumentcurrency only by completing an instrument proficiency check.
 
Clip4 said:
(c)(1) established time period 1. (d)(1) allows 6 more months if you fail (c)(1) to get the experiance before an IPC is required.

(c)(1) Within time period 1 that person performed and logged at least the following tasks and iterations in an airplane,

(d)(1) a person who has failed to meet the instrument experience requirements of time period 1 of this section for more than six calendar months may reestablish instrumentcurrency only by completing an instrument proficiency check.
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Yeah, the piece that got people worked up was reading the 6 months in (d) to be the same as the 6 months in (c) rather than the 6 months after the 6 months in (c).

Even funnier, I saw the same issue raised after the 2018 update, which cleaned up the device vs aircraft mess, even though not one word was changed.
 
midlifeflyer said:
I see it in the reg
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It seems pretty straightforward to me, too…
Instrument current? Keep doing the stuff in (c)(1) ot a couple of other things to stay that way.
Not instrument current, but last day you were instrument current is less than 6 months ago? Go do the stuff in (c)(1). Or you can do an IPC, or a couple of other things. This is the “grace period.”
Not instrument current, and your last day of instrument currency was more than 6 months ago? IPC per (c)(3).

I think one of the biggest issues is over-paraphrasing…probably a symptom of regulitis?
 
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MauleSkinner said:
It seems pretty straightforward to me, too…
Instrument current? Keep doing the stuff in (c)(1) ot a couple of other things to stay that way.
Not instrument current, but last day you were instrument current is less than 6 months ago? Go do the stuff in (c)(1). Or you can do an IPC, or a couple of other things. This is the “grace period.”
Not instrument current, and your last day of instrument currency was more than 6 months ago? IPC per (c)(3).

I think one of the biggest issues is over-paraphrasing…probably a symptom of regulitis?
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Paraphrasing (and its step-cousin mnemonics) can be a problem. For IPCs I ask a question about alternate requirements. The scenario is a CAVU day when the destination has no instrument approaches. I'm sure you would not be surprised at the number of people who get it wrong citing the "1-2-3" rule.

But in this case, there may be a bit of FAA diaregurhea involved. Until 1997, the rule read

A person who does not meet the recent instrument experience requirements of [internal reference] of this section during the prescribed time, or within 6 calendar months thereafter, may not serve as pilot in command under IFR, or in weather conditions less than the minimums prescribed for VFR, until that person passes an instrument competency test...​

I don't recall anyone misunderstanding how the recapture period (it not really a grace period) worked. The 1997 change was not too bad. Most of it was about the semantic change from ICC to IPC

a person who does not meet the recent instrument experience requirements of [internal reference] of this section within the prescribed time or within 6 calendar months after the prescribed time may not serve as pilot in command under IFR or in weather conditions less than the minimums prescribed for VFR until that person passes an instrument proficiency check...​

Then, in 2009, when they went to:

a person who does not meet the instrument experience requirements of paragraph (c) of this section within the 12 calendar months preceding the month of the flight may not serve as pilot in command under IFR or in weather conditions less than the minimums prescribed for VFR until having passed an instrument proficiency check..."​

Not much reason for the change, but it was still pretty clear. The current language appeared in 2011 and has raised questions ever since. @M20K is not alone. I think it raised question because it removed the fairly clear "12 months" language.
 
M20K said:
Besides all the other "mysteries" of the FARs, here's another one I haven't been able to resolve yet.
AND I AM LOOKING FOR DOCUMENTATION... NOT THAT MY CFII TOLD ME OR I READ IN SOME ARTICLE (unless it actually have a reference to the FARs)

So you are IFR Current and you let it go 9 months. WHERE does it state there is a 6 month grace period to get your currency back?

61.57 states in (d) Instrument proficiency check.
(1) Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check.... (and it continues)
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You quoted the reference.
 
I also suspect the “grace period” terminology confuses the issue, as the regs don’t say anything like that, they simply state an end period for a specific qualification activity if it exist in regulation.

Using “grace period” terminology, the grace period for getting yourself 90-day current with 3 takeoffs and landings ends when you die. ;)
 
midlifeflyer said:
The current language appeared in 2011 and has raised questions ever since.
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Exactly. I figured by now there would have been an Legal Interpretation or I'd even accept and AC. But it is all implied and remembered by us that got our Inst. rating back in the day where it said "within 6 calendar months thereafter."
 
M20K said:
Exactly. I figured by now there would have been a Legal Interpretation or I'd even accept and AC. But it is all implied and remembered by us that got our Inst. rating back in the day where it said "within 6 calendar months thereafter."
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It’s not implied. It’s specifically stated…
M20K said:
(1) Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check....
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MauleSkinner said:
I don’t see the number 13 anywhere in the regs you quoted. Where are you finding it?
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You didn't know you were current for 7 months? Then we get into my question where 61.57 talks about the IPC 6 months later.
(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,

So on January 1 you are current. You are then current for then next 7 months (within the 6 calendar months PRECEDING the month of the flight), so you are current up to July 31.... 7 months
Six months pass and you need an IPC.... 6 months
7+6=13 And that part hasn't changed since I got my Inst. rating last century.
 
M20K said:
You didn't know you were current for 7 months? Then we get into my question where 61.57 talks about the IPC 6 months later.
(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,

So on January 1 you are current. You are then current for then next 7 months (within the 6 calendar months PRECEDING the month of the flight), so you are current up to July 31.... 7 months
Six months pass and you need an IPC.... 6 months
7+6=13 And that part hasn't changed since I got my Inst. rating last century.
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When your currency started is not specified in the reg, nor is it relevant. Merely when your currency ended, per the reg.

And that hasn’t changed since my instrument currency last started in the last century.
 
MauleSkinner said:
It’s not implied. It’s specifically stated…
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I disagree. It specifically states that you need an IPC. It does not specifically state that I can go out and get current in those 6 months.

Granted, they may have meant to say that. But they removed the wording "or within 6 calendar months thereafter." So if they actually took the wording out, I want to know where it says I can still do that. Not that everyone isn't still doing it. But this is one of those long time questions. It DOES NOT say I can go get current in those 6 months between currency lapsing and as you quoted in (d)(1) it only says "...for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check..."
 
MauleSkinner said:
When your currency started is not specified in the reg, nor is it relevant. Merely when your currency ended, per the reg.
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So you do not believe you get 7 months per the reg???? And you don't need to know when your currency started to be able to calculate when it lapses?

Well okay then. Hope whomever gives you your IPC is a member here. :D
 
M20K said:
I disagree. It specifically states that you need an IPC. It does not specifically state that I can go out and get current in those 6 months.

Granted, they may have meant to say that. But they removed the wording "or within 6 calendar months thereafter." So if they actually took the wording out, I want to know where it says I can still do that. Not that everyone isn't still doing it. But this is one of those long time questions. It DOES NOT say I can go get current in those 6 months between currency lapsing and as you quoted in (d)(1) it only says "...for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check..."
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(c) says you can go out and get current without a CFII. (d) tells you when that ability ends. That’s as explicit as it needs to be.
 
M20K said:
So you do not believe you get 7 months per the reg???? And you don't need to know when your currency started to be able to calculate when it lapses?

Well okay then. Hope whomever gives you your IPC is a member here. :D
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When does your currency started “start” per the reg?
 
M20K said:
You didn't know you were current for 7 months? Then we get into my question where 61.57 talks about the IPC 6 months later.
(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,

So on January 1 you are current. You are then current for then next 7 months (within the 6 calendar months PRECEDING the month of the flight), so you are current up to July 31.... 7 months
Six months pass and you need an IPC.... 6 months
7+6=13 And that part hasn't changed since I got my Inst. rating last century.
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Being current on January 1 does not mean you will be current for 6 or 7 months unless you did an IPC on January 1.
 
dmspilot said:
Being current on January 1 does not mean you will be current for 6 or 7 months unless you did an IPC on January 1.
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Okay, granted, I implied I had completed all of the required tasks on January 1. But I'm not sure how you took the leap to say an IPC was required? I could have flown all through the fall into October, then the next good Wx day was Jan 1, so I went up and did all the required task to KEEP my currency and restart the clock/calendar again on Jan 1.

And in a discussion like this, I would hope no one would toss out a trick statement to confuse the issue. "So on January 1 you are current" just meant exactly that, the person is totally current is all aspects of the Regs.
 
I'm now confused on something I thought I understood.

Jan 1 - I'm current going into that day. I fly 6 approaches, a hold and follow a navaid.
I can fly in IMC until the end of June.
If I did nothing during that time, I can get current with a safety pilot, but can't fly IFR until getting current.
At the end of the year, if I've still done nothing, I must get an IPC

Is that correct? Not worried about 6 vs 7 months, just the broad strokes.
 
M20K said:
Okay, granted, I implied I had completed all of the required tasks on January 1. But I'm not sure how you took the leap to say an IPC was required? I could have flown all through the fall into October, then the next good Wx day was Jan 1, so I went up and did all the required task to KEEP my currency and restart the clock/calendar again on Jan 1.

And in a discussion like this, I would hope no one would toss out a trick statement to confuse the issue. "So on January 1 you are current" just meant exactly that, the person is totally current is all aspects of the Regs.
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No, I'm not trying trick anyone. I'm trying to prevent you from tricking anyone.

I suppose you could do all six approaches and the other required tasks on January 1, but your premise does not justify your conclusion in this statement: "So on January 1 you are current. You are then current for then next 7 months." You cannot infer your currency expiration date based on being current on January 1 without more information.

If you do one approach on January 1st after having done one each on December 1st, November 1st, October 1st, September 1st, and August 1st, you are only current until February.
 
Hang 4 said:
I can fly in IMC until the end of June.
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End of July... "preceding" 6 months would be Jan through June.

So in July you are looking to see if you were current in the "preceding" 6 months.
 
dmspilot said:
No, I'm not trying trick anyone. I'm trying to prevent you from tricking anyone.
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Again, it would be pretty dumb to try and sneak in a gotcha like that in a discussion like this. I wouldn't and don't take kindly to you assuming I would.
 
Assuming you are currently current when starting:
If you go do 6 approaches and procedures today (Aug 7) you would remain current until Feb 28th, correct?

If you did 3 on Jul 20th and another 3 today (Aug 7) you would remain current until Jan 31, correct?

If you don't consider "preceding" months to include the current month you are in then it would move those out one more month.
 
Dixiebluesky said:
Assuming you are currently current when starting:
If you go do 6 approaches and procedures today (Aug 7) you would remain current until Feb 28th, correct?

If you did 3 on Jul 20th and another 3 today (Aug 7) you would remain current until Jan 31, correct?

If you don't consider "preceding" months to include the current month you are in then it would move those out one more month.
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And assuming you are not current when starting, instrument currency in your second example wouldn’t “start” until today, Aug 7, and you wouldn’t get the 7 months of currency that the OP claims are part of the formula to get the mythical 13 months.
 
M20K said:
Again, it would be pretty dumb to try and sneak in a gotcha like that in a discussion like this. I wouldn't and don't take kindly to you assuming I would.
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You started this nonsense of people trying to trick people. I don't know what your deal is. Post an incorrect statement, get corrected. I'm sorry that offends you.
 
Hang 4 said:
I'm now confused on something I thought I understood.

Jan 1 - I'm current going into that day. I fly 6 approaches, a hold and follow a navaid.
I can fly in IMC until the end of June.
If I did nothing during that time, I can get current with a safety pilot, but can't fly IFR until getting current.
At the end of the year, if I've still done nothing, I must get an IPC

Is that correct? Not worried about 6 vs 7 months, just the broad strokes.
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Yes. That is correct.
 
midlifeflyer said:
I thought I linked the legal interpretation earlier in Post #4.
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“This letter of interpretation makes clear that the correct interpretation of the language of
§61.57(d) is that a pilot must perform the instrument recent flight experience required by
§61.57(c) within 12 calendar months of the last date that the pilot was able act as PIC under
IFR or weather conditions less than the minimums prescribed for VFR. If a pilot fails to
meet the recent flight experience within this 12 calendar month period, then the pilot must
pass an IPC…”

Under that interpretation, one passed there instrument check ride in Jan 2026, they are current through July 2026 and doesn’t require an IPC through July 2027 (within 12 calendar months of the last date that pilot was able to act as PIC)
 
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gacoon said:
Someone flow chart it
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Have you been instrument current at any time within the last 6 calendar months?


Yes—you can do more flying to get/stay current. 61.57(c)(1)

No—you need to get an IPC. 61.57(d)(1)
 
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I think the confusion comes from people calling it a grace period. The regulation doesn’t provide a grace period. It provides a currency rule plus an exception to the currency rule.

Leave out 61.57(d) altogether. Now, instrument currency is just a matter of the approaches, holds, and course interceptions in your logbook. That’s how it works for day and night passenger currency. There is no need for a grace period, because the rule is the same whether your logbook never shows a lapse in currency or if you’ve been out of currency for years.

For instrument currency, though, we have 61.57(d), which creates an exception under which your having been non-current for 6 months eclipses anything else in your logbook that could re-establish currency other than an IPC.

That part is very clearly written as long as you don’t try to find the “grace period” as a positive statement in the regulation.

What might be unclear is whether an IPC that doesn’t get your logbook to 6 approaches, 1 hold, and 1 intercepted course within the past 6 months is sufficient to be current. Say you are 6 approaches short of current and you do an IPC that includes flying 5 approaches. Do you need to log 1 more approach before you can operate under IFR? Does it matter if the IPC was done when you were current, when you were within 6 months of being current, or later? That’s the part of 61.57 that I think could use the most clarification.
 
am i missing something? i will say i'm a bit lax but the rule says "failed to meet... 6 mos" so you've had to fail to be current for 6 mos

61.57 states in (d) Instrument proficiency check.
(1) Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check.... (and it continues)
 
iamtheari said:
What might be unclear is whether an IPC that doesn’t get your logbook to 6 approaches, 1 hold, and 1 intercepted course within the past 6 months is sufficient to be current. Say you are 6 approaches short of current and you do an IPC that includes flying 5 approaches. Do you need to log 1 more approach before you can operate under IFR? Does it matter if the IPC was done when you were current, when you were within 6 months of being current, or later? That’s the part of 61.57 that I think could use the most clarification.
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I've seen this question come up before, but I never thought that 61.57d was unclear at all. By my reading, it pretty simply says "if you don't meet instrument currency, you can only get it back by completing an IPC." Thereby, completing an IPC makes you current again. Number of approaches doesn't matter, as long as you complete the tasks required for the IPC.

Now, in reality, most people I work with who need an IPC end up needing far more than just the minimum, precisely because they are not only non current, they're non-proficient at this point as well. So we usually end up doing at least 2 flights or maybe more, and that usually means we're over 6 approaches by the time we're done anyway.

I imagine it's the same for most instructors. Most people coming for an IPC haven't been current in YEARS, let alone 6 months. And of course it's almost always because they have a big family trip coming up and "want to be ready" for any IMC that may occur.
 
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