PIC Instrument Currency Question
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If a PART 91 pilot completes an IPC is January, he’s now “current” for 6 months (February - 31 July). If, on 1 August the PIC did not complete 6 approaches, a hold and a track, he’s now unable to file and fly IFR. Here’s my question, the PIC now has 6 months (August - January) to regain currency (flying with a safety pilot / CFII) before an IPC is required, correct? 

Thanks!
18 Replies
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Correct.

Another way to look at it is if it's been more than 6 months since you were last current, you need an IPC.
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Thanks Ron!  Much appreciated.
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I always find it easier to apply the regulation as it is written, which requires looking backwards versus looking forwards. For maintaining currency before having to fly with a safety pilot, look within the 6 calendar months preceding the month in which you want to file an IFR flight. In your example, you want to file IFR in August, so the six month period you have meet the 61.57(c)(1) is February - July. If not met during that time you then have 6 months to fly with a safety pilot, August - January. After that time you need an IPC.
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And by the way, the FAA has simplified currency maintenance by allowing the use of simulators. Reference 61.57(c)(2). Although it is never as good as actual flight, it is an excellent alternative and has many benefits.
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Prometheus At AOPA:
And by the way, the FAA has simplified currency maintenance by allowing the use of simulators. Reference 61.57(c)(2). Although it is never as good as actual flight, it is an excellent alternative and has many benefits.

Agreed.  Just remember it has to be an FAA-approved flight simulation device, and they aren't cheap -- $5500 and up.  But the good news is that the FAA deleted the requirement for an instructor to be present in order to log it for recent experience requirements.

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I agree with you Prometheus, and this is how I go about tracking. Thanks for the input, much appreciated. 
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I know previously one could get current with a Safety Pilot after the six months but before the 1 year and not require the IPC. I now no longer see that in the CFR, only the IPC in an Airplane or approved SIM with an Instructor after the 6 month period is legal.

§61.57   Recent flight experience: Pilot in command  (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.

Any thoughts????
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Peter Forte:
I know previously one could get current with a Safety Pilot after the six months but before the 1 year and not require the IPC. I now no longer see that in the CFR, only the IPC in an Airplane or approved SIM with an Instructor after the 6 month period is legal.


Nothing has changed.  You have never been able to regain currency by flying with a safety pilot more than 6 months after your instrument currency expired.  More than 6 months after your currency runs out, you've never been able to regain it without an IPC.  Here's the 1999 version of that section:
 
(d) Instrument proficiency check. Except as provided in paragraph (e) of this section, a person who does not meet the instrument experience requirements of paragraph (c) 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 consisting of a representative number of tasks required by the instrument rating practical test.

All they've done since is clean up the wording without changing the requirement.
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I believe per CFR changes, a SP is no longer valid after 6 months and an IPC in an A/C or SIM is required with an Instructor.
§61.57   Recent flight experience: Pilot in command.
(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. The instrument proficiency check must consist of at least the following areas of operation:
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Hi Peter, if I understand your question correctly, the answer is that it is implied in the paragraph itself that the only way to meet the currency requirements after the initial six months is to have someone on board that can act as the PIC (your safety pilot) while you are the sole manipulator of the controls. That last bit enables you to log the maneuvers as PIC for the purpose of meeting the currency requirements. If on the simulator, the FAA does not require an instructor (or anyone else for that matter) to be present.