How to work with the new regulations
Out of instrument currency again? Chances are you and your fellow instrument-rated pilots have never been heard to say, "Gosh, it sure is easy and fun to maintain instrument currency." But it has to be done, and as painlessly and inexpensively as possible. After all, the goal is to have a flying budget left over for the personal flights, while still maintaining a safe level of skill. Unfortunately, instrument flying is a mental skill, and mental skills atrophy quickly.
VFR pilots, of course, have no legal requirement to maintain proficiency on instruments. But such skills must magically appear if there is an inadvertent encounter with weather while flying VFR. Instrument skills are not only useful, but they may also be necessary on a clear but moonless VFR night when outside references disappear.
An airline pilot said recently that his instrument skills begin to weaken after two weeks away from flying. What, then, must be the condition of the average general aviation pilot's skills five months after meeting the six-month currency requirements?
New currency regulations are simple to understand
Keeping current is a problem mainly for general aviation pilots operating under FAR Part 91, right? Wrong. Airline pilots face the same problem. Many of their approaches are spent briefly descending through clouds during a long, straight-in final — with the aircraft controlled by the autopilot. That barely counts as an approach and does little to maintain skills.
The old regulations made it a certainty that instrument-rated pilots who failed to meet currency requirements (and that was most of us) would head for the local flight school and ante up for what is now called an instrument proficiency check. It was a lot less expensive than finding a safety pilot and cruising around under the hood to meet the requirement for not only six approaches, but six hours of actual or simulated instrument time.
Last year, the FAA changed that picture dramatically. Now, pilots have a shot at keeping current on their own — and doing it less expensively. Six hours of simulated or actual instrument time are no longer a part of the currency requirement. At first glance, the new currency requirements in FAR 61.57(c)(1) seem simple: Every six months you need to perform at least six instrument approaches, holding procedures, and intercepting and tracking courses through the use of navigation systems. Failing that, you have, as was the case with the old regs, another six months to get current before having to take an instrument proficiency check. During that six months you may not file IFR.
But wait. First of all, there is an s on holding procedures; and does tracking courses mean those other than used for an approach?
To find out, AOPA Technical Services personnel asked the author of 61.57, FAA official John D. Lynch. Here's his answer:
"When paragraph 61.57(c)(1)(ii) [i.e., "Holding procedures"] was written it was not intended to mean multiple holdings. The emphasis is on the word procedures. There is more to holding than just flying circles in the sky. There is the planning for holding, slowing the aircraft down prior to entry, entering the holding pattern correctly, correcting for winds, establishing the one-minute inbound leg, etc. That is why I wrote it as 'Holding procedures.' So no, I never intended it to be multiple holdings."
He goes on to say that you need not document in the logbook where the maneuver took place. But what about tracking? Here, again, the answer is simple.
"Yes," Lynch told AOPA, "when a person does an approach or holding, he/she is also intercepting and tracking a course. See how simple we made paragraph 61.57(c)?" Imagine that; something from the FAA that is intentionally simple and easy to understand. No gotchas. No hidden traps.
As one might expect, Lynch has been asked a constant stream of questions about all aspects of the new Part 61, including IFR currency requirements. All of the answers (.pdf) are available on the Web.
Penalties for losing currency are stiff and unforgiving
Airline pilot Jeff Jones has compiled accident statistics for the AOPA Air Safety Foundation that show there is a severe penalty for lack of instrument proficiency. He looked at 1994 accidents and reclassified them in a more useful manner.
For example, if an aircraft flew into a thunderstorm and was destroyed, the federal government may classify that as "loss of control." Jones reclassified such accidents as "poor judgment." With that caveat, here is what he found.
For study he selected 61 general aviation accidents that occurred in instrument meteorological conditions, and the blame for a majority of them can be laid to the lack of instrument proficiency. Sixteen of the accidents, none of them fatal, resulted from loss of control. Fourteen, eight of them fatal, were caused by improper planning and decision making. In 10 of the accidents — five with fatal results — approach or departure procedures were flown incorrectly.
Among the loss-of-control accidents was the case of a Piper Arrow that crashed during an instrument approach at Sarasota, Florida. The aircraft was cleared for an ILS approach. Radar data shows that the airplane S-turned along the localizer as if the pilot were overcorrecting. One mile from the runway, the aircraft began a nonstandard missed approach, and an alternative procedure was transmitted to the pilot, who acknowledged by clicking the microphone button. However, the instructions were not followed. Witnesses saw the airplane descend through the fog in a steep, nose-down, right-bank attitude before crashing.
Jones listed this accident under improper planning and decision making. A commercial pilot flying a Cessna Turbo 210 reported to air traffic control that he was losing oil pressure and needed to descend to a nearby airport. The pilot was cleared to 12,000 feet, and encountered instrument conditions during the descent. For some reason, the pilot did not stop at the assigned altitude. The pilot later told a unicom operator that he was eight miles east of the airport near Richmond, Utah, and that he hoped his aircraft didn't hit any of the mountains. It appears the pilot knew about the terrain — but needed better planning to avoid it. Searchers later found the wreckage 400 feet below the crest of a 9,765-foot mountain.
These booklets may help
The FAA and the AOPA Air Safety Foundation have each produced booklets that will aid your personal currency program.
Descent to the MDA or DH and Beyond can be obtained by calling your local FAA flight standards district office. Ask for booklet FAA-P-8740-09, produced as part of the FAA Aviation Safety Program.
The Single-Pilot IFR Safety Advisor published by the AOPA Air Safety Foundation is available free on AOPA Online ( www.aopa.org/asf/publications/sa05.pdf). If you are not on the Internet, then it can be obtained by mail. Send $1 and a self-addressed (not stamped) envelope to: AOPA Air Safety Foundation, Attn: Single-Pilot IFR, 421 Aviation Way, Frederick, Maryland 21701.
Tip Sheet
- Fly with an instructor during actual instrument weather for currency practice. The VFR pilot, of course, will be primarily a passenger, but will get to see what it's really like when the chips are down. The instrument-rated pilot gains the best training possible — the chance to use all of the skills learned, but with the added insurance policy of an instructor in the right seat.
- To save money, combine currency requirements. For example, take an instrument proficiency check at night. Doing so will combine the rental operator's 60- or 90-day recency-of-flight requirement (if you don't have your own aircraft) with the night landings required by the FARs to carry passengers. Remember to make three landings to a full stop.
Lexicon
DH (decision height): The height at which a decision must be made to either continue or execute a missed approach.
ILS (instrument landing system): A precision instrument approach system which normally consists of a localizer, glideslope, outer marker, middle marker, and approach lights.
IMC (instrument meteorological conditions): Meteorological conditions expressed in terms of visibility, distance from cloud, and ceiling less than the minimums specified for visual meteorological conditions.
IPC (instrument proficiency check): This was known prior to August 1997 as the ICC or instrument competency check.
Localizer: The component of an ILS which provides course guidance to the runway.
MDA (minimum descent altitude): The lowest altitude, expressed in feet above mean sea level, to which descent is authorized on final approach or during circle-to-land maneuvering in execution of a standard instrument approach procedure where no electronic glideslope is provided.
MEA (minimum en route altitude): The lowest published altitude between radio fixes which assures acceptable navigational signal coverage and meets obstacle clearance requirements between those fixes.
What's in a proficiency check?
The regulations concerning the content of the instrument proficiency check haven't changed — only the name. It was previously known as the instrument competency check, or ICC. The IPC is intended to include a representative number of tasks from the instrument rating practical test. Is that what you are going to practice when maintaining proficiency on your own?
You can now get legally instrument current in a little over one hour. Just fly an ILS six times, fly one missed approach and hold, and you're done. But is that enough? What happens five months from now when you are faced with a partial-panel NDB approach?
Chief Flight Instructor Tyson Wheeler, based at a Maryland flight school, likes the new regulations because pilots at least have a chance to keep themselves current. But he warns pilots not to practice the same maneuver over and over just to satisfy currency requirements. His IPCs normally include flight planning, map symbols, regulations, partial-panel work, unusual attitudes, holds, and approaches. That normally requires an hour on the ground and 1.5 hours in the air. That is five more items than are now required by the new regulations.
The most common problem Wheeler sees with the rusty pilot is the lack of a plan — or as he puts it, "a clue" — for setting up the approach. The second most common problem is interpreting the weather and applying it to the route. Where is the freezing level? Will you break out on top?
FlightSafety International offers a three-day, $1,000 recurrency course at its Lakeland Learning Center in Florida. Obviously it is the Cadillac of training, and not everyone can afford a luxury car. It includes nine hours of ground school, six hours of flight or simulator time, and three hours of flight briefings. Chief Pilot William A. Hanner customizes the course for each pilot, asking what they most want to review. The answers are not surprising: holding, nonprecision approaches, GPS work, regulations, and flight planning.
Hanner has an unusual perspective in that he sees a cross-section of general aviation pilots, not just those from Central Florida. As a whole, he notes, the average pilot he sees is pretty good. And one other thing. Not to butter you up, but Hanner also notices that AOPA members who come there seem more serious about their training than the average pilot, and more dedicated to improving their skills.
"The new regulations show the trust the FAA has always had in pilots," Hanner said. "But if they do not fly in the system, they are not as proficient as pilots who do. I don't recommend that such pilots get current themselves. They should at least have a qualified instructor."
Bottom line? Even with the new regulations, you're still going to need to fly with an instructor at least once a year. Be honest with yourself. Take this little test. Say this to yourself out loud: DME arc to a back-course localizer approach, flown to minimums, and followed by a circling approach that ends in a missed approach with a hold at an intersection. If that made your hands sweat, then you may be out of currency. — AKM
Links to all Web sites referenced in this issue can be found on AOPA Online. E-mail the author at [email protected].
