This came up in yesterday’s Zoom session (topic: N-reg) and a view was expressed that the annual test ensures pilot standardisation and avoids bad habits creeping in.
My view is that the 6/6 rolling currency is better in the typical GA context because it forces the pilot to always seek out IAPs and fly them, whereas the EASA IR holder can fly visual approaches all year and then do a couple on his annual test.
The advantage of the 6/6 rolling currency is that one can perform it without a CFI or CFII and just a safety pilot who is not likely to charge for their services. It leaves it to the pilot seeking currency to determine if they require instruction verses just practice to polish their skills. An IPC is not required unless you are 6 months past being current. so an additional 6 months to obtain currency without an IPC.
NCYankee wrote:
The advantage of the 6/6 rolling currency is that one can perform it without a CFI or CFII and just a safety pilot
Why do you need a safety pilot? Why can’t you just fly an instrument approach?
There is this strange idea in the UK that if you fly an instrument approach in VMC conditions then it is by definition a ‘training’ or ‘practice’ approach and thus people say you need someone in the right seat. I don’t understand the basis of that assertion – to me it is just an instrument approach that one is qualified to make, solo or with passenger/instructor, regardless of the weather conditions.
If pushed on the matter people tend to say that if you can see outside then you have a duty to see and avoid so you cannot fly a heads-down instrument approach on your own. Leaving aside the fact that ‘heads-down’ comes in all sorts of shades of grey, to that I counter: so what happens in IMC? It might seem facetious, but I don’t believe your legal responsibility to see and avoid is actually removed when in IMC, certainly in uncontrolled airspace. It seems a rather fatalistic view to assert that in IMC it’s ok to just hope you don’t hit anything. If anyone can show me a regulation saying that an aircraft in IMC in uncontrolled airspace has different collision avoidance responsibilities than one in VMC then I’d be most interested.
My instrument currency is poor at the moment and I need to revalidate my IMCr/IR(R) by November – I have already had a Covid-19 extension. My last instrument approach was at EGTK Oxford about a month ago – in severe CAVOK, to a full-stop landing and alone in the cockpit. Did I do a little bit of looking outside for collision avoidance? Yes – a tiny bit but I was in receipt of a radar service. Was I flying an instrument approach? Yes. Was it a ‘practice approach’? No.
I did not put it in my logbook as ‘instrument time’ but that does not mean it was not an instrument approach, nor does it make it practice/training.
Graham wrote:
Why do you need a safety pilot? Why can’t you just fly an instrument approach?
You can and it’s certainly good practice – but it doesn’t count, at least not in FAA-land.
For currency an approach has to be either
- flown at least partly in IMC
- flown under the hood with a safety pilot in the right seat
Reason being IFR vs VFR and ATC. On a practice approach you don’t actually enter the ATC IFR environment. The phraseology here is ‘XYZ cleared for the ABC 25 practice approach, no separation services provided’. IOW you need to self-separate from other traffic and – at least technically – also have to observe the VFR visibility and cloud clearance minima. In short: to all intents and purposes you’re flying VFR.
172driver wrote:
Reason being IFR vs VFR and ATC. On a practice approach you don’t actually enter the ATC IFR environment.
Who decides it’s a practice approach? Is it always a practice approach if the weather is above some maxima?
‘Flown at least partly in IMC’ – is that verbatim from the regs? How is that defined/interpreted? If you nip through a tiny puff of cumulus while being vectored to intercept, is that enough?
I have never understood what constitutes a ‘practice’ approach. When I flew into EGTK a month ago the ATC phraseology was exactly as if it were OVC003 and from the perspective of both me and the controller there was no difference whatsoever. There was nothing ‘practice’ about it – I was flying to the airport and upon initial contact requested vectors to the ILS. I didn’t book a training slot or anything like that.
If an FAA-licenced airline pilot flies an instrument approach in a B747 and the conditions happen to be visual, does that mean it does not count for currency purposes? In this sort of situation, is someone counting? Do they say “Ah, we were in quite a bit of cloud on that one so you can log it for IR currency purposes”?
Graham wrote:
Who decides it’s a practice approach?
You do. You ask for it. If you fly approaches for currency and the wx is good enough you never enter the IFR system. You fly VFR and ask ATC for a practice approach to whatever airport you want to go to. You also tell them which approach you want (doesn’t always mean you get it, but that’s the procedure). Essentially your entire flight is VFR, BUT with an approach thrown in. You can do this all day long if you like. Actually it’s something we do on a pretty regular basis here, going from one L.A. area airport to the next and so on and shoot on approach after the other. Do this for a couple of hours and you get a good workout. In between the approaches you normally are on Flight Following.
Graham wrote:
If you nip through a tiny puff of cumulus while being vectored to intercept, is that enough?
This part isn’t perfectly clear, but this document might help local copy
Graham wrote:
If an FAA-licenced airline pilot flies an instrument approach in a B747 and the conditions happen to be visual, does that mean it does not count for currency purposes?
Correct, at least to the best of my knowledge. I’ve had that discussion with a few CFIs and the answer has always been unequivocally no.
172driver wrote:
Do this for a couple of hours and you get a good workout. In between the approaches you normally are on Flight Following.
I help out a friend as safety pilot periodically and we typically do 6 approaches at 3 airports in one flight, one uncontrolled. All under the hood for him.
Graham wrote:
There is this strange idea in the UK that if you fly an instrument approach in VMC conditions then it is by definition a ‘training’ or ‘practice’ approach and thus people say you need someone in the right seat
As in “EASA-land” the number of instrument approaches and the instrument time is completely irrelevant for all practical licensing purposes that’s a pure semantic statement (and obviously helps ATC as they do not need to take care of separation, …)
Graham wrote:
If an FAA-licenced airline pilot flies an instrument approach in a B747 and the conditions happen to be visual, does that mean it does not count for currency purposes?
As no-one would be able to prove that there hasn’t been that small patch of Cu somewhere, I’d assume there is at least as much creative reporting as in Pakistani theory skill tests ;-)
On a more serious note (and just out of curiosity): What is the FAA definition of “IMC” in this regard? Do you have to actually be in a cloud or is it enough, that you are not able to maintain required VFR cloud clearance (i.e. you are legally IMC already when you are closer than 100ft above a cloud)?
IIRC the last FAA chief counsel view on this is that you have to be in IMC at the FAF. Previous thread.
Graham wrote:
If an FAA-licenced airline pilot flies an instrument approach in a B747 and the conditions happen to be visual, does that mean it does not count for currency purposes?
An important distinction is the 747 pilot is probably operating under Part 121. Part 121 or 135, and for that matter type rating holders are subject to there own proficiency requirements. These checks are available for all prospective employers to view BTW. There is not a complete overlap but essentially the FAA IR 6/6 requirements in effect only applies to “private” operations i.e. part 91, because the 121 requirement are at least as good. It is a good system that encourages you to practise.
