How Does a CFI Maintain Pax Carrying Currency

[C of G]

How about this one... We all know currency landings made during the day do not count towards night currency, but do night currency landings count towards day currency?

 

I say it does because the reg doesn't state a time during the day that those landings must be completed the way it does for night. I've asked this of a handful of instructors at my school and they seem to be split 50/50.

 

The night counts towards the day. It used to be spelled out a lot clearer, but if you can manage to follow the logic of the current iteration, then yes, night counts for the day.

 

Again, don't take anyone's word for it, it's all in black and white. Not saying there aren't plenty of grey areas, but a lot of these basic regs have been bashed out a long tmie ago.

 

 

As my high school geometry teacher, Mr McGuinness used to say

 

"We are merely midgets standing on the shoulders of giants"

 

We aren't pioneering any of this stuff.

[C of G]

Decending through clouds while getting vectored, and ending up lined up on the runway when finally breaking through is a pretty good indication of an instrument approach made.

 

Ok, so it was an ASR? PAR? I don't know if there is a PAR in atlanta. You got your own controller. Cool. Log it. But just flying through the clouds and descending doesn't make it an instrument approach.

Edited August 3, 2012 by C of G

[jimbo2181]

Great minds think alike c of g.

[nightsta1ker]

If it is not written it is not required. It is written for nvg currency. I won't be held to implied rules and regulations.

 

So just out of curiosity, would you consider picking the helicopter up into a hover and setting it back down three times "three take offs and landings?". I think that's kind of a no brainer. Now, traffic patterns might not be a requirement but some sort of departure, en route, and approach to landing need to be performed. Ferrying a helicopter between airports for maintenance is how I maintain my currency. As long as I log three of those flights every 90 days I'm covered. Those flights are usually my only opportunity to be the sole manipulator of the controls. I understand your point about not being held to implied regs. I HAVE seen SOMETHING in writing but I don't know where it is. When/if I find it I will post it. In the meantime, don't mind me. I really don't care what you do or don't do. Just don't do it near me!

[C of G]

So just out of curiosity, would you consider picking the helicopter up into a hover and setting it back down three times "three take offs and landings?". I think that's kind of a no brainer. Now, traffic patterns might not be a requirement but some sort of departure, en route, and approach to landing need to be performed. Ferrying a helicopter between airports for maintenance is how I maintain my currency. As long as I log three of those flights every 90 days I'm covered. Those flights are usually my only opportunity to be the sole manipulator of the controls. I understand your point about not being held to implied regs. I HAVE seen SOMETHING in writing but I don't know where it is. When/if I find it I will post it. In the meantime, don't mind me. I really don't care what you do or don't do. Just don't do it near me!

 

I agree, that I think I saw it once, but I can't find it either. And, again, a lot of this is academic, just fun to bounce back and forth.

[jimbo2181]

So just out of curiosity, would you consider picking the helicopter up into a hover and setting it back down three times "three take offs and landings?". I think that's kind of a no brainer. Now, traffic patterns might not be a requirement but some sort of departure, en route, and approach to landing need to be performed.

 

Absolutely I would consider TAKING OFF into a hover and LANDING three times 3 takeoffs and landings.

 

I also recall nothing about "some sort of departure, enroute, and approach..." being required to be performed except in the instance of NVG currency.

 

As C of G stated the wording choice is very similar to what is put on the NVG currency requirements in the same section of the FARs. Because they went to the trouble of adding it to the NVG section and not the VFR section I would gladly let the FAA try and tell me I don't meet VFR currency for only taking off into a hover and landing three times. My lawyer would have a field day stripping apart their "implied" regulation.

[jimbo2181]

I agree, that I think I saw it once, but I can't find it either. And, again, a lot of this is academic, just fun to bounce back and forth.

 

Definitely just academic. I haven't had to worry about currency since I got my certificate 10 years ago. Beyond academics if I hadn't touched a helicopter in 90 days and wanted to take ma out to see the sights I would probably spend the extra couple hundred bucks to go up with a CFI and run myself through the ringer rather then just do a few patterns.

[nightsta1ker]

As always, if you can apply some common sense you will very likely never have a problem. The issue is that common sense is not really that "common". These regs are really only there to crucify those that make grievous errors that cost lives or damage to property. As I have said before, this is the rope we are given to hang ourselves with. Understanding the intent, as well as the absolute legal limit of the regs is good, but as we all know and has been stated by many, not commonly adhered to. I try and follow the letter of the law as much as possible because in doing so I create that mindset for my students. That gives me less of a chance of one of THEIR booboos catching up with ME later.

[C of G]

Discussing the whole current vs. proficient argument is, to me, another matter. I was really just looking at the letter of the law. So where that other (or couple of other threads) went off the rails, I am just looking to get the wheels spinning. Night shift in the swamp is obviously taking it's toll on my sanity.

[Pohi]

That whole flight in the traffic pattern thing I did find in one place, it's not under staying current it is for getting the rating.

 

61.129©(4)

 

(ii) 5 hours in night VFR conditions with 10 takeoffs and 10 landings (with each landing involving a flight in the traffic pattern).

 

That's the only place I found it so far

[Pohi]

 

 

Ok, so it was an ASR? PAR? I don't know if there is a PAR in atlanta. You got your own controller. Cool. Log it. But just flying through the clouds and descending doesn't make it an instrument approach.

 

I have no idea, I was 13 rows back from the cockpit. Next time, I'll ask the captain though, just to make sure that when I'm making a joke about logging an instrument approach in a plane that im not even type rated in, nor even in the cockpit, or even at the controls, I wont have some guy telling me that I'm wrong because he knows so much more about what I was doing.

[C of G]

Yeah I suppose mentioning that you were in a cabin instead of the cockpit as a crew member might help clarify when you're quoting someone on a helicopter forum.

 

Otherwise we might get the impression that you were adding something to the discussion.

 

Some helicopter pilots do fly ASRs with their students IMC. And they can log the currency even when they're not on the controls.

[eagle5]

Absolutely I would consider TAKING OFF into a hover and LANDING three times 3 takeoffs and landings.

 

Although the reg doesn't say it specifically, I just don't feel as if I'm really following the "spirit" of the reg unless I fly around the pattern!

 

This is just another reg that was written by someone who didn't take helicopters into consideration! If they had, I'll bet they would have stipulated that it had to be more than just a pickup and setdown!?

[iChris]

Absolutely I would consider TAKING OFF into a hover and LANDING three times 3 takeoffs and landings.

 

I also recall nothing about "some sort of departure, enroute, and approach..." being required to be performed except in the instance of NVG currency.

 

 

Correct, nothing in 14 CFR 61 or 91; however, an interpetation implies a forward phase of flight between takeoff and landing:

 

 

September 18, 1990

 

Mr. John C. H. Miller

 

Dear Mr. Miller:

 

This is in response to your letter concerning Federal Aviation Regulation Section 121.311(d). Your questions and our responses follow.

 

We wish to point out that legal interpretations are issued in respect to actual or realistic hypothetical fact situations. Since you have presented us with neither situation, while we have done our best to answer your questions, a definitive legal interpretation would depend upon the facts of the situation in which the rule is to be applied.

 

Question #1. Regarding Section 121.311 [ d ], please define the language "takeoff."

 

Response #1. The Federal Aviation Administration (FAA) published a glossary in 1975 titled the FAA Glossary. In that glossary the term "takeoff" is defined as: "The act of beginning flight in which an aircraft is accelerated from a state of rest to that of flight. The departure time of the aircraft is considered as the time the aircraft leaves the takeoff surface."

 

Question #2. Regarding same section, please define the term "land."

 

Response #2. Neither the term "land" nor "landing" is defined in the FAA Glossary. However, we believe that, as generally understood in aviation, the term refers to the act of terminating flight in which the aircraft is made to descend, lose flying speed, establish contact with the ground, and finally come to rest. (Jordanoff's Aviation Dictionary, Harper and Brothers Publishers, p.210.) ... I trust this satisfactorily responds to your request.

 

Sincerely,

 

 

/s/ Donald P. Byrne

Acting Assistant Chief Counsel

Regulations and Enforcement

Edited August 4, 2012 by iChris

[eagle5]

"...accelerated from a state of rest to that of flight"

 

"...lose flying speed,"

 

Looks like a couple of AIRPLANE statements to me! We need to put a helicopter pilot in that office!

[nightsta1ker]

Do helicopters not do those things? I think their point is once again inferring that the intent of the regulation on three take offs and landings is that those takeoffs and landings be made to and from a forward flight condition.

 

Now, keep in mind also that most of those FAA people ARE pilots and quite a few of them are dual rated. The reason helicopters have been left so much out of the regs is because over regulating us will severely limit what we are capable of doing and the FAA does not want that any more than we do.

 

I'm perfectly happy with the regs as they are. I understand that they were written for fixed wing and that because of that there are some very gray areas that helicopters operate in. This is more of an advantage to us than it is a hindrance. My advice as a CFI is: know the rules and abide by them to the best of your knowledge and ability.

[Parafiddle]

My thought is that, as others have already mentioned, the intent of the regulation is that you made some kind of take-off, approach and landing for it to qualify as a landing. If an airplane takes off, does a lap in the pattern, an approach, and then bounces in the air twice while landing after the wheels touch the runway in between bounces, does that qualify as three take-offs and landings? Of course not, only as one bad landing. Seems like lifting up into a hover and setting back down in a helicopter three times would be the equivalent as my scenario above.

 

In my opinion, there is a lot more going on when you transition from forward flight to a landing vs. just getting into a hover and then setting it back down.

[Pohi]

An air taxi should do the trick for the intent

[Gomer Pylot]

I haven't bothered to log much for a long time. You're only required to log anything in order to prove eligibility for a rating or currency. I'm only interested in proving currency at this point. But once upon a time I did log extra landings, since my employer charged the customer for flight time at the rate of 2 minutes per takeoff, not bothering to actually keep track of flight time. I rarely logged fewer than 100 takeoffs per day, with a total of well over 9000 in 6 months. By the time those 6 months were up, I could land a 206B on an offshore platform pretty well. But logging landings for currency by just lifting to a hover and back down is so ridiculous I couldn't bring myself to do it no matter what. If I were an employer and read posts where someone advocated that, his chances of employment with me would be zero. But again, it's your logbook.

[eagle5]

Do helicopters not do those things? I think their point is once again inferring that the intent of the regulation on three take offs and landings is that those takeoffs and landings be made to and from a forward flight condition.

 

Now, keep in mind also that most of those FAA people ARE pilots and quite a few of them are dual rated. The reason helicopters have been left so much out of the regs is because over regulating us will severely limit what we are capable of doing and the FAA does not want that any more than we do.

 

I'm perfectly happy with the regs as they are. I understand that they were written for fixed wing and that because of that there are some very gray areas that helicopters operate in. This is more of an advantage to us than it is a hindrance. My advice as a CFI is: know the rules and abide by them to the best of your knowledge and ability.

 

So just move forward a few feet then sit it back down!

 

Ok, lets say the reg was written;

 

"...each landing involving a flight around a traffic pattern...helicopters must take each landing all the way to a surface."

 

How does that severly limit what we are capable of doing?

 

Lets say that other reg was written;

 

"...when the airfoil begins to move with the intent of flight, logging of flight time begins, and ends when the airfoil comes to rest after landing."

 

How does that severly limit what we are capable of doing?

 

And what if 91.103 was written;

 

"...for any flight (except helicopters) runway lengths at airports of intended use..."

 

How does that severly limit what we are capable of doing?

 

I'm tired of inferring the "intent" of the regulation!

 

Something tells me I'm going to get beat up for this!

Edited August 4, 2012 by eagle5

[ridethisbike]

A pick up is WAY different than a takeoff, and a set down is WAY different than a landing. I almost feel as if you are arguing just for the sake of arguing now...

 

Plenty of advise and reference has been posted as to what the FAA means with the reg. If that isn't enough for you, email, call or snail mail them yourself and see what they think of your interpretation. Worst that can happen is they shoot you down right? I don't see that as a bad thing as long as you get the clarification you need.

 

 

And 91.103? Really? C'mon man, you're better than this...

[eagle5]

A pick up is WAY different than a takeoff, and a set down is WAY different than a landing. I almost feel as if you are arguing just for the sake of arguing now...

 

Plenty of advise and reference has been posted as to what the FAA means with the reg. If that isn't enough for you, email, call or snail mail them yourself and see what they think of your interpretation. Worst that can happen is they shoot you down right? I don't see that as a bad thing as long as you get the clarification you need.

 

 

And 91.103? Really? C'mon man, you're better than this...

 

You're obviously missing the point of my post! Read it again (along with #3) and you'll see my stance on currency flights!

[ridethisbike]

You're obviously missing the point of my post! Read it again (along with #3) and you'll see my stance on currency flights!

 

Touche! I read the entire thread, and had kept up with only the new posts. Some of what was said in the beginning disappeared from my brain. Next round is on me!