121 Check as IPC?

[Ralgha]

Does a 121 checkride count as an IPC for part 91 flying? I'm thinking it doesn't unless you get the additional signoff, which in my opinion is bull**CENSORED****CENSORED****CENSORED****CENSORED**, but unfortunatly I didn't write the rulebook.

 

[vclean]

FAR 61.57(d)(2)(iii) seems clear to me.

 

[Ralgha]

Yes it does, doesn't it? But often times someone whips out an interpretation that is completly opposite of what the FAR says. That's why I ask.

Also, that check pilot isn't giving a 91 IPC, they're giving a 121.441 or similar check.

 

[vclean]

Reread 61.57(d)(2). A proficiency check must be given by -
(i) an examiner
(ii) Armed forces examiner
(iii) 121, 125, 135 check pilot
(iv) Authorized instructor (you)
(v) FAA approved examiners

(iii) is one method of satisfying 61.57. 121.441 checks include items required for an ipc.

If you're still not convinced, ask your POI.

 

[A Squared]

But often times someone whips out an interpretation that is completly opposite of what the FAR says.

can you point to any interpretation which states the opposite of what a regulation says?



Anyway, regarding the 121PC/IPC issue: My personal opinion is that it does count, however, I had this discussion a while back on Doc's FAR forum, and Doc is of the opinion that it doesn't count.

http://www.propilot.com/doc/bbs/messages/6108.html

Doc has no official standing, nor is he an attorney, but he is very knowlegable about the regs. I have a great deal of respect for his opinion, however on this issue, I think he missed the boat. His position is that a 121PC doesn't consist of a *representative* number of tasks from the Instrument PTS, because you don't do unusual attitude recoveries, constant airspeed climbs and descents, or no-gyro approaches. My view is that *representative* doesn't mean *all* and you do most of the tasks in the PTS on a 121PC, and some tasks which are beyond the PTS. I'm thinking that if I can demonstrate cirling to land with 2 engines failed, maybe I oughtta get a pass on constant airspeed climbs. Presumabley, if I couldn't do those, I'd have been pinked at the "area departure" portion of the PC, right after takeoff.

I don't know of any official interepretations which address this, it would be interesting to see the Chief Counsel's opinon on this.

 

[iflyabeech]

(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.
(1) The instrument proficiency check must be--
(i) In an aircraft that is appropriate to the aircraft category;
(ii) For other than a glider, in a flight simulator or flight
training device that is representative of the aircraft category; or
(iii) For a glider, in a single-engine airplane or a glider.
(2) The instrument proficiency check must be given by--
(i) An examiner;
(ii) A person authorized by the U.S. Armed Forces to conduct
instrument flight tests, provided the person being tested is a member of
the U.S. Armed Forces;
(iii) A company check pilot who is authorized to conduct instrument
flight tests under part 121, 125, or 135 of this chapter, and provided
that both the check pilot and the pilot being tested are employees of
that operator;
(iv) An authorized instructor; or
(v) A person approved by the Administrator to conduct instrument
practical tests.

 

[iflyabeech]

I don't know who this "Doc" guy is, but of course 121 check or a 135.297 ride counts as an IPC. A .297 is basically an ATP checkride.

How many airline pilots do think do IPC check with a local CFI to get current?

LOL

 

[Jim]

How many airline pilots do think do IPC check with a local CFI to get current?

LOL

Just because you are current under 121 does not mean you are current under 91. My 121 Captain PC makes me both instrument current and night landing current. I stay instrument current until my next PC regardless of the number of approaches I shoot. I can shoot none. Usually the next PC is within 6 months so this is a moot point. But there is a 30 day grace period - so it could be 7 months between PCs - and I will be current under 121 for that 7th month where I won't under 91. I can fly the airline's plane IFR but not a Cessna. Same type of situation for night landings. As long as I make 3 lands day or night every 90 days, I remain 121 current for night but not under 91.


Edit:

read 61.57 e dude

Yes I can fly my carrier's aircraft under part 91 in the situations I described above. But I can not just jump in any GA aircraft and take it for a night or IFR spin if I'm in my grace month and do not otherwise meet 61.57 a thru d requirements. For 61.57e(2) is my situation and its exceptions are only for my carrier's aircraft.

 

[iflyabeech]

read 61.57 e dude

 

[Ralgha]

can you point to any interpretation which states the opposite of what a regulation says?

The interpretation that says CFI checkrides don't count as BFRs. Granted it's not exactly contrary because you have to pull in the PTS as well. The BFR requirement says pilot proficiency checks count, the CFI PTS says the applicant must fly to commercial standards, and the examiner (I hope) won't pass someone who can't fly. Therefore, I see it as a pilot proficiency check. The interp doesn't.

I've heard there might be an interp saying that a CFI with only an instrument rating (no ASEL or AMEL) can give instrument instruction in a twin. If true, this is 180 degrees opposite of the regs, which quite clearly state that if you don't have the approprate cat/class ratings, you can't instruct in the aircraft, end of story.

Anyway back to the topic at hand.

Paragraph (e) does not apply. In order for it to work, the 91 operation must be for the 121 company. Personal flying would not qualify.

However, I do agree that the 121 check contains a representative number of tasks from the checkride, so perhaps it would count. All of the tasks are not needed, an IPC is not a checkride.