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.

 

[iflyabeech]

What does a CFI or commercial anything have to do with an IPC?

By the way, I got my CFII before the CFI single and multi, and
I could give instrument instruction as long my pilot ratings were for that category and class of aircraft, which they were.
Ref. 61.195

Also, there is no need for an IPC if you have done the 6 approaches, holding, etc. . . and what IFR 135 or 121 driver who was actually flying wouldn't have stayed current by normal flying??

I could also explain that a 135.293 check, or the equivilent 121 check also serves as a BFR. But that is a different subject altogether also. Ref 61.56 (d)

Ha! Next you will tell me that we can't shoot an approach when the ceiling is lower than the MDA or DH! (note-ceiling doesn't matter, it is visibility)

That should really get you guys going, lol!

 

[Ralgha]

What does a CFI or commercial anything have to do with an IPC?

Do you read? I was answering his question of what interps are there that contradict the rules.

By the way, I got my CFII before the CFI single and multi, and
I could give instrument instruction as long my pilot ratings were for that category and class of aircraft, which they were.
Ref. 61.195

Maybe you should try reading that reference you gave. I'll even reproduce the important part with emphasis added to make it easy.

61.195

(b) Aircraft ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:
(1) A pilot certificate and flight instructor certificate with the applicable category and class rating; and

(2) If appropriate, a type rating.


Any questions?

Also, there is no need for an IPC if you have done the 6 approaches, holding, etc. . . and what IFR 135 or 121 driver who was actually flying wouldn't have stayed current by normal flying??

Obviously you have not been keeping up on the weather in the Pacific Northwest.

]I could also explain that a 135.293 check, or the equivilent 121 check also serves as a BFR.

Obviously. It's quite black-and-white in the regs.

Ha! Next you will tell me that we can't shoot an approach when the ceiling is lower than the MDA or DH! (note-ceiling doesn't matter, it is visibility)

That should really get you guys going, lol!

Likewise this is quite clear in the regs.

 

[iflyabeech]

Gotcha dude. You should try to not be such a jerk, especially when you are wrong!


read 61.195 c, it pertains to INSTRUMENT training!


You should quit listening to "interps" or whatever that is and read the regs.

LOL

nice bold type by the way!

LOL

 

[Ralgha]

Gotcha dude. You should try to not be such a jerk, especially when you are wrong!

I could say the same to you.

read 61.195 c, it pertains to INSTRUMENT training!

Yes, it does, however it does not overrule part b. Part b says, and I quote "A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold:" It does not qualify it to a specific kind of flight training, nor does it provide for any exceptions in other paragraphs as is often seen elsewhere in the regs.

You should quit listening to "interps" or whatever that is and read the regs.

Oh how I wish I could, unfortunatly the interpretations are what will kill you in court.

nice bold type by the way!

Thanks I try.

 

[JAFI]

Oh how I wish I could, unfortunatly the interpretations are what will kill you in court.
.

That is intersting, I have never seen any one "killed" in court. Some people can leave pissed off but not dead....

Perhaps you need to understand what an interpitation is. An Airman writes to FAA Legal with a specific question on the application of a CFR. An FAA Lawyer will answer the letter. In court, the Judge will determine if you complied with the regulations after hearing arguments from both sides. If you have an interpitation that you followed the judge may think (I do not tell Judges how or what to think) that you were acting in a compliant manner. If you showed the FAA lawyer the letter you were trying to comply with before the trial, there may never be a trial. A Letter of interpitation is just that, a specific INTERPITION of some part of a CFR (Code of Federal Regulations - FAR's went out when the FAA Act of 1958 was codified in 1998).

JAFI

 

[iflyabeech]

Ralgha, if you are that naive I will let you be.

There is a difference between instruction towards an aircraft rating, and towards an insturment rating and that is spelled out in 61.195 b & c.

However, know it all 1700 hr flight instructors who are DORK enough to list every airplane they ever looked at are sure to be right:
Aircraft Experience: C120, C150, C152, C172, C172RG, C177, C182, C185, C310, C402, PA28-161, PA28-180, PA28R-200, PA30, PA44, RV6A, M20E, M20J, SR22, SNJ-5

Think what you want, but you are a DORK!

 

[A Squared]

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.

Doc is an airline pilot who also runs a forum dedicated to aviation regulations. It's a pretty useful site, and Doc is pretty resourceful when it comes to digging up relevant interpretations and other official sources. Like I said, his forum has no official standing, but it is a useful source of info. Again like I said, I don't agree with his views on this, but I mentioned them as an alternate view. your results may vary.

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.

No it's not contrary at all. it is in 100% agreement with the text of the regulation.

The regulation specifies a checkride for a *pilot* certificate. At the end of a sucessful CFI checkride, does the examiner give you a pilot certificate? no he gives you an *instructor* certificate. An instructor certificate is not a pilot certificate. Take it out of your pocket and look at it carefully. You'll notice that the only place you'll find the word "pilot" is where it says: "valid only when accompanied by pilot certificate #xxxxxxxx"

Walk into an FBO where you are not known. Ask to rent an airplane. Show them only your instructor certificate ... think they're going to rent you an airplane?

Next time you get ramp checked, show only your instructor certificate to the inspector .... think he will accept that?

Bottom line is that the instructor certificate is not a pilot certificate, and the regulation specifies a checkride for a pilot certificate. There is nothing in the interpretation which is contrary to the regulation.

 

[Ralgha]

iflyabeech:

Now you stoop to petty insults. If that makes you feel better, fire away, I really don't care.

(b) is not refering to instruction for ratings, it is referring to FLIGHT INSTRUCTION. The little heading in the front "Aircraft Ratings" is referring to the instructor's ratings, not training for ratings. This is further supported by the fact that (c) includes the verbage "provides instrument flight training for the issuance of an instrument rating or type rating not limited to VFR". Notice that (b) has no such language in it limiting it to aircraft ratings.

About the BFR thing, I know why it doesn't count, and I shouldn't have shown it as being contrary to the regs because it's not really. But, in my OPINION, it should count since the PTS requires pilot proficiency at the commercial level. My opinion means nothing and I know that so don't anyone bother trying to tell me please.

 

[A Squared]

But, in my OPINION, it should count since the PTS requires pilot proficiency at the commercial level.

Yeah, and I'd tend to agree with that opinion, but tlike you pointed out, our opinions on the matter are somewhat irrelevant.

 

[iflyabeech]

(b) is not refering to instruction for ratings, it is referring to FLIGHT INSTRUCTION. The little heading in the front "Aircraft Ratings" is referring to the instructor's ratings, not training for ratings. This is further supported by the fact that (c) includes the verbage "provides instrument flight training for the issuance of an instrument rating or type rating not limited to VFR". Notice that (b) has no such language in it limiting it to aircraft ratings.

Dude, you are wrong and you are a dork. Do you realize that people laugh at dorks like you that read too much into the regs?

I know folks who have nothing but a CFII and they give instrument instruction and sign people off for IFR rides, IPC's and such. Do you really think the FAA would allow his 8710 signoffs to go through when they issue the rating if he is not legal to give instruction? Do you really think the FAA would issue an Instrument Instructor rating as the only instructor rating if it were not legal or if it was not legal to use it? Use some common sense and chill with all of your dorky questions.

In time you will realize your dorkness.