IFR recency and the 6/6/6 rule

[dougj]

Can someone please point out the section of CARS stipulating what must be done to maintain the IFR rating? In case I misunderstand the legalese here is my question: My 12 month grace period after passing the flight test has lapsed without making the 6/6/6 (my bad). Does the 6 month rule start now, meaning can I fly solo IFR within the next 6 months and be legal or has that opportunity passed? I read a synopsis that once the 12 months have passed, the 6 month rule applies so does that mean the 12 month grace period is really a 6 monther?
Thanks
(Damn icing!)

[photofly]

you're now not legal to fly IFR today because in the last six months from today you don't have six approaches to minimums and six hours of instrument flight. You'll need six hours under the hood with a safety pilot and to complete six simulated approaches in VMC to minimums before you can exercise the privileges of your instrument rating.

Alternatively you can take an instrument proficiency check following the successful completion of which you will not have to meet the 6/6/6 rule for the next twelve months.

It's a 12 month grace period.

[girouxc]

Check Advisory Circular (AC) No. 401-004

[snakesonaplane]

If you hold a group 1 IFR, do the 6/6/6 have to be done in a multi engine airplane? Or can you do it in a single and still maintain group 1 currency?

[Big Pistons Forever]

you're now not legal to fly IFR today because in the last six months from today you don't have six approaches to minimums and six hours of instrument flight. You'll need six hours under the hood with a safety pilot and to complete six simulated approaches in VMC to minimums before you can exercise the privileges of your instrument rating.

Alternatively you can take an instrument proficiency check following the successful completion of which you will not have to meet the 6/6/6 rule for the next twelve months.

It's a 12 month grace period.

The 6 Instrument approaches can't be done in VMC with a safety pilot because the definition of an "Instrument Approach " in CAR 101.01 is

Instrument approach means the orderly positioning of an IFR aircraft from the enroute phase to a position and altitude from which a landing may be completed or a missed approach procedure may be initiated; (approche aux instruments)

Since you can't file IFR you can't fly the approaches on your own. You can do them with an IFR rated Instructor or another person who meets the requirements of CAR 425.21 (9) (b)

[photofly]

you're now not legal to fly IFR today because in the last six months from today you don't have six approaches to minimums and six hours of instrument flight. You'll need six hours under the hood with a safety pilot and to complete six simulated approaches in VMC to minimums before you can exercise the privileges of your instrument rating.

Alternatively you can take an instrument proficiency check following the successful completion of which you will not have to meet the 6/6/6 rule for the next twelve months.

It's a 12 month grace period.

The 6 Instrument approaches can't be done in VMC with a safety pilot because the definition of an "Instrument Approach " in CAR 101.01 is

Instrument approach means the orderly positioning of an IFR aircraft from the enroute phase to a position and altitude from which a landing may be completed or a missed approach procedure may be initiated; (approche aux instruments)

Since you can't file IFR you can't fly the approaches on your own. You can do them with an IFR rated Instructor or another person who meets the requirements of CAR 425.21 (9) (b)

Nice try. But, no. Read 401.05(3)(b) more carefully.

Wait a minute.... you're saying that although it can explicitly be under simulated instrument conditions, it doesn't count as an "approach" unless the flight is made on an instrument flight plan? I don't believe any TC inspector would support that interpretation.

For instance, you can take and pass your instrument rating flight test by flying your "approaches" without an IFR flight plan on the agreement of the examiner, It would bizarre to insist that an IFR flight plan was required to maintain your currency.

[lownslow]

I wonder if 101.01 means an IFR equipped aircraft?

[SuperchargedRS]

Aside from the rules, if you're not even shooting one real approach a month, would you really even want to fly IFR/IMC?

Honestly even flying twice the requirement, I wouldn't feel good shooting a STAR to a ILS at 0300L, down to mins in chit weather.

[spit_IX]

If you hold a group 1 IFR, do the 6/6/6 have to be done in a multi engine airplane? Or can you do it in a single and still maintain group 1 currency?

CAR 401.05(3)(b) and (c) specify that you can maintain your instrument rating currency by

(b) Completing your 6/6/6 in an aircraft in simulated or actual instrument conditions, or in the appropriate simulator, of the same category (i.e. aeroplane). Doesn't mention anything about classes.

(c) Completing your 6/6/6 in an aircraft in simulated or actual instrument conditions, while acting as a flight instructor toward the endorsement of a licence/permit with an instrument rating.

So, my interpretation is that as long as your 6/6/6 was done in the same category of aircraft, you should still be valid for group 1 no matter what class of aeroplane it was.

[photofly]

Sure... the weather doesn't need to be anywhere close to approach minimums to make an IFR flight in IMC useful.

[Rookie50]

Sure... the weather doesn't need to be anywhere close to approach minimums to make an IFR flight in IMC useful.

+1. Often it's simple cruise IMC or a transition on top.

[SuperchargedRS]

Sure... the weather doesn't need to be anywhere close to approach minimums to make an IFR flight in IMC useful.

True.

However if you're not comfortable shooting a ILS to mins in chit weather you probably shouldn't be filing IFR or going IMC, weather has been know to be a unpredictable at times


If you're filing as a /whatever you should be able to preform to all the abilities of that airframe IMHO.

[photofly]

Nonsense. a forecast 2000' OVC becomes VV100 just about never. By the same argument you'd never be safe flying VFR, because, you know, weather has been known to be unpredictable at times.

[Rookie50]

Nonsense. a forecast 2000' OVC becomes VV100 just about never. By the same argument you'd never be safe flying VFR, because, you know, weather has been known to be unpredictable at times.

Arguably more so.

Also, People are at different levels. Was out a couple weeks back, heading back to ZBA and an unforecast snowshower happened along. Radio lit up with requests for headings and diversions from VFR pilots. I went into it, vis maybe 2 -3 miles. VFR -- sure. Comfortable for everyone -- nope.

It's no shame to always plan for and have a chicken out, IFR or VFR, for better conditions.

[SuperchargedRS]

Nonsense. a forecast 2000' OVC becomes VV100 just about never. By the same argument you'd never be safe flying VFR, because, you know, weather has been known to be unpredictable at times.

I don't think you're getting what I'm laying down here.

If you're flying IFR you should be able to fly IFR, all phases of flight.

If you're flying VFR you should be able to fly VFR all phases of flight.

If you're unable, you ether

1 should land.
2 shouldnt fly under those flight rules.
3 should declare a emergency.
4 shouldnt set foot in said plane until you receive dual instruction and become capable and comfortable flying in all phases of flight under said flight rules.

[photofly]

I think I understand what you're saying, and for reasons expressed earlier, disagree strongly.

I don't have to feel comfortable flying an ILS to minimums in a 40kt crosswind in a C172 or circling to land at 500 agl in the dark on a moonless night, in order to make sensible and safe use of the privileges of an instrument rating. That's why we establish the concept of personal minimums.

Any more than a VFR pilot needs "retraining" until they're comfortable cruising cross country under a 1200 overcast in 2 to 3 sm visibility.

An instrument rating extends your legal bounds, and you still have to pick your days and destinations where and when the weather will remain appropriate to your personal minima.

[Big Pistons Forever]

I wonder if 101.01 means an IFR equipped aircraft?

From CAR 101.01

IFR means instrument flight rules; (IFR)

IFR aircraft means an aircraft operating in IFR flight; (aéronef IFR)

IFR flight means a flight conducted in accordance with the instrument flight rules; (vol IFR)

An IFR aircraft is by definition conducting an IFR flight, which by definition means it is operating under Instrument flight rules.

[Rookie50]

I think I understand what you're saying, and for reasons expressed earlier, disagree strongly.

I don't have to feel comfortable flying an ILS to minimums in a 40kt crosswind in a C172 or circling to land at 500 agl in the dark on a moonless night, in order to make sensible and safe use of the privileges of an instrument rating. That's why we establish the concept of personal minimums.

Any more than a VFR pilot needs "retraining" until they're comfortable cruising cross country under a 1200 overcast in 2 to 3 sm visibility.

An instrument rating extends your legal bounds, and you still have to pick your days and destinations where and when the weather will remain appropriate to your personal minima.

Can't agree more. I have rules I exercise in my IFR flights, appropriate to my recency and total experience. More dual would not change those factors.

[khedrei]

I wonder if 101.01 means an IFR equipped aircraft?

From CAR 101.01

IFR means instrument flight rules; (IFR)

IFR aircraft means an aircraft operating in IFR flight; (aéronef IFR)

IFR flight means a flight conducted in accordance with the instrument flight rules; (vol IFR)

An IFR aircraft is by definition conducting an IFR flight, which by definition means it is operating under Instrument flight rules.

See 401.05 posted above.

You can maintain currency for the 6/6/6 in simulated or actual conditions. If you can simulate it, the plane need not be equipped for IFR flight.

[careerpilot?]

If you hold a group 1 IFR, do the 6/6/6 have to be done in a multi engine airplane? Or can you do it in a single and still maintain group 1 currency?

CAR 401.05(3)(b) and (c) specify that you can maintain your instrument rating currency by

(b) Completing your 6/6/6 in an aircraft in simulated or actual instrument conditions, or in the appropriate simulator, of the same category (i.e. aeroplane). Doesn't mention anything about classes.

(c) Completing your 6/6/6 in an aircraft in simulated or actual instrument conditions, while acting as a flight instructor toward the endorsement of a licence/permit with an instrument rating.

So, my interpretation is that as long as your 6/6/6 was done in the same category of aircraft, you should still be valid for group 1 no matter what class of aeroplane it was.

I’m going to resurrect this thread to pull on this one, since the rest of the thread seems to take a different direction.

My read of AIC 401-005 supports this interpretation, there is a very clear note:

13. The 6- 6- 6 recency requirements referred to in paragraph 5.0(2)(B) of this AC must be completed in the same category of aircraft.

And the CARS say(100.01):

category means

(a) when used in reference to flight crew licensing, the classification of aircraft as an aeroplane, a balloon, a glider, a gyroplane, a helicopter or an ultra-light aeroplane, and

(b) when used in reference to the certification of aircraft, a grouping of aircraft based upon intended use or operating limitations such as normal, utility, aerobatic, commuter and transport; (catégorie)

So, is this the general interpretation used by the industry?

I fly helos for the RCAF and therefore maintain a Group 4 currency quite easily, but now that I also have a Group 1 I’m faced with how to maintain that currency. The above would imply I cannot use my rotary wing hours and approaches towards my Group 1, and I don’t have access to a twin to fly the hours. I do have access to an IFR rated 172 and therefore if I can do my 6/6/6 in the 172 that’s what I’ll do.

My other option is an IPC in the redbird sim across the street, which would have the advantage of resetting me for another 12mos rather than 6, but I’d rather build airplane PIC time while I do it.

[careerpilot?]

I believe I have my answer from this linked thread, which didn’t initially show up in search as the original post and title had been removed. It seems a single engine can be used to meet 6/6/6 for Group 1 recency.

viewtopic.php?t=213754

But I’m going to pull on the thread even farther! The CARS state:

(3.1) No holder of a Canadian pilot licence endorsed with an instrument rating or to which is attached instrument rating privileges shall exercise the privileges of the instrument rating unless, following the first day of the 13th month after the completion date of a test referred to in subsection (3) and within six months before the flight, the holder has

(a) acquired six hours of instrument time; and

(b) completed six instrument approaches in an aircraft in actual or simulated instrument meteorological conditions, or in a Level B, C or D simulator or an approved flight training device configured for the same category as the aircraft

(i) under the supervision of a person who holds the qualifications referred to in subsection 425.21(9) of Standard 425 — Flight Training, or

(ii) while acting as a flight instructor conducting training in respect of the endorsement of a flight crew licence or permit with an instrument rating.

The CARS don’t define aircraft, but they define aeroplane as “a power-driven heavier-than-air aircraft that derives its lift in flight from aerodynamic reactions on surfaces that remain fixed during flight.” Aircraft throughout the CARS seems to be used to refer to anything that flies (balloon, helicopter, aeroplane).

Therefore - I submit that 6/6/6 can be met in any aircraft, including a helicopter, and still count towards Group 1 recency. Almost seems too good to be true (one could technically meet 6/6/6 in a balloon if they could find one with instruments )

To pull even further, the 24 month requirement can be met by (one of):

(a) an instrument rating flight test in an aircraft or in a Level B, C or D simulator of the same group as the aircraft;

(b) a Canadian Armed Forces instrument rating flight test;

Again, note an instrument test in an aircraft. And no mention of a CAF IRT needing to be in the same category or class. This one I feel is thin - the wording implies it, but if 6/6/6 feels too good to be true, this one just feels wrong…

Am I crazy or missing something? I mean, I do enough IFR in helicopters that I feel comfortable with my personal recency in an aeroplane, it really isn’t that different. But is it legal?

[careerpilot?]

Anyone hear about TC changing 6/6/6 to be required after the 7th month, vs 13th? This effectively removes the year post IPC that used to be in place. This is the first I heard of it…

Source:
https://gazette.gc.ca/rp-pr/p2/2025/202 ... 1-eng.html

or
(10) Subsections 401.05(3.1) and (3.2) of the Regulations are replaced by the following:

(3.1) No holder of a pilot licence that is endorsed with an instrument rating or to which instrument rating privileges are attached shall exercise the privileges of the instrument rating unless, following the first day of the seventh month after the completion of a test or check referred to in subsection (3) and within six months before the flight, the holder has completed six instrument approaches in accordance with the minima specified in the instrument approach procedure

(a) in an aircraft, in actual or simulated instrument meteorological conditions;
(b) in an aircraft, in actual or simulated instrument meteorological conditions, while acting as a flight instructor who is conducting training in respect of the endorsement of a flight crew licence with an instrument rating;
(c) in a Level B, C or D full-flight simulator of the same group as the aircraft indicated on the pilot’s licence; or
(d) in a flight training device under the supervision of a person who holds the qualifications referred to in subsection 425.21(9) of the personnel licensing standards.

[OnceAgainWithFeeling]

That's correct (obviously) - but the 6 hours instrument flight requirement ("acquired six hours of instrument time; and") is being removed at the same time. So a couple of practice sessions of 3 quick approaches to minimums each and you're done.

[digits_]

That's correct (obviously) - but the 6 hours instrument flight requirement ("acquired six hours of instrument time; and") is being removed at the same time. So a couple of practice sessions of 3 quick approaches to minimums each and you're done.

Nice!


(also much easier to pencil whip )

[careerpilot?]

That's correct (obviously) - but the 6 hours instrument flight requirement ("acquired six hours of instrument time; and") is being removed at the same time. So a couple of practice sessions of 3 quick approaches to minimums each and you're done.

Yeah I just picked up on that! Positive change overall I’d say.