Night Currency

[Aviatard]

Here's another question:

Can a pilot without a multi-engine rating accompany an appropriately qualified pilot in a multi-engine aircraft and meet the recency requirement (for their own single engine privileges) by completing 5 takeoffs and landings in it?

No because recency is by category and class:
(i) in the case of an aircraft other than a glider or a balloon, in the same category and class of aircraft as the aircraft, or in a Level B, C or D simulator of the same category and class as the aircraft, at least

(A) five night or day take-offs and five night or day landings, if the flight is conducted wholly by day, or

[Big Pistons Forever]

I specifically asked our TC inspector the question of whether students are passengers or crew. I was asking in the context of the rule that says category 1 medical validity is 6 months or 12 months when 40 and over but less than 60 years old. It would make a difference to having to renew a medical. The answer I received is that students are not passengers, they are crew and therefore the medical validity period would be 12 months.

Of course your TC inspector may have a different opinion.

... and I was told the same thing, except that a student is a passenger during a familiarization flight. That distinction made no sense to me since nothing distinguishes air exercise 1 from the others. Asking on what basis a student isn't a passenger is what led to this.

I did learn one thing though, which is that inspectors all have their own personal interpretations of different regulations, and once you ask an inspector for their interpretation of something contentious you are somewhat bound to abide by it, even when that interpretation is different to yours. So sometimes it's better to come to your own conclusion based on the text of the regulations, and existing jurisprudence, and not to ask an inspector at all.

Ottawa has now come up with an official policy statement on this. Student pilots are crew members. A familiarization flight or discovery flight or what ever the FTU calls the first flight is conducted as Lesson Plan 1 of the FIG and therefore is "flight training" and the student is a crew member not a passenger so it is not a "single pilot" commercial flight. That being said I would make sure that the departure and landing airports were the same.

[photofly]

Here's another question:

Can a pilot without a multi-engine rating accompany an appropriately qualified pilot in a multi-engine aircraft and meet the recency requirement (for their own single engine privileges) by completing 5 takeoffs and landings in it?

No because recency is by category and class:
(i) in the case of an aircraft other than a glider or a balloon, in the same category and class of aircraft as the aircraft, or in a Level B, C or D simulator of the same category and class as the aircraft, at least

(A) five night or day take-offs and five night or day landings, if the flight is conducted wholly by day, or

Right. Thanks. That one, at least, seems clear-cut.

[Big Pistons Forever]

When I say you can't log the flight time, I mean that you can't claim the time towards the issue of any licence or rating. I don't mean that you can't enter the flight in your logbook. If you were claiming credit for the landings in your logbook you would in fact be required to enter the flight. I have many flights recorded in my logbook that I don't count towards flight time totals - flights where i received checkouts from other-than-instructors, for example. Just don't add the flight time in when you add up that page.

Where any of those "not counted" flights intended to be proof of satisfying a CAR's recency requirement as per CAR 408 (1) (b)? If so how would you satisfy CAR 408.08 (2) (c) or (g) since you are not logging flight time ?

Personal Logs
401.08 (1) Every applicant for, and every holder of, a flight crew permit, licence or rating shall maintain a personal log in accordance with subsection (2)

(a) experience acquired in respect of the issuance of the flight crew permit, licence or rating; and

(b) recency.

Subsection is as follows

(2) A personal log that is maintained for the purposes referred to in paragraphs (1)(a) and (b) shall contain the holder’s name and the following information in respect of each flight:

(a) the date of the flight;

(b) the type of aircraft and its registration mark;

(c) the flight crew position in which the holder acted;

(d) the flight conditions with respect to day, night, VFR and IFR;

(e) in the case of a flight in an aeroplane or helicopter, the place of departure and the place of arrival;

(f) in the case of a flight in an aeroplane, all of the intermediate take-offs and landings;

(g) the flight time;

(h) in the case of a flight in a glider, the method of launch used for the flight; and

(i) in the case of a flight in a balloon, the method of inflation used for the flight.

[photofly]

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Where any of those "not counted" flights intended to be proof of satisfying a CAR's recency requirement as per CAR 408 (1) (b)? If so how would you satisfy CAR 408.08 (2) (c) or (g) since you are not logging flight time ?

I don't think so; but if there were, I don't see the problem. Notice that 408.01(a) - experience - and (b) - recency - are separate purposes; it seems mundane that any given flight could count towards (a), or (b), or both (a) and (b), according to the circumstances of the flight.

In the case of a flight during which takeoffs and landings were completed, I would make a note of the name of the PIC, write the flight time in the dual column in parentheses, as a reminder to myself not to add the flight into the page totals, and note the number of landings and takeoffs I completed in the columns for day/night takeoffs and landings.

I would have done this when flying some (typically 5.0) hours accompanied by the vendor in an aircraft I was buying, to meet the insurance company's requirement for some time "on type" with a type-experienced pilot before acting as PIC. Those would count as neither PIC time, nor official "dual" time since only an instructor (or other Standard 425.21 qualified person) can provide dual flight time towards a licence or rating.

But I would have absolutely no hesitation at all in saying those circuits I flew with the owner next to me shouldn't count towards meeting the recency requirements if I needed to. I completed them, while complying with all relevant rules and legislation. Why should I be denied credit for them?

[Big Pistons Forever]

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Where any of those "not counted" flights intended to be proof of satisfying a CAR's recency requirement as per CAR 408 (1) (b)? If so how would you satisfy CAR 408.08 (2) (c) or (g) since you are not logging flight time ?

I don't think so; but if there were, I don't see the problem. Notice that 408.01(a) - experience - and (b) - recency - are separate purposes; it seems mundane that any given flight could count towards (a), or (b), or both (a) and (b), according to the circumstances of the flight.

In the case of a flight during which takeoffs and landings were completed, I would make a note of the name of the PIC, write the flight time in the dual column in parentheses, as a reminder to myself not to add the flight into the page totals, and note the number of landings and takeoffs I completed in the columns for day/night takeoffs and landings.

I would have done this when flying some (typically 5.0) hours accompanied by the vendor in an aircraft I was buying, to meet the insurance company's requirement for some time "on type" with a type-experienced pilot before acting as PIC. Those would count as neither PIC time, nor official "dual" time since only an instructor (or other Standard 425.21 qualified person) can provide dual flight time towards a licence or rating.

But I would have absolutely no hesitation at all in saying those circuits I flew with the owner next to me shouldn't count towards meeting the recency requirements if I needed to. I completed them, while complying with all relevant rules and legislation. Why should I be denied credit for them?

I think we will have to end this with agreeing to disagree. I don't think anyone should count flights which are being used to maintain recency when on that flight you have not acting as either the PIC, or some one receiving instruction from the holder of a flight instructor rating. Unfortunately like many CAR's there is not a black and white answer to the question. What is black and white is if you fly 5 solo night circuits or 5 night circuits with someone holding a flight instructor rating with in the previous 6 months there will be no doubt you meet the CAR's recency requirements if you were ever challenged on it.

[photofly]

Unfortunately like many CAR's there is not a black and white answer to the question.

I agree with that!

[digits_]

A related discussion could happen in a 2 crew airplane. If a co pilot is pilot flying, does the landing count towards the PIC's recency?

It's even more grey during takeoff as lots of SOPs have both pilots performing essential tasks during take off.

Companies seem to get around the grey area by filling in the gaps in their ops manual. But just looking at the CARs, there's no clear answer either.

[digits_]

Furthermore there can only be 1 flight crew member because the certified crew requirement for GA light aircraft is 1 pilot. There is no way for someone to act as co-pilot ( a flight crew member position) in this operation.

I undestand your reasoning up until this point. What CAR would prevent you to have more than 1 flight crew member?

Commercially there are plenty of single crew certified aircraft planes flying around multi crew. You're using the 'GA light aircraft' a lot, but there's no clear definition for that.

Privately, regulation wise, I don't see any difference between fying a navajo single/multi crew or a 172 single/multi crew.

Single crew certified aircraft flying multi-crew are typically operating in commercial air service. We all agree there are rules for more than one pilot to be recognized as flight crew of such an aircraft in part 7 operations, as there are rules for the training and appointment of flight crew.

The question is - does the absence of such rules for training and qualification of further flight crew in private operations mean a) that such further flight crew cannot be appointed or b) the opposite, that they are easier to appoint since there are fewer restrictions?

To be clear, co-pilot time can only be credited to a second pilot where they are required flight crew in the commercial operation, but just because you can't log co-pilot time doesn't mean you aren't being a flight crew member.

I agree with that. I brought it up because if someone would ask 'I am flying my private navajo and I took my buddy up for a flight. I let him do 5 landings for his recency', it would likely not raise many questions.
But because it's a 172 or other single piston, there's a bit more scrutiny and a first instinct of saying 'you can't do that'.

It was to point out that the 'light GA aircraft' terminology is quite vague.

[photofly]

I agree with that. I brought it up because if someone would ask 'I am flying my private navajo and I took my buddy up for a flight. I let him do 5 landings for his recency', it would likely not raise many questions.

I don't think it would (or should) raise any questions in a 172 either, but for consistency's sake, either neither or both should be ok.

A related discussion could happen in a 2 crew airplane. If a co pilot is pilot flying, does the landing count towards the PIC's recency?

I would say, no. Two pilots cannot both "complete" the same landing. Clearly the pilot flying is the one who does that.

It's even more grey during takeoff as lots of SOPs have both pilots performing essential tasks during take off.

Who's handling the flight controls?

[Big Pistons Forever]

In a 2 crew aircraft every flight will have one crew member designated as pilot flying and one as pilot monitoring. The pilot flying gets credit for the takeoffs and landings.

[digits_]

A related discussion could happen in a 2 crew airplane. If a co pilot is pilot flying, does the landing count towards the PIC's recency?

I would say, no. Two pilots cannot both "complete" the same landing. Clearly the pilot flying is the one who does that.

They both complete the same flight, no? Why not the landing?

It just seems weird to me that the whole multi crew concept revolves around working together as a team to complete the flight, yet suddenly only one can log or complete the landing.

It's even more grey during takeoff as lots of SOPs have both pilots performing essential tasks during take off.

Who's handling the flight controls?

I worked at 2 companies where one handles the yoke, the other sets the power. It's impossible to take off without doing both.

[digits_]

In a 2 crew aircraft every flight will have one crew member designated as pilot flying and one as pilot monitoring. The pilot flying gets credit for the takeoffs and landings.

I agree that's how it seems to work in the industry, but the CARs don't specify that. Or at least I couldn't find a reference.

[photofly]

There's some (a little) ambiguity in the use of the word "complete" in respect of a takeoff and landing. Does anyone know what was the wording of the equivalent passage in the air navigation orders that the CARs replaced?

CARAC is currently running a campaign asking for input on what elements of the CARs should be updated:
https://letstalktransportation.ca/moder ... l-aviation

Aside from the author of the page not knowing the difference between adverse and averse, they might like to have this ambiguity about how to meet the recency requirements drawn to their attention.

On the other hand I'm fairly sure that there is no appetite amongst TC policy wonks for choosing a more permissive disambiguation over a more restrictive one. I have more faith in the TATC process to lay down the 'correct' law in a sensible manner, but that would take an enforcement action and a subsequent appeal, with financial and reputational penalties on the line.

EDIT: I see Mike Schuster has already entered (almost) this issue in the discussion, 4 days ago. Great timing.

[Big Pistons Forever]

I worked at 2 companies where one handles the yoke, the other sets the power. It's impossible to take off without doing both.

I would expect as per the TC approved 2 crew SOP's the person handling the yoke is the pilot flying and the person monitoring is handling the power controls and setting them as commanded by the pilot flying. Seems pretty obvious who should get the credit for the takeoff.

[digits_]

I worked at 2 companies where one handles the yoke, the other sets the power. It's impossible to take off without doing both.

I would expect as per the TC approved 2 crew SOP's the person handling the yoke is the pilot flying and the person monitoring is handling the power controls and setting them as commanded by the pilot flying. Seems pretty obvious who should get the credit for the takeoff.

That might work for currency during commercial ops, and it certainly doesn't break any CARs. But if a pilot wanted to use his PNF landings or takeoffs to count to fly a private twin with pax at night, then I don't see what CAR he would be breaking.

[Big Pistons Forever]

I worked at 2 companies where one handles the yoke, the other sets the power. It's impossible to take off without doing both.

I would expect as per the TC approved 2 crew SOP's the person handling the yoke is the pilot flying and the person monitoring is handling the power controls and setting them as commanded by the pilot flying. Seems pretty obvious who should get the credit for the takeoff.

That might work for currency during commercial ops, and it certainly doesn't break any CARs. But if a pilot wanted to use his PNF landings or takeoffs to count to fly a private twin with pax at night, then I don't see what CAR he would be breaking.

I find it discouraging that pilots are looking for ways to avoid meeting what seems to me a logical requirement, having to demonstrate night landing proficiency before you carry passengers. If you are comfortable watching someone else land the airplane and then count that towards your personal competency then I guess I have an issue with your decision making. My opinion represent one data point and is obviously not binding on you or anyone else so go do what you want to do.

[photofly]

I'm comfortable with understanding the requirement to be the one of handling the flight controls for the relevant number of recent takeoffs and landings - either by day or by night - just to get your eye in, so to speak. I don't see ones status as PIC, sole occupant, or accompanied by another pilot, as relevant to achieving or failing at that goal.

It's also a minimum bar, there to provide just the tiniest bit of reassurance for people who are genuine passengers. Just like the "have flown as PIC or co-pilot in the last 5 years" rule, it doesn't guarantee any particular level of competence, and it's not supposed to.

[digits_]

I find it discouraging that pilots are looking for ways to avoid meeting what seems to me a logical requirement, having to demonstrate night landing proficiency before you carry passengers. If you are comfortable watching someone else land the airplane and then count that towards your personal competency then I guess I have an issue with your decision making.

Of course, the good old 'you disagree with me / you dare to question the CARs so I have an issue with your decision making'.

But, since it's been brought up, let's explore that avenue.
A few points I'd like to make:

1) I would like to point out that completing a 2 crew take off or landing involves much more than just 'waching someone else land the airplane'

2) If the regulator deems this issue to be of the utmost importance, the least they can do is publish clear rules.

3) one could argue that 'watching someone else land the airplane' while actually being physically located in said airplane might be more beneficial than performing 5 'night' landings in a simulator.

4) This particular passenger recency requirement is a regulation that falls into the 'protecting the public without any benefit to the pilot' category. It's not surprising that a pilot would want to satisfy this in the easiest/cheapest way possible. If you think your skills are not up to par to perform a night landing with passengers on board, it's likely not a good idea to perform a landing *without* passengers on board either

5) Landing on a 10 000 ft highly lit runway on a full moon night while just not being recent is arguably significantly safer than landing in a dark night on a minimum length runway with minimum lights while just meeting the recency requirements. The night landing requirement is quite arbitrary -as many regulations are-, which also means that people will try to find possibly creative -yet allowed- ways of meeting the regulation. I don't think that's evidence of bad decision making. Merely an indication of a keen mind, with the willingness to follow the regulations.

6) Note that you don't have to demonstrate night landing proficiency. You merely have to perform 5 landings. They can be horrible landings. Nobody's judging you. And as long as you don't break the plane, nobody will likely know.

7) I looked up if the terminology of 'perform' was used anywhere else in the CARs. It is, while describing the 6/6/6 recency rule.
I found this:

(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 regulator there specifically allows an instructor, in a simulator, to count all the simulated IFR approaches their students are flying towards their recency. Is it then so far fetched to believe a required crew member in an actual airplane would be able to count the landings during which he is performing duties -albeit not necessarily touching the yoke-, towards his recency?