COPA has successfully lobbied Transport Canada Civil Aviation (TCCA) to remove an arbitrary, bureaucratic hurdle that required aircraft used for IFR check rides (IPC) to be equipped with approved GNSS capability (IFR Flight Test Guide 02/2017). TCCA has revised this requirement to be applicable on the initial IFR test ride only – recognizing that numerous IFR-rated private pilots own aircraft not equipped with GNSS who would not be able to maintain their IFR ratings without undertaking significant avionics upgrades or renting aircraft from flight schools solely for the purpose of their IPC. With this announcement now formalized by Transport Canada, these pilots will continue to be able to renew their IFR rating on their own aircraft, in its current configuration.
Several important aspects have changed with respect to our IFR rating in the last year or so. The first major change is that the IFR rating does not expire anymore. Once it is on our license, it is there for life, like the license itself, and we will not have to rewrite the INRAT if our rating has lapsed beyond a certain date. We still have to do an Instrument Proficiency Check (IPC) every two years, on or before the anniversary of our rating. Does this sound like anything major or significant for the GA pilot in Canada? Probably not. On the other hand, we must recognize that these changes are legitimate in that they do address numerous issues in other areas of our licensing system.
Along with these changes, we also have the IFR currency requirement: 6 hours and 6 approaches to published minima in the last 6 months, or 6-6-6. This means that on the day we plan to fly IFR in IMC, we must have met this currency requirement. The onus is on us, as pilots, to keep track in our logbook of all our flights that qualify toward that currency requirement. When a flight addresses the 6-6-6, simply make a note to that effect with the logbook entry. It is also much wiser and safer to have this currency flying spread over time instead of cramming the day before the intended flight.
The recency requirement provides pilots flying in IMC (IFR of course) a means to ensure they are not rusty to the point of being unsafe. It does not invalidate your IFR rating if the 6-6-6 is not satisfied. The 6-6-6 is effective on the 1st day of the 13th month following your instrument rating flight test or your IPC. If your 6-6-6 has expired, you do not meet the recency requirement to fly IFR. In this case, you have two easy options to revive your IFR recency:
VMC – You get in your IFR equipped and approved aircraft and you go fly off the 6-6-6 requirement in VMC. You can do this by flying simulated published approaches down to the published minimum. You can do this at a controlled airport when the controller authorizes you, or at an uncontrolled aerodrome if this is more practical for you. The intent of this currency requirement is to ensure that you are current on the procedures, that you still remember how to read and interpret the plates for instance and can fly the approach with accuracy and safely, respecting all limitations and relevant guidance. The regulation does not mandate that a qualified person must be with you. It is however a wise and safe practice to have a knowledgeable and reliable person in the right hand seat to act as a security lookout. You will be flying with your head down in the cockpit, in VFR conditions. You are always responsible for your own traffic avoidance and aircraft separation; or
IMC – You get in your IFR equipped and approved aircraft and you go renew your 6-6-6 by flying IFR in IMC, on a flight plan. In this case, you most definitely must have a qualified person in the right hand seat. Since you cannot file IFR, that flight plan will have to be on that person’s IFR ticket. That qualified person can be a Flight Instructor with valid IFR and 6-6-6, a CPL with valid IFR and 6-6-6, an ATPL with valid IFR and 6-6-6, or you can go all the way to a TCCA authorized and qualified examiner.
(A miscommunication between COPA and TCCA lead to the publication of misleading information with respect to the IFR recency in the Dec 1st article on IFR. The relevant section of the article is reproduced now with the appropriate clarifications incorporated in bold type.)
