Night Time Currency

SilkyD

Well-Known Member
Later on this week, I have a a couple of night flights with students (pattern works and X-country PPL requirements). I was looking at my log book and noticed I was out of my 90 day night-time currency (i.e. 3 t/o and landings to a full stop).
My question is, can I regain that currency with a student, or do I need to go up solo to regain the currency? I have heard two versions. Some CFI's say that I can regain my night time currency with a student as they are doing their night time takeoffs and landings; while others say I can't. I will look up the reg's later on today, but I just wanted to run it by others first to see what your take may be.

Thanks,
 
If providing instruction, night currency is not required. This is because the student is not a passenger but is a 'required crew member'.


61.57(b)

(b) Night takeoff and landing experience. (1) Except as provided in paragraph (e) of this section, no person may act as pilot in command of an aircraft carrying passengers


There are a couple letter of interpretations from the FAA on this. Here's a snippet from one from Rebecca MacPherson (Assistant Chief Counsel).


We agree that, for purposes of section 61.57(b), an authorized instructor providing instruction in an aircraft is not considered a passenger with respect to the person receiving instruction, even where the person receiving the instruction is acting as PIC. (The instructor must be current, qualified to instruct, and hold a category, class and type rating in the aircraft, if a class and type rating is required.) The instructor is not a passenger because he is present specifically to train the person receiving instruction. Neither is the person receiving instruction a passenger with respect to the instructor. This training may take place, even though neither pilot has met the 61.57(b) requirements.
 
If providing instruction, night currency is not required. This is because the student is not a passenger but is a 'required crew member'.
There's nothing in the Chief Counsel opinion that makes the student a "required crew member." Just not a "passenger" for currency purposes. Saying that the student was a required crew member would be problematic.
 
There's nothing in the Chief Counsel opinion that makes the student a "required crew member." Just not a "passenger" for currency purposes. Saying that the student was a required crew member would be problematic.

True, poor wording on my part because "required crew member" has other meaning.
 
That's what I thought as well. However, other CFI's thought that wasn't the case. Thanks for the replies gents!!
 
It's not obvious from the reg (and not even from prior Chief Counsel opinions involving student pilots). The Chief Counsel opinion letters on the subject are about 5 years old. It's not surprising that there are those out there who are not familiar with it. After all, there are still folks (although far fewer than there used to be) unfamiliar with the basic PIC logging rules, and the Chief Counsel opinions on those began more than 30 years ago.
 
It's not obvious from the reg (and not even from prior Chief Counsel opinions involving student pilots). The Chief Counsel opinion letters on the subject are about 5 years old. It's not surprising that there are those out there who are not familiar with it. After all, there are still folks (although far fewer than there used to be) unfamiliar with the basic PIC logging rules, and the Chief Counsel opinions on those began more than 30 years ago.

Not surprising, as I did not know this either. Great question.
 
So that means I am legal to go with a student pilot even though I am a few days out of currency and this is their first night flight? Now the question is do those landings I coach them through count towards regaining my night time currency?
 
So that means I am legal to go with a student pilot even though I am a few days out of currency and this is their first night flight? Now the question is do those landings I coach them through count towards regaining my night time currency?
14 CFR 61.57:
(b) Night takeoff and landing experience. (1) Except as provided in paragraph (e) of this section, no person may act as pilot in command of an aircraft carrying passengers during the period beginning 1 hour after sunset and ending 1 hour before sunrise, unless within the preceding 90 days that person has made at least three takeoffs and three landings to a full stop during the period beginning 1 hour after sunset and ending 1 hour before sunrise, and—

(i) That person acted as sole manipulator of the flight controls


Draw from that your own conclusions.
 
14 CFR 61.57:
(b) Night takeoff and landing experience. (1) Except as provided in paragraph (e) of this section, no person may act as pilot in command of an aircraft carrying passengers during the period beginning 1 hour after sunset and ending 1 hour before sunrise, unless within the preceding 90 days that person has made at least three takeoffs and three landings to a full stop during the period beginning 1 hour after sunset and ending 1 hour before sunrise, and—

(i) That person acted as sole manipulator of the flight controls

Draw from that your own conclusions.
Problem is that we've all seen enough "I't's my ticket so I log them" responses to the question of instructors logging student landings even though this reg has been around a very long time.

So...
SilkyD said:
Now the question is do those landings I coach them through count towards regaining my night time currency?
No.
 
Why not stop thinking about yourself and your logbook, and start thinking how safely you truly feel you can instruct in conditions you haven't flown in in months. I'd say your first responsibility is to get yourself current.
 
Why not stop thinking about yourself and your logbook, and start thinking how safely you truly feel you can instruct in conditions you haven't flown in in months. I'd say your first responsibility is to get yourself current.
Maybe. Maybe not.

I agree with you that the first consideration is safety. But there are pilots out there who have a lot of night experience for whom maintaining technical legal currency is a matter of jumping in an airplane and doing a group of very boring, very non-eventful night landings. In that case, safety is not an issue. Pure legality is.
 
Talk you your boss (assuming you work at a flight school) and tell him/her that you want to take up a plane to get night current. I did this when I was instructing and ran out of ME currency. My boss told me to take the Seminole up and bill it to the company.
 
MidlifeFlyer,
Your last post was exactly on target.Thanks for the advice!

I just wish it was stated more clearly in the FARS (i.e. instructors/students not considered passengers). That is what made me uneasy about the legal interpretation. The fact it was never incorporated in the FAR's and it's been 5 years since they came out with that interpretation.

TowJoe,
I spoke to my boss and he will let me use the plane for free any time there is an issue with currency.
 
SilkyD, there's a lot of that going around. All agencies, both federal and state, end up having to provide interpretive guidance to fill in gaps that even the best reg-writers can leave behind. Some end up being incorporated into the regulatory language, but most don't. Can you imagine how long and convoluted (even more so that it already is) the FAR would be if it were?
 
MidlifeFlyer,

First off, I just wanted to thank you and the others for some sound advice and helpful insights. Much appreciated!! It's nice to have a place where fellow pilots are helping other pilots. I will definitely "pay it forward" to others.

Thanks for the legalese. Reading the FARs is painful enough as it is. :)

On another note, not being able to log student landings since you're not sole manipulator makes sense. But I'd venture to say that a vast majority of CFI's log their students landings.

But what if on the flare the student is doing poorly and you provide assistance with the flare by providing control inputs? Do I get to log that landing? Technically I'm not sole manipulator but help with control inputs was needed. So who gets to log that landing?
 
But what if on the flare the student is doing poorly and you provide assistance with the flare by providing control inputs? Do I get to log that landing? Technically I'm not sole manipulator but help with control inputs was needed. So who gets to log that landing?
We can dance on the head of a pin for that one but I read "sole manipulator" to mean, well, "sole manipulator." Practically speaking, if you can't maintain basic landing currency without "stealing" student landings, I think there's a bigger issue than a logbook entry.

Who logs the assisted landing?

Well, if it's a student pilot, frankly, I have the student log all of the landings in which the student does any of the work. 61.57 doesn't apply, since passenger-carrying currency is irrelevant for a student pilot and those landing numbers building up can be a confidence booster.

If it's a pilot above the student pilot grade, an assisted landing is logged by no one.
 
Daytime landing currency isn't an issue; since I go out and fly solo and I also do discovery flights where I do the landings.

Thanks for all of your help MidlifeFlyer. Much appreciated!!
 
Back
Top