By Jean-Claude Audet

We recently initiated a discussion on IFR topics, starting with clarifying the IFR Flight Test Guide (Feb 2017) requirement (Aeroplane (b) on page 2) for an aircraft used for an IFR Flight Test to ‘’be equipped with GNSS receiving equipment … ‘’. This initial step then brought us into a discussion on the instrument recency requirements of CAR 401.05(3), and more specifically the 6-6-6.

From the beginning, COPA and TCCA have worked in very close collaboration in the spirit of clarifying these issues and interpretations to the benefit of all our pilots. We have received numerous comments/questions/feedback/queries from our readers presenting various interpretations. This feedback demonstrates that there is a need for fostering a better understanding of these regulations and interpretations and we are very happy at this turn of event. I personally remember the early 80’s when I had just started instructing and some of these issues and interpretations, as well as some others too, were dynamic topics of discussion in our flight school.  COPA has the full support and collaboration of TCCA in this matter. They too have received similar feedback, which has generated much internal discussions with respect to these interpretations. Note that this is a situation where TCCA has definitely paid serious attention to COPA’s perspective and their personnel has focused on interpreting the regulation in a manner that is as accommodating as possible to our pilots, while respecting the regulations and maintaining safety of flight. This level of communications with TCCA will be maintained until we attain the point where all reasonable questions are satisfactorily addressed. At this point, both COPA and TCCA sincerely hope this will be the last iteration. We jointly believe that the added value associated with bringing this discussion in the open, albeit somewhat inadvertently, is unquestionable.

The initial post on this IFR topic incorporated an erroneous statement to the effect that even if your 6-6-6 was not current, your IFR rating was still valid and you could file and fly IFR in VMC. A second post subsequently clarified this and included some additional clarifications. We have now uncovered that some further clarification is required with respect to the 6-6-6. This new clarification addresses the interpretation of simulated instrument time and its impact on the 6-6-6. TCCA interprets this as meaning ‘’with the use of a Vision Limiting Device (VLD)’’ when flying/practicing in VMC.

Let us look at two relevant scenarios. In both scenarios, your IFR ticket is within its two-year IPC period and is valid.

Scenario 1:

Your 6-6-6 is current but about to expire. You can then file and fly IFR. The 6-month period will be up in a few days and you are missing two approaches and a bit of instrument time. You have three possible means of catching up and ensuring your 6-6-6 does not expire:

  • Use an FSTD which is instrument ground time with an instrument-qualified instructor and is always a valid means of maintaining your recency;
  • VFR in VMC: this is the simulated instrument time scenario. TCCA interprets this as ‘’with the use of VLD’s’’. Then, you definitely need a safety pilot;
  • IFR flight plan in IMC or VMC: file an IFR flight plan and go fly the required approaches and instrument time in IMC or VMC.  In order to have a more effective practice of instrument flight a VLD is recommended in VMC and requires a safety pilot with you to help keep an eye out for other traffic.

Scenario 2:

Your 6-6-6 has expired. Even if your IFR ticket is still valid, you cannot file IFR. You have three possible means of updating your 6-6-6:

  • Use an FSTD which is always a valid means of renewing your currency with an instrument-qualified instructor;
  • VFR in VMC: this is the simulated instrument time scenario. TCCA interprets this as ‘’with the use of Vision Limiting Devices (VLD)’’. Then, you definitely need a safety pilot;
  • IFR flight plan in IMC or VMC: You cannot file IFR in this scenario. You then need somebody with you whose IFR is valid and 6-6-6 is current. The IFR flight plan will be filed on that qualified person’s IFR ticket and you go fly the required approaches and instrument time in IMC or VMC. Our second post stated: ‘’ 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.’’ We can now add a PPL to this list of qualified pilots.

The astute reader will notice and question a peculiar aspect in all of this. If you fly on an IFR flight plan in VMC, you do not need a VLD to satisfy you 6-6-6 currency. If you fly in VMC with no IFR flight plan, you would need a VLD to be able to count your flight time as simulated instrument time towards your 6-6-6. Discussions are still ongoing within TCCA on this one. Don’t go away, we will be right back!