The way I read 61.57(d) (the requirement for an IPC), it's just an extra
requirement that kicks in under certain circumstances. It's not a subpart
of 61.57(c) (6 approaches etc in 6 months), and (c) does not have any
exceptions related to (d).

So if an IPC is essentially a checkride, it could be done by a proficient
pilot with (say) 3 approaches. Would that pilot be legal for IFR if he
had gone into the IPC needing it (no approaches within 6 months)?

--
Ben Jackson AD7GD
>
http://www.ben.com/

"Ben Jackson" > wrote in message
...
> The way I read 61.57(d) (the requirement for an IPC), it's just an extra
> requirement that kicks in under certain circumstances. It's not a subpart
> of 61.57(c) (6 approaches etc in 6 months), and (c) does not have any
> exceptions related to (d).
>
> So if an IPC is essentially a checkride, it could be done by a proficient
> pilot with (say) 3 approaches. Would that pilot be legal for IFR if he
> had gone into the IPC needing it (no approaches within 6 months)?

Not as the regulation is written. As you note, 61.57d sets forth an
additional requirement, not a substitution for or exception to the
requirements of 61.57c. So an IPC might indeed include only three
approaches, but that wouldn't qualify the pilot to fly IFR unless the pilot
has flown three other approaches within the past six months.

--Gary

> So an IPC might indeed include only three
> approaches, but that wouldn't qualify the pilot to fly IFR unless the pilot
> has flown three other approaches within the past six months.

Gee, I never looked at it that way. But, OTOH, an instrument rated
pilot who goes nine months without any instrument time, and subsequently
does six approaches, holds, and intercepts under the hood, would not
need the IPC, since he at that point DOES meet the original requirement.
This would make the IPC irrelevant, which I'm sure is not what they
had in mind.

What =were= they thinking?? (my question every time I read the regs)

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

"Jose" > wrote in message
. com...
>> So an IPC might indeed include only three approaches, but that wouldn't
>> qualify the pilot to fly IFR unless the pilot has flown three other
>> approaches within the past six months.
>
> Gee, I never looked at it that way. But, OTOH, an instrument rated pilot
> who goes nine months without any instrument time, and subsequently does
> six approaches, holds, and intercepts under the hood, would not need the
> IPC, since he at that point DOES meet the original requirement. This would
> make the IPC irrelevant, which I'm sure is not what they had in mind.

After just nine months without instrument time, a pilot would not
necessarily need an IPC to regain currency. The IPC requirement kicks in six
months after instrument currency expires. At that point, though, just the
six approaches (and holds and intercepts) do not suffice to reestablish
currency; there has to be an IPC. So the IPC isn't irrelevant in that case.

--Gary

> After just nine months without instrument time, a pilot would not
> necessarily need an IPC to regain currency.

Oh right. Duh!

But it does seem that an IPC even within six months is not sufficient to
restablish currency.

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

Yea, the IPC can be done in less time than doing 6 in 6 for currency
assuming a current pilot. I almost always do IPCs myself just because
it takes so damn long to get in 6 approachs at busy airports. The
requirements of the IPC are very strickly called out in the IFR PTS. It
is not open to the latitude that a BFR is.

-Robert, CFII

Ben Jackson wrote:
> The way I read 61.57(d) (the requirement for an IPC), it's just an extra
> requirement that kicks in under certain circumstances. It's not a subpart
> of 61.57(c) (6 approaches etc in 6 months), and (c) does not have any
> exceptions related to (d).
>
> So if an IPC is essentially a checkride, it could be done by a proficient
> pilot with (say) 3 approaches. Would that pilot be legal for IFR if he
> had gone into the IPC needing it (no approaches within 6 months)?
>
> --
> Ben Jackson AD7GD
> >
> http://www.ben.com/

Jose wrote:
> But it does seem that an IPC even within six months is not sufficient to
> restablish currency.

An IPC automatically starts your clock again regardless if your last
currency was 2 weeks ago or 30 years ago. The manuevers required of the
IPC are called out in the IFR PTS.

-Robert, CFII

On Thu, 24 Aug 2006 14:52:35 -0400, "Gary Drescher"
> wrote:

>"Ben Jackson" > wrote in message
...
>> The way I read 61.57(d) (the requirement for an IPC), it's just an extra
>> requirement that kicks in under certain circumstances. It's not a subpart
>> of 61.57(c) (6 approaches etc in 6 months), and (c) does not have any
>> exceptions related to (d).
>>
>> So if an IPC is essentially a checkride, it could be done by a proficient
>> pilot with (say) 3 approaches. Would that pilot be legal for IFR if he
>> had gone into the IPC needing it (no approaches within 6 months)?
>
>Not as the regulation is written. As you note, 61.57d sets forth an
>additional requirement, not a substitution for or exception to the
>requirements of 61.57c. So an IPC might indeed include only three
>approaches, but that wouldn't qualify the pilot to fly IFR unless the pilot
>has flown three other approaches within the past six months.
>
>--Gary
>


This is from the last set of FAQ's that we are not supposed to have
anymore. It used to be stated as FAA policy, but someone decided that
they didn't want to stick their neck out anymore. I believe it to be
accurate. Since an IPC is essentially an instrumet checkride given by
a CFII, and an instrument checkride consists of only 3 approaches
anyway, it stands to reason that an IPC and currency needs not be
something more than the original practical test consisted of. The
sucessful instrument applicant left the checkride current to fly IFR
in the system with only 3 approaches demonstrated.

QUESTION: A question has arisen about the "6 in 6" rule and the IPC as
they relate to pilots out of currency for more than 6 months.
Paragraph (d) says such pilots may not act as PIC under IFR until they
get an IPC. However, the way it is worded, one might conclude that
the pilot must also achieve the 6 approaches/intercept/track/hold
criteria in paragraph (c) before he can be PIC under IFR -- that the
IPC is a necessary but not sufficient criterion for returning to
currency after more than 6 months out of currency. So, is a
successful IPC sufficient for IFR currency regardless of the number of
approaches completed in the last 6 months? Does this change if you
are out of the 6 months-without-currency grace period?

ANSWER: Ref. § 61.57(d); An instrument proficiency check (IPC)
conducted in accordance with the § 61.57(d)/ Instrument Rating PTS
meets all the requirements to "start the clock" over for remaining
instrument rated current. Passing an IPC fulfills the requirement for
currency.
Back in 1997-1998 it was questioned what was meant by § 61.57(d) in
stating that passing IPC "... consisting of a representative number of
tasks required by the instrument rating practical test . . ." was
required. This question was answered by AFS-630 that write the PTS's.
In the Instrument Rating Practical Test Standards, FAA-S-8081-4C a
task table was added with "PC' as one of the columns in change #2, on
page 15 of the introduction portion of the PTS. Conducting an IPC in
accordance with this standard is a requirement now. When a pilot
completes such an IPC of at least 3 approaches (Area of Operation VI)
and in a multiengine airplane of at least one more approach (Area of
Operation VII), the person will then be considered to be instrument
rated current for that category of aircraft.
{Q&A-514}

> An IPC automatically starts your clock again regardless if your last
> currency was 2 weeks ago or 30 years ago.

I've heard that too. But where is it written?

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

"Bill Zaleski" > wrote in message
...
> This is from the last set of FAQ's that we are not supposed to have
> anymore. It used to be stated as FAA policy, but someone decided that
> they didn't want to stick their neck out anymore. I believe it to be
> accurate. Since an IPC is essentially an instrumet checkride given by
> a CFII, and an instrument checkride consists of only 3 approaches
> anyway, it stands to reason that an IPC and currency needs not be
> something more than the original practical test consisted of. The
> sucessful instrument applicant left the checkride current to fly IFR
> in the system with only 3 approaches demonstrated.

I agree that both an instrument checkride and an IPC need not include more
than three approaches. Still, as the regs are written, neither a
just-completed instrument checkride, nor a just-completed IPC, waives the
requirement of 61.57c to have flown six approaches in the past six months in
order to be instrument-current. But I have no idea whether the FAA
interprets the regs as written (the FAQ you cite suggests that they don't).

--Gary

d) Instrument proficiency check. Except as provided in
paragraph (e) of this section, a person who does not meet
the instrument experience requirements of paragraph (c) of
this section within the prescribed time, or within 6
calendar months after the prescribed time, may not serve as
pilot in command under IFR or in weather conditions less
than the minimums prescribed for VFR until that person
passes an instrument proficiency check consisting of a
representative number of tasks required by the instrument
rating practical test.
(1) The instrument proficiency check must be-
(i) In an aircraft that is appropriate to the aircraft
category;

The check is available at any time and fully meets the
requirements of legal currency...

a person who does not meet the instrument experience
requirements of paragraph (c) until that person passes an
instrument proficiency check consisting of a representative
number of tasks required by the instrument rating practical
test.



"Gary Drescher" > wrote in message
...
| "Bill Zaleski" > wrote in
message
| ...
| > This is from the last set of FAQ's that we are not
supposed to have
| > anymore. It used to be stated as FAA policy, but
someone decided that
| > they didn't want to stick their neck out anymore. I
believe it to be
| > accurate. Since an IPC is essentially an instrumet
checkride given by
| > a CFII, and an instrument checkride consists of only 3
approaches
| > anyway, it stands to reason that an IPC and currency
needs not be
| > something more than the original practical test
consisted of. The
| > sucessful instrument applicant left the checkride
current to fly IFR
| > in the system with only 3 approaches demonstrated.
|
| I agree that both an instrument checkride and an IPC need
not include more
| than three approaches. Still, as the regs are written,
neither a
| just-completed instrument checkride, nor a just-completed
IPC, waives the
| requirement of 61.57c to have flown six approaches in the
past six months in
| order to be instrument-current. But I have no idea whether
the FAA
| interprets the regs as written (the FAQ you cite suggests
that they don't).
|
| --Gary
|
|

On 2006-08-25, Jim Macklin <> wrote:
>
> The check is available at any time and fully meets the
> requirements of legal currency...

As written, I don't see where you get that. For one thing, if the IPC
supersedes the 6-in-6 rule, when does IPC-induced currency run out? If
I flew three approaches last month, and then flew an IPC this month
with three more, do run out in 5 months or 6?

To consider a parallel set of regulations -- does a BFR make you current
to fly passengers at night?

--
Ben Jackson AD7GD
>
http://www.ben.com/

A IPC is valid for 6 months. You need to read legal documents using formal rules. The IPC rule says that a pilot who does not meet the 6-6 rule may take an IPC, the IPC becomes mandatory 12 months after the date currency was established.

There are clearly many examples were the 6-6 rule is inadequate to provide safety. The new IR pilot who stops flying for 9 months the day after the IR practical test with a TT of say 200 hours. More time would be needed just to be VFR current and just flying 6-6 with a safety pilot is not as good as the IPC. A 3,000 professional pilot might be able to take a layoff for a full year and get back in the cockpit safely with a one hour flight with a CFI. The IPC might bring them back to speed since they have a good base.

If you don't "see" the meaning of the words, suggest you find a qualified high school English teacher or a lawyer and have them show you. You carefully snipped the quoted regulation so it couldn't be seen by anyone else.

d) Instrument proficiency check. Except as provided in
paragraph (e) of this section, a person who does not meet
the instrument experience requirements of paragraph (c) of
this section within the prescribed time, or within 6
calendar months after the prescribed time, may not serve as
pilot in command under IFR or in weather conditions less
than the minimums prescribed for VFR until that person
passes an instrument proficiency check consisting of a
representative number of tasks required by the instrument
rating practical test.
(1) The instrument proficiency check must be-
(i) In an aircraft that is appropriate to the aircraft
category;

The check is available at any time and fully meets the
requirements of legal currency...

a person who does not meet the instrument experience
requirements of paragraph (c) until that person passes an
instrument proficiency check consisting of a representative
number of tasks required by the instrument rating practical
test.

Note that years ago, any CFII could do an IPC with one trip around the airport and one instrument approach. The rule was tightened by requiring the completion of the IPC following the tasks in the IR PTS.


--
James H. Macklin
ATP,CFI,A&P



"Ben Jackson" > wrote in message ...
| On 2006-08-25, Jim Macklin <> wrote:
| >
| > The check is available at any time and fully meets the
| > requirements of legal currency...
|
| As written, I don't see where you get that. For one thing, if the IPC
| supersedes the 6-in-6 rule, when does IPC-induced currency run out? If
| I flew three approaches last month, and then flew an IPC this month
| with three more, do run out in 5 months or 6?
|
| To consider a parallel set of regulations -- does a BFR make you current
| to fly passengers at night?
|
| --
| Ben Jackson AD7GD
| >
| http://www.ben.com/

Jim Macklin wrote:
> A IPC is valid for 6 months. You need to read legal documents using
> formal rules. The IPC rule says that a pilot who does not meet the 6-6
> rule may take an IPC, the IPC becomes mandatory 12 months after the date
> currency was established.

That's the way I was instructed it worked as well. For my normal flying
I rarely get 6 approaches (in IMC to after the FAF) so my currency will
lapse. What I do in each case is book time with my instructor and do an
IPC. Anyone can do 6 approaches with a safety pilot (or however many
more you need to be current, tracking VOR's we all do that, and fly
without outside reference, holding) but does that mean you're doing it
well? Can a safety pilot evaluate you and your habits as well as a CFII
who is experienced in seeing what the student (of any level) is doing
and correcting small faults or bad habits before they get too ingrained?

Most of the time a couple of hours flying with a CFII, doing the things
required in the PTS for the IPC will suffice. I've done an IPC and had
one of those days when things just didn't come together well and after
we landed my CFI said "lets go up one more time and work on those things
you had difficulty with and I'll sign you off after that".

That kind of evaluation does me more good than flying around with a
buddy under the hood.

I fly IFR in the clouds and most of the time I have my family with me.
Our safety is paramount and that's why I go to the extra effort of
getting an IPC every 6 months or so.

Robert

"Robert Chambers" > wrote in message
et...
>
> That's the way I was instructed it worked as well. For my normal flying I
> rarely get 6 approaches (in IMC to after the FAF) so my currency will
> lapse.

Do approaches have to be in IMC to after the IAF to count towards currency?

No.


Personally, I only log approaches that are IMC past the FAF,
but the regulation is written so that you have done an IAP
once you have become established on a segment.



"Steven P. McNicoll" > wrote
in message
link.net...
|
| "Robert Chambers" > wrote in
message
| et...
| >
| > That's the way I was instructed it worked as well. For
my normal flying I
| > rarely get 6 approaches (in IMC to after the FAF) so my
currency will
| > lapse.
|
| Do approaches have to be in IMC to after the IAF to count
towards currency?
|
|

"Jim Macklin" > wrote in message
news:%rDHg.5985$SZ3.4860@dukeread04...
>
> No.
>
>
> Personally, I only log approaches that are IMC past the FAF,
> but the regulation is written so that you have done an IAP
> once you have become established on a segment.
>

I log an approach whenever one is needed to get into the field. If there's
a solid layer at or below the MIA/MVA then an approach is required to get
in, even if the field is reporting VMC.

Steven P. McNicoll wrote:
> "Jim Macklin" > wrote in message
> news:%rDHg.5985$SZ3.4860@dukeread04...

> I log an approach whenever one is needed to get into the field. If there's
> a solid layer at or below the MIA/MVA then an approach is required to get
> in, even if the field is reporting VMC.

Even if you break out before the IAP?

-Robert

Steven P. McNicoll wrote:
> "Jim Macklin" > wrote in message
> news:%rDHg.5985$SZ3.4860@dukeread04...

> I log an approach whenever one is needed to get into the field. If there's
> a solid layer at or below the MIA/MVA then an approach is required to get
> in, even if the field is reporting VMC.

Steven,
How many approachs do you normally get in that Aeronca?
-Robert

No not at all, that's my personal decision to count an approach as
legit. I figure if I get to the FAF and I'm not IMC then I'd need a
hood and a safety pilot to make it count as one of the 6 approaches.
Sorry for the confusion there.

Steven P. McNicoll wrote:
> "Robert Chambers" > wrote in message
> et...
>
>>That's the way I was instructed it worked as well. For my normal flying I
>>rarely get 6 approaches (in IMC to after the FAF) so my currency will
>>lapse.
>
>
> Do approaches have to be in IMC to after the IAF to count towards currency?
>
>

"Robert M. Gary" > wrote in message
ups.com...
>
> Even if you break out before the IAP?
>

Can you give me an example?

"Robert M. Gary" > wrote in message
ps.com...
>
> Steven,
> How many approachs do you normally get in that Aeronca?
>

None. It's not the only airplane I fly.

"Robert Chambers" > wrote in message
t...
>
> No not at all, that's my personal decision to count an approach as legit.
> I figure if I get to the FAF and I'm not IMC then I'd need a hood and a
> safety pilot to make it count as one of the 6 approaches.

Why do you feel it's not kosher otherwise?

On Fri, 25 Aug 2006 16:18:09 GMT, "Steven P. McNicoll"
> wrote:

>
>"Robert Chambers" > wrote in message
t...
>>
>> No not at all, that's my personal decision to count an approach as legit.
>> I figure if I get to the FAF and I'm not IMC then I'd need a hood and a
>> safety pilot to make it count as one of the 6 approaches.
>
>Why do you feel it's not kosher otherwise?


This is the only "FAA" reference to what they consider an appropriate
amount of IMC constitutes for logging for currency that I have ever
been able to find.


FAAviation News , July-Aug 1990.

"Once you have been cleared for and have initiated an approach in IMC,
you may log that approach for instrument currency, regardless of the
altitude at which you break out of the clouds"


>

I understand that, but my personal requirement and that's all it is, is
that if I begin an approach in IMC and break out before the FAF then I
won't log it as an approach since I'm then doing see-and-avoid and will
be looking for the runway anyway. I just hold myself to a higher
standard than FAA minimums that's all. To each their own I guess.

Bill Zaleski wrote:
> On Fri, 25 Aug 2006 16:18:09 GMT, "Steven P. McNicoll"
> > wrote:
>
>
>>"Robert Chambers" > wrote in message
t...
>>
>>>No not at all, that's my personal decision to count an approach as legit.
>>>I figure if I get to the FAF and I'm not IMC then I'd need a hood and a
>>>safety pilot to make it count as one of the 6 approaches.
>>
>>Why do you feel it's not kosher otherwise?
>
>
>
> This is the only "FAA" reference to what they consider an appropriate
> amount of IMC constitutes for logging for currency that I have ever
> been able to find.
>
>
> FAAviation News , July-Aug 1990.
>
> "Once you have been cleared for and have initiated an approach in IMC,
> you may log that approach for instrument currency, regardless of the
> altitude at which you break out of the clouds"
>
>
>
>

"Jim Macklin" > wrote in message
news:hqBHg.5978$SZ3.5107@dukeread04...
>A IPC is valid for 6 months. You need to read legal documents using formal
>rules.

Nothing in the FARs says anything about a validity period (6 months or
otherwise) for an IPC. There is a 6-month validity period for the 6
approaches (and holds and tracking).

>The IPC rule says that a pilot who does not meet the 6-6 rule may take an
>IPC,

Yes.

> the IPC becomes mandatory 12 months after the date currency was
> established.

That's a confusing way to put it, since currency may have been established
years ago, and maintained ever since. The IPC becomes mandatory six months
after currency has expired.

But that's not the question at issue. We all agree when the IPC is required.
We all agree that an IPC might include only 3 approaches. The question is
whether, *in addition* to the IPC (when the IPC is required), you have to
satisfy the 6-in-6 requirement of 61.57c in order to be instrument current.
My point is that nothing in 61.57c (or in 61.57d) asserts that the 6-in-6
requirement is waived by the completion of an IPC. As the regs are written
(though perhaps not as they're interpreted in practice), the 6-in-6
requirement has to be met even if you've just had an IPC.

>You carefully snipped the quoted regulation so it couldn't be seen by
>anyone else.

Uh, sure Jim. No one here is familiar with 61.57d, or knows how to find it
unless we keep repeating it in each of our posts.

> The check is available at any time

Yes.

> and fully meets the requirements of legal currency...

No. That's exactly what the regs *don't* say. If you disagree, please
explain what part of 61.57c or 61.57d (or any other FAR) supports your claim
that an IPC by itself suffices to reestablish currency.

What 61.57d says is that if your instrument currency expired six months ago,
then you're *not* instrument-current again *unless* you pass an IPC. Nowhere
does it say that you *are* current if you *do* pass an IPC but *do not* meet
the *other* instrument-currency requirements (such as the 6-in-6 rule in
61.57c).

> You need to read legal documents using formal rules.
> If you don't "see" the meaning of the words, suggest you find a
> qualified high school English teacher

Good advice. Please heed it yourself. In the meantime, the relevant formal
principle is that "not-P unless Q" is equivalent to "not-Q implies not-P",
but is *not* equivalent to "Q implies P". But the latter is how you're
(incorrectly) interpreting it. (Here, P is "instrument-current again after
currency lapsed for at least six months" and Q is "passed an IPC".)

--Gary

On 24 Aug 2006 13:22:36 -0700, "Robert M. Gary" >
wrote:

>Yea, the IPC can be done in less time than doing 6 in 6 for currency
>assuming a current pilot. I almost always do IPCs myself just because
>it takes so damn long to get in 6 approachs at busy airports. The
>requirements of the IPC are very strickly called out in the IFR PTS. It
>is not open to the latitude that a BFR is.
>
>-Robert, CFII

I also like to think that an occasional IPC may help to uncover any
bad habits I might have developed. A pilot can rely on 6 in 6 to stay
continuously current for years without ever seeing a CFII. A Flight
Review administered by a CF-single-I may not give the same scrutiny to
instrument skills as an IPC while also working on stalls and short
landings. Just flying 6 approaches doesn't teach much if it's always
the same approach. An IPC offers a chance to review all those skills.

Now another question: Can the IPC be used as part of a Wings phase?

RK Henry

RK Henry wrote:
> On 24 Aug 2006 13:22:36 -0700, "Robert M. Gary" >
> wrote:
> Now another question: Can the IPC be used as part of a Wings phase?

For Land Wings it would certainly count as the 1 hour required for
instrument training. It wouldn't do you any good for Sea Wings.

-Robert

"Robert M. Gary" > wrote in
ups.com:

> For Land Wings it would certainly count as the 1 hour required for
> instrument training. It wouldn't do you any good for Sea Wings.
>
AC61-91H(7)(b) shows a one hour requirement of instrument instruction
under certain circumstances, see "Note".

--

RK Henry wrote:

> Now another question: Can the IPC be used as part of a Wings phase?
>
> RK Henry

Absoluely, and mine usually do. It's just a pretty intense wings flight
for that portion of wings.

On 2006-08-25, Jim Macklin <> wrote:
>
> A IPC is valid for 6 months. You need to read legal documents using =
> formal rules. The IPC rule says that a pilot who does not meet the 6-6 =
> rule may take an IPC, the IPC becomes mandatory 12 months after the date =
> currency was established.

Right, and it doesn't say anything about the previous rule, which
independently states that you have to have 6-in-6.

> There are clearly many examples were the 6-6 rule is inadequate

Sure, the rules don't equal safety. I was just asking about the rules.

> If you don't "see" the meaning of the words, suggest you find a =
> qualified high school English teacher or a lawyer and have them show =
> you. You carefully snipped the quoted regulation so it couldn't be seen =
> by anyone else.

No need to be a jerk. I snipped the quoted regulation because you only
quoted part (d) which is not the whole story. Your comment (snipping
again):

> The check is available at any time and fully meets the
> requirements of legal currency...

is not supported by the regulation. You then paraphrase it in support:

> a person who does not meet the instrument experience
> requirements of paragraph (c) until that person passes an
> instrument proficiency check

If it *said* that, then I'd agree. *Your* phrasing says you meet (c) if
you pass an IPC. But the reg says that a person who does not meet (c) in
time, or within 6 months, may not serve as PIC under IFR until ... an IPC.
So what passing an IPC does is remove the restriction in (d) about not
serving as PIC under IFR. Independently, section (c) has rules about
recency of experience for IFR. Just like section (b) has rules about
night takeoffs and landings. Just passing the IPC to lift one "may
not serve as PIC" restriction does not lift them all.

--
Ben Jackson AD7GD
>
http://www.ben.com/

> Now another question: Can the IPC be used as part of a Wings phase?

One of the parts of a wings phase is one hour of instrument instruction.
If the IPC takes an hour or more, then it counts.

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

My wife is an English Master and an English teacher at the
college level and I've been answering questions to the Feds
about what their regulations mean for many years. I have
taken so many annual and 6 month checks under FAR 141 and
135 that I've lost count. I have a number of friends who
are lawyers.

We have told you the answer, you may contact the FAA
Regional office and get a letter from their legal staff.


"Gary Drescher" > wrote in message
...
| "Jim Macklin" > wrote
in message
| news:hqBHg.5978$SZ3.5107@dukeread04...
| >A IPC is valid for 6 months. You need to read legal
documents using formal
| >rules.
|
| Nothing in the FARs says anything about a validity period
(6 months or
| otherwise) for an IPC. There is a 6-month validity period
for the 6
| approaches (and holds and tracking).
|
| >The IPC rule says that a pilot who does not meet the 6-6
rule may take an
| >IPC,
|
| Yes.
|
| > the IPC becomes mandatory 12 months after the date
currency was
| > established.
|
| That's a confusing way to put it, since currency may have
been established
| years ago, and maintained ever since. The IPC becomes
mandatory six months
| after currency has expired.
|
| But that's not the question at issue. We all agree when
the IPC is required.
| We all agree that an IPC might include only 3 approaches.
The question is
| whether, *in addition* to the IPC (when the IPC is
required), you have to
| satisfy the 6-in-6 requirement of 61.57c in order to be
instrument current.
| My point is that nothing in 61.57c (or in 61.57d) asserts
that the 6-in-6
| requirement is waived by the completion of an IPC. As the
regs are written
| (though perhaps not as they're interpreted in practice),
the 6-in-6
| requirement has to be met even if you've just had an IPC.
|
| >You carefully snipped the quoted regulation so it
couldn't be seen by
| >anyone else.
|
| Uh, sure Jim. No one here is familiar with 61.57d, or
knows how to find it
| unless we keep repeating it in each of our posts.
|
| > The check is available at any time
|
| Yes.
|
| > and fully meets the requirements of legal currency...
|
| No. That's exactly what the regs *don't* say. If you
disagree, please
| explain what part of 61.57c or 61.57d (or any other FAR)
supports your claim
| that an IPC by itself suffices to reestablish currency.
|
| What 61.57d says is that if your instrument currency
expired six months ago,
| then you're *not* instrument-current again *unless* you
pass an IPC. Nowhere
| does it say that you *are* current if you *do* pass an IPC
but *do not* meet
| the *other* instrument-currency requirements (such as the
6-in-6 rule in
| 61.57c).
|
| > You need to read legal documents using formal rules.
| > If you don't "see" the meaning of the words, suggest you
find a
| > qualified high school English teacher
|
| Good advice. Please heed it yourself. In the meantime, the
relevant formal
| principle is that "not-P unless Q" is equivalent to "not-Q
implies not-P",
| but is *not* equivalent to "Q implies P". But the latter
is how you're
| (incorrectly) interpreting it. (Here, P is
"instrument-current again after
| currency lapsed for at least six months" and Q is "passed
an IPC".)
|
| --Gary
|
|

You're wrong.


"Ben Jackson" > wrote in message
...
| On 2006-08-25, Jim Macklin <> wrote:
| >
| > A IPC is valid for 6 months. You need to read legal
documents using =
| > formal rules. The IPC rule says that a pilot who does
not meet the 6-6 =
| > rule may take an IPC, the IPC becomes mandatory 12
months after the date =
| > currency was established.
|
| Right, and it doesn't say anything about the previous
rule, which
| independently states that you have to have 6-in-6.
|
| > There are clearly many examples were the 6-6 rule is
inadequate
|
| Sure, the rules don't equal safety. I was just asking
about the rules.
|
| > If you don't "see" the meaning of the words, suggest you
find a =
| > qualified high school English teacher or a lawyer and
have them show =
| > you. You carefully snipped the quoted regulation so it
couldn't be seen =
| > by anyone else.
|
| No need to be a jerk. I snipped the quoted regulation
because you only
| quoted part (d) which is not the whole story. Your
comment (snipping
| again):
|
| > The check is available at any time and fully meets the
| > requirements of legal currency...
|
| is not supported by the regulation. You then paraphrase
it in support:
|
| > a person who does not meet the instrument experience
| > requirements of paragraph (c) until that person passes
an
| > instrument proficiency check
|
| If it *said* that, then I'd agree. *Your* phrasing says
you meet (c) if
| you pass an IPC. But the reg says that a person who does
not meet (c) in
| time, or within 6 months, may not serve as PIC under IFR
until ... an IPC.
| So what passing an IPC does is remove the restriction in
(d) about not
| serving as PIC under IFR. Independently, section (c) has
rules about
| recency of experience for IFR. Just like section (b) has
rules about
| night takeoffs and landings. Just passing the IPC to lift
one "may
| not serve as PIC" restriction does not lift them all.
|
| --
| Ben Jackson AD7GD
| >
| http://www.ben.com/

"Jim Macklin" > wrote in message
news:hbHHg.5999$SZ3.1815@dukeread04...
> My wife is an English Master and an English teacher at the
> college level and I've been answering questions to the Feds
> about what their regulations mean for many years. I have
> taken so many annual and 6 month checks under FAR 141 and
> 135 that I've lost count. I have a number of friends who
> are lawyers.

Instead of appealing to authority, you would do well to try to address the
arguments that Ben and I have presented. In particular, if you (or your wife
or your friends) disagree somehow with my analysis of "not-P unless Q", it
would be helpful to see what your reasoning is.

But you have steadfastly refused to say *anything at all* about the
reasoning by which you get from the wording of the regs to your conclusion
about the sufficiency of an IPC even if the 6-in-6 requirement is not met.
Instead, you repeatedly just quote the regs and then assert your
interpretation, with zero explanation of how you get from the former to the
latter. (And when Ben and I carefully explain how we get to *our*
interpretation, you just reply with "You're wrong".)

> We have told you the answer, you may contact the FAA
> Regional office and get a letter from their legal staff.

That might tell me how the FAA interprets the regs in practice, but I've
said repeatedly that I'm not making any claims about that question (nor is
Ben). I'm just addressing the separate question of what the regs actually
say.

--Gary

> "Gary Drescher" > wrote in message
> ...
> | "Jim Macklin" > wrote
> in message
> | news:hqBHg.5978$SZ3.5107@dukeread04...
> | >A IPC is valid for 6 months. You need to read legal
> documents using formal
> | >rules.
> |
> | Nothing in the FARs says anything about a validity period
> (6 months or
> | otherwise) for an IPC. There is a 6-month validity period
> for the 6
> | approaches (and holds and tracking).
> |
> | >The IPC rule says that a pilot who does not meet the 6-6
> rule may take an
> | >IPC,
> |
> | Yes.
> |
> | > the IPC becomes mandatory 12 months after the date
> currency was
> | > established.
> |
> | That's a confusing way to put it, since currency may have
> been established
> | years ago, and maintained ever since. The IPC becomes
> mandatory six months
> | after currency has expired.
> |
> | But that's not the question at issue. We all agree when
> the IPC is required.
> | We all agree that an IPC might include only 3 approaches.
> The question is
> | whether, *in addition* to the IPC (when the IPC is
> required), you have to
> | satisfy the 6-in-6 requirement of 61.57c in order to be
> instrument current.
> | My point is that nothing in 61.57c (or in 61.57d) asserts
> that the 6-in-6
> | requirement is waived by the completion of an IPC. As the
> regs are written
> | (though perhaps not as they're interpreted in practice),
> the 6-in-6
> | requirement has to be met even if you've just had an IPC.
> |
> | >You carefully snipped the quoted regulation so it
> couldn't be seen by
> | >anyone else.
> |
> | Uh, sure Jim. No one here is familiar with 61.57d, or
> knows how to find it
> | unless we keep repeating it in each of our posts.
> |
> | > The check is available at any time
> |
> | Yes.
> |
> | > and fully meets the requirements of legal currency...
> |
> | No. That's exactly what the regs *don't* say. If you
> disagree, please
> | explain what part of 61.57c or 61.57d (or any other FAR)
> supports your claim
> | that an IPC by itself suffices to reestablish currency.
> |
> | What 61.57d says is that if your instrument currency
> expired six months ago,
> | then you're *not* instrument-current again *unless* you
> pass an IPC. Nowhere
> | does it say that you *are* current if you *do* pass an IPC
> but *do not* meet
> | the *other* instrument-currency requirements (such as the
> 6-in-6 rule in
> | 61.57c).
> |
> | > You need to read legal documents using formal rules.
> | > If you don't "see" the meaning of the words, suggest you
> find a
> | > qualified high school English teacher
> |
> | Good advice. Please heed it yourself. In the meantime, the
> relevant formal
> | principle is that "not-P unless Q" is equivalent to "not-Q
> implies not-P",
> | but is *not* equivalent to "Q implies P". But the latter
> is how you're
> | (incorrectly) interpreting it. (Here, P is
> "instrument-current again after
> | currency lapsed for at least six months" and Q is "passed
> an IPC".)
> |
> | --Gary
> |
> |
>
>

John Godwin wrote:
> "Robert M. Gary" > wrote in
> ups.com:
>
> > For Land Wings it would certainly count as the 1 hour required for
> > instrument training. It wouldn't do you any good for Sea Wings.
> >
> AC61-91H(7)(b) shows a one hour requirement of instrument instruction
> under certain circumstances, see "Note".

Hi John. My reading of that is just that a non-instrument rated pilot
does not need to shoot approaches, but still needs to do 1 hour of
"basic instrument training" (their words).
However, for SeaWings there is no instrument requirement at all (I just
did my Seawings yesterday)...


b. Seaplanes and Amphibians.
(1) One hour of flight training in a seaplane or amphibian
to include a demonstration by the applicant of a complete
seaplane or amphibian passenger safety briefing, a weight
and balance computation and interpretation for the actual
flight, a review and evaluation of current and forecast
weather, and on-the-water training in docking, beaching
and anchoring, and maneuvering in confined areas.
(2) One hour of flight training in a seaplane or amphibian
to include landing area assessment, safe approaches and
departures, takeoffs, and landings, including crosswind,
rough water, and glassy water techniques. (Conditions
may be simulated.)
(3) One hour of flight training in a seaplane or amphibian
to include power-on and power-offstalls in various configurations with
minimum altitude loss,
power-off emergency landings, step taxi, step turns, rapid
decelerations from the step, and emergency procedures.
In addition to the 1 hour of flight time (not included in the 1
hour), there must be a discussion of stall avoidance and
prevention techniques,

-Robert

"Robert M. Gary" > wrote in
ps.com:

> Hi John. My reading of that is just that a non-instrument rated
> pilot does not need to shoot approaches, but still needs to do 1
> hour of "basic instrument training" (their words).
> However, for SeaWings there is no instrument requirement at all (I
> just did my Seawings yesterday)...

NOTE: If the applicant is not qualified
and current in accordance with 61.57 for
instrument flight, 1 additional hour of
basic instrument training with emphasis
on partial panel approaches, inadvertent
penetration into instrument
meteorological conditions (180 turn),
descent into visual meteorological
conditions, and safe operations shall he
accomplished in an airplane, seaplane,
FAAapproved aircraft simulator, or
training device for each odd-numbered
award phase (Phase 1, III, V, etc.).

--

John Godwin wrote:
> "Robert M. Gary" > wrote in
> ps.com:
>
> > Hi John. My reading of that is just that a non-instrument rated
> > pilot does not need to shoot approaches, but still needs to do 1
> > hour of "basic instrument training" (their words).
> > However, for SeaWings there is no instrument requirement at all (I
> > just did my Seawings yesterday)...
>
> NOTE: If the applicant is not qualified
> and current in accordance with 61.57 for
> instrument flight, 1 additional hour of
> basic instrument training with emphasis
> on partial panel approaches, inadvertent
> penetration into instrument
> meteorological conditions (180 turn),
> descent into visual meteorological
> conditions, and safe operations shall he
> accomplished in an airplane, seaplane,
> FAAapproved aircraft simulator, or
> training device for each odd-numbered
> award phase (Phase 1, III, V, etc.).

Yes, but none of that applies to Seawings because there is no
instrument requirement whatsoever for Seawings.

-Robert

Going back and re-reading that, you're right. I'll bet most seaplane
operations are not aware of that. It appears that if a pilot is not
instrument current, and is doing an odd phase of sea wings (1,3,5,7,..)
he must do an additional hour of instrument training. That becomes very
hard since many seaplane operators remove all gyros from their
airplanes because they get beat to crap by the impact of water
landings. It also messes up their "fix price" wings offering.

-Robert

John Godwin wrote:
> "Robert M. Gary" > wrote in
> ps.com:
> NOTE: If the applicant is not qualified
> and current in accordance with 61.57 for
> instrument flight, 1 additional hour of
> basic instrument training with emphasis
> on partial panel approaches, inadvertent
> penetration into instrument
> meteorological conditions (180 turn),
> descent into visual meteorological
> conditions, and safe operations shall he
> accomplished in an airplane, seaplane,
> FAAapproved aircraft simulator, or
> training device for each odd-numbered
> award phase (Phase 1, III, V, etc.).
>
> --

Interesting. That an IPC would make a pilot current for IFR for 6
months, regardless of the number of approaches done, is something that
I've always just thought I've "known". But looking at the regs, to my
surprise, they just don't seem to say that.

So where did the notion come from? Well, I think I know where it got
stuck in my head, at least, namely from an FAA IR knowledge test bank
question, which goes a little something like this:

4021 A20
How long does a pilot meet the recency of experience requirements
for IFR flight
after successfully completing an instrument proficiency check if no
further
IFR flights are made?
A. 90 days.
B. 6 calendar months.
C. 12 calendat months.

I think the "intent" is that the IPC resets the clock, regardless of
number of approaches. It would be "nice", though, if the rules actually
stated what many of us are assuming they mean.
-harry

Its just a case of a poorly worded FAR. Certainly the FAA has always
held that an IPC meets the instrument currency requirements of 61.56 as
does an instrument checkride (which is also not stated in the FAR,
after your instrument checkride are you not instrument current???).
BTW: A CFII checkride does not automatically reset your clock.

-Robert

wrote:
> Interesting. That an IPC would make a pilot current for IFR for 6
> months, regardless of the number of approaches done, is something that
> I've always just thought I've "known". But looking at the regs, to my
> surprise, they just don't seem to say that.
>
> So where did the notion come from? Well, I think I know where it got
> stuck in my head, at least, namely from an FAA IR knowledge test bank
> question, which goes a little something like this:
>
> 4021 A20
> How long does a pilot meet the recency of experience requirements
> for IFR flight
> after successfully completing an instrument proficiency check if no
> further
> IFR flights are made?
> A. 90 days.
> B. 6 calendar months.
> C. 12 calendat months.
>
> I think the "intent" is that the IPC resets the clock, regardless of
> number of approaches. It would be "nice", though, if the rules actually
> stated what many of us are assuming they mean.
> -harry

> Its just a case of a poorly worded FAR.

Why is it that regulations, which are presumably written by lawyers, who
are well versed in the English language and have more schooling than
most, are so often so poorly worded?

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

Jose asked,

> Why is it that regulations, which are presumably written by lawyers, who
> are well versed in the English language and have more schooling than most,
> are so often so poorly worded?

I asked that question at a convention to two gentlemen who identified
themselves as lawyers who both previously worked at the FAA. They both
agreed that regulations are INTENTIONALLY written to be ambiguous. They
weren't kidding, either. The less clear a regulation (or law) is, the more
liberally it can be interpreted -- by lawyers -- whose job depends on the
need for interpretation.

Jon

"Robert M. Gary" > wrote in message
oups.com...
> Its just a case of a poorly worded FAR. Certainly the FAA has always
> held that an IPC meets the instrument currency requirements of 61.56 as
> does an instrument checkride (which is also not stated in the FAR,
> after your instrument checkride are you not instrument current???).

As the regs are written, passing a checkride does not make you current
unless you've completed six approaches within the past six months. (Again,
that may not be how the FAA interprets the regs, but that's what they say.)

--Gary

"Jon Woellhaf" > wrote in message
. ..
> Jose asked,
>
>> Why is it that regulations, which are presumably written by lawyers, who
>> are well versed in the English language and have more schooling than
>> most, are so often so poorly worded?
>
> I asked that question at a convention to two gentlemen who identified
> themselves as lawyers who both previously worked at the FAA. They both
> agreed that regulations are INTENTIONALLY written to be ambiguous. They
> weren't kidding, either. The less clear a regulation (or law) is, the more
> liberally it can be interpreted -- by lawyers -- whose job depends on the
> need for interpretation.

I don't see how that theory could explain the matter at hand. Here, the regs
clearly (not ambiguously) say one thing, and the FAA (reportedly) interprets
them to mean something *more generous*. That is, the FAA's interpretation is
less restrictive on pilots than what the regs actually say, leading to
strictly *fewer* opportunities to prosecute pilots and involve lawyers.

--Gary

> wrote:
> Interesting. That an IPC would make a pilot current for IFR for 6
> months, regardless of the number of approaches done, is something
> that I've always just thought I've "known".

It works the other way too. Let's say you've only got 3 approaches
logged in the last 6 months and come to me for an IPC. We fly 3 more
approaches, I decide that you suck at instruments and decline to sign
you off for an IPC.

You're now legally current anyway, by virtue of having flown 6
approaches.

"Roy Smith" > wrote in message
...
> > wrote:
>> Interesting. That an IPC would make a pilot current for IFR for 6
>> months, regardless of the number of approaches done, is something
>> that I've always just thought I've "known".
>
> It works the other way too. Let's say you've only got 3 approaches
> logged in the last 6 months and come to me for an IPC. We fly 3 more
> approaches, I decide that you suck at instruments and decline to sign
> you off for an IPC.
>
> You're now legally current anyway, by virtue of having flown 6
> approaches.

Not if the approaches were flown in VMC and you do not sign as safety pilot.

Allen > wrote:
>
>"Roy Smith" > wrote in message
...
>> > wrote:
>>> Interesting. That an IPC would make a pilot current for IFR for 6
>>> months, regardless of the number of approaches done, is something
>>> that I've always just thought I've "known".
>>
>> It works the other way too. Let's say you've only got 3 approaches
>> logged in the last 6 months and come to me for an IPC. We fly 3 more
>> approaches, I decide that you suck at instruments and decline to sign
>> you off for an IPC.
>>
>> You're now legally current anyway, by virtue of having flown 6
>> approaches.
>
>Not if the approaches were flown in VMC and you do not sign as safety pilot.

There's no such thing as "sign as safety pilot".

"Roy Smith" > wrote in message
...
> Allen > wrote:
>>
>>"Roy Smith" > wrote in message
...
>>> > wrote:
>>>> Interesting. That an IPC would make a pilot current for IFR for 6
>>>> months, regardless of the number of approaches done, is something
>>>> that I've always just thought I've "known".
>>>
>>> It works the other way too. Let's say you've only got 3 approaches
>>> logged in the last 6 months and come to me for an IPC. We fly 3 more
>>> approaches, I decide that you suck at instruments and decline to sign
>>> you off for an IPC.
>>>
>>> You're now legally current anyway, by virtue of having flown 6
>>> approaches.
>>
>>Not if the approaches were flown in VMC and you do not sign as safety
>>pilot.
>
> There's no such thing as "sign as safety pilot".

Whether you write or he writes it your name will be in his logbook.

A one paragraph regulation has dozens and even hundreds of
pages of legal opinion and testimony, as part of its
adoption.


"Gary Drescher" > wrote in message
. ..
| "Jon Woellhaf" > wrote in message
| . ..
| > Jose asked,
| >
| >> Why is it that regulations, which are presumably
written by lawyers, who
| >> are well versed in the English language and have more
schooling than
| >> most, are so often so poorly worded?
| >
| > I asked that question at a convention to two gentlemen
who identified
| > themselves as lawyers who both previously worked at the
FAA. They both
| > agreed that regulations are INTENTIONALLY written to be
ambiguous. They
| > weren't kidding, either. The less clear a regulation (or
law) is, the more
| > liberally it can be interpreted -- by lawyers -- whose
job depends on the
| > need for interpretation.
|
| I don't see how that theory could explain the matter at
hand. Here, the regs
| clearly (not ambiguously) say one thing, and the FAA
(reportedly) interprets
| them to mean something *more generous*. That is, the FAA's
interpretation is
| less restrictive on pilots than what the regs actually
say, leading to
| strictly *fewer* opportunities to prosecute pilots and
involve lawyers.
|
| --Gary
|
|

All that is required is for the pilot to record the name of
the safety pilot, no endorsement is required, not even the
certificate number.

But after 12 months from the first day you were current [six
months after currency lapsed] you must have an IPC.
So, after 12 months, with no approaches in the mean time, an
IPC makes you current.

61.57 says an IPC makes you current, it does not say an IPC
and 6 approaches.



"Allen" > wrote in message
...
|
| "Roy Smith" > wrote in message
| ...
| > Allen > wrote:
| >>
| >>"Roy Smith" > wrote in message
| ...
| >>> > wrote:
| >>>> Interesting. That an IPC would make a pilot current
for IFR for 6
| >>>> months, regardless of the number of approaches done,
is something
| >>>> that I've always just thought I've "known".
| >>>
| >>> It works the other way too. Let's say you've only got
3 approaches
| >>> logged in the last 6 months and come to me for an IPC.
We fly 3 more
| >>> approaches, I decide that you suck at instruments and
decline to sign
| >>> you off for an IPC.
| >>>
| >>> You're now legally current anyway, by virtue of having
flown 6
| >>> approaches.
| >>
| >>Not if the approaches were flown in VMC and you do not
sign as safety
| >>pilot.
| >
| > There's no such thing as "sign as safety pilot".
|
| Whether you write or he writes it your name will be in his
logbook.
|
|

On 2006-08-30, Jim Macklin <> wrote:
> 61.57 says an IPC makes you current, it does not say an IPC
> and 6 approaches.

You're wrong.

--
Ben Jackson AD7GD
>
http://www.ben.com/

On Wed, 30 Aug 2006 19:08:11 -0500, Ben Jackson > wrote:

>On 2006-08-30, Jim Macklin <> wrote:
>> 61.57 says an IPC makes you current, it does not say an IPC
>> and 6 approaches.
>
>You're wrong.

Jim is right. I spent a week at the FAA examiner certification school
at Oak City. All the teachers/FAA managers concurred that the initial
instrument checkride, as well as an IPC alone, resets the clock to
zero on instrument currency. FAR 61.57 (d) sets the requirements to
act as PIC if (c) is not met. It does not state that (c) must also be
met. (d) is the controlling paragraph for one out of currency, not
(c). Paragraph (c) is the recency of experience requirements to
operate IFR. Beyond 6 months, paragraph (d) now applies, as it
contains the verbiage of what is required after the first 6 month
period (6 more months to complete (c) OR IPC only beyond that).
Paragraph (c) becomes a moot point after the time that you are allowed
to comply with it passes. (d) takes over and stands alone. This is
how it was explained to me. It was also brought up, (without need, I
feel), that one can complete an IPC at any time, and not have to be
out of currency to do so. If one can assume that 6 approches are also
needed, then the verbiage of (d) could also be construed to mean that
you must be 6 months out of currency in order to do an IPC. (Silly)

There are questions in the instrument knowledge test question pool
whose correct answers support this. The faq's, that by letter of
memorandum were once stated as FAA policy, used to support this.
Advisory Circular 61-98A, although out of date, supports this. Sure
the FAR's are vague at times, but there have been plenty of references
to policy that make the case. If you just understand that one
paragraph is for maintaining currency, and the other to get back
current, if you are not, the regulation's intent is clear.

The nice thing about the FAR, is it is like the Bible, we
all should follow it and each of us gets to decide what it
means.

FAR 91 first word is "except."

Thanks.

BTW, I'm not a Bible thumper, maybe because it is vague.


--
James H. Macklin
ATP,CFI,A&P

--
The people think the Constitution protects their rights;
But government sees it as an obstacle to be overcome.
some support
http://www.usdoj.gov/olc/secondamendment2.htm
See http://www.fija.org/ more about your rights and duties.


"Bill Zaleski" > wrote in message
...
| On Wed, 30 Aug 2006 19:08:11 -0500, Ben Jackson
> wrote:
|
| >On 2006-08-30, Jim Macklin <> wrote:
| >> 61.57 says an IPC makes you current, it does not say an
IPC
| >> and 6 approaches.
| >
| >You're wrong.
|
| Jim is right. I spent a week at the FAA examiner
certification school
| at Oak City. All the teachers/FAA managers concurred that
the initial
| instrument checkride, as well as an IPC alone, resets the
clock to
| zero on instrument currency. FAR 61.57 (d) sets the
requirements to
| act as PIC if (c) is not met. It does not state that (c)
must also be
| met. (d) is the controlling paragraph for one out of
currency, not
| (c). Paragraph (c) is the recency of experience
requirements to
| operate IFR. Beyond 6 months, paragraph (d) now applies,
as it
| contains the verbiage of what is required after the first
6 month
| period (6 more months to complete (c) OR IPC only beyond
that).
| Paragraph (c) becomes a moot point after the time that you
are allowed
| to comply with it passes. (d) takes over and stands alone.
This is
| how it was explained to me. It was also brought up,
(without need, I
| feel), that one can complete an IPC at any time, and not
have to be
| out of currency to do so. If one can assume that 6
approches are also
| needed, then the verbiage of (d) could also be construed
to mean that
| you must be 6 months out of currency in order to do an
IPC. (Silly)
|
| There are questions in the instrument knowledge test
question pool
| whose correct answers support this. The faq's, that by
letter of
| memorandum were once stated as FAA policy, used to support
this.
| Advisory Circular 61-98A, although out of date, supports
this. Sure
| the FAR's are vague at times, but there have been plenty
of references
| to policy that make the case. If you just understand that
one
| paragraph is for maintaining currency, and the other to
get back
| current, if you are not, the regulation's intent is clear.
|

"Bill Zaleski" > wrote in message
...
> FAR 61.57 (d) sets the requirements to act as PIC if (c) is not met.

No, it asserts *a* requirement that has to be met if (c) is not met (or
rather, if c has not been met for six months).

> It does not state that (c) must also be met.

Of course not. Why should (d) reaffirm (c)? Or reaffirm any other FARs? The
point is that nothing says that (c) *doesn't* still have to be met.

In general, you're required to obey *every* regulation. You can't decide
that because you're complying with one, you can ignore another one (unless
the wording explicitly says that).

> (d) is the controlling paragraph for one out of currency, not (c).

There's nothing in the FARs that says (c) doesn't apply too.

> (d) takes over and stands alone.

But it doesn't say that anywhere in the FARs.

> This is how it was explained to me.

Did the explainers say how they arrived at their interpretation that (d)
sets forth a substitute requirement rather than an additional requirement?
If so, would you tell us their explanation?

> If one can assume that 6 approches are also
> needed, then the verbiage of (d) could also be construed to mean that
> you must be 6 months out of currency in order to do an IPC.

How would that follow? Where does (d) say that?

> There are questions in the instrument knowledge test question pool
> whose correct answers support this. The faq's, that by letter of
> memorandum were once stated as FAA policy, used to support this.
> Advisory Circular 61-98A, although out of date, supports this.

It may well be that the FAA takes that position. All I'm saying is that if
so, they're contradicting what the FARs clearly state.

--Gary

see
http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_101_00.pdf#search=%22site%3Awww.faa.gov%20instru ment%20competency%20check%22

Which say in part...
(b) an IFR currency record, a copy of

logbook endorsement for 14 CFR § 61.57 instrument

competency check, or a record of instrument currency

(6 hours and 6 approaches) obtained within the past

6 months.











"Gary Drescher" > wrote in message
. ..
| "Bill Zaleski" > wrote in
message
| ...
| > FAR 61.57 (d) sets the requirements to act as PIC if
(c) is not met.
|
| No, it asserts *a* requirement that has to be met if (c)
is not met (or
| rather, if c has not been met for six months).
|
| > It does not state that (c) must also be met.
|
| Of course not. Why should (d) reaffirm (c)? Or reaffirm
any other FARs? The
| point is that nothing says that (c) *doesn't* still have
to be met.
|
| In general, you're required to obey *every* regulation.
You can't decide
| that because you're complying with one, you can ignore
another one (unless
| the wording explicitly says that).
|
| > (d) is the controlling paragraph for one out of
currency, not (c).
|
| There's nothing in the FARs that says (c) doesn't apply
too.
|
| > (d) takes over and stands alone.
|
| But it doesn't say that anywhere in the FARs.
|
| > This is how it was explained to me.
|
| Did the explainers say how they arrived at their
interpretation that (d)
| sets forth a substitute requirement rather than an
additional requirement?
| If so, would you tell us their explanation?
|
| > If one can assume that 6 approches are also
| > needed, then the verbiage of (d) could also be construed
to mean that
| > you must be 6 months out of currency in order to do an
IPC.
|
| How would that follow? Where does (d) say that?
|
| > There are questions in the instrument knowledge test
question pool
| > whose correct answers support this. The faq's, that by
letter of
| > memorandum were once stated as FAA policy, used to
support this.
| > Advisory Circular 61-98A, although out of date, supports
this.
|
| It may well be that the FAA takes that position. All I'm
saying is that if
| so, they're contradicting what the FARs clearly state.
|
| --Gary
|
|

On Wed, 30 Aug 2006 22:40:01 -0400, "Gary Drescher"
> wrote:

>"Bill Zaleski" > wrote in message
...
>> FAR 61.57 (d) sets the requirements to act as PIC if (c) is not met.
>
>No, it asserts *a* requirement that has to be met if (c) is not met (or
>rather, if c has not been met for six months).
>
>> It does not state that (c) must also be met.
>
>Of course not. Why should (d) reaffirm (c)? Or reaffirm any other FARs? The
>point is that nothing says that (c) *doesn't* still have to be met.
>
>In general, you're required to obey *every* regulation. You can't decide
>that because you're complying with one, you can ignore another one (unless
>the wording explicitly says that).
>
>> (d) is the controlling paragraph for one out of currency, not (c).
>
>There's nothing in the FARs that says (c) doesn't apply too.
>
>> (d) takes over and stands alone.
>
>But it doesn't say that anywhere in the FARs.
>
>> This is how it was explained to me.
>
>Did the explainers say how they arrived at their interpretation that (d)
>sets forth a substitute requirement rather than an additional requirement?
>If so, would you tell us their explanation?
>
>> If one can assume that 6 approches are also
>> needed, then the verbiage of (d) could also be construed to mean that
>> you must be 6 months out of currency in order to do an IPC.
>
>How would that follow? Where does (d) say that?
>
>> There are questions in the instrument knowledge test question pool
>> whose correct answers support this. The faq's, that by letter of
>> memorandum were once stated as FAA policy, used to support this.
>> Advisory Circular 61-98A, although out of date, supports this.
>
>It may well be that the FAA takes that position. All I'm saying is that if
>so, they're contradicting what the FARs clearly state.
>
>--Gary
Yes, the FAR's are clear here, if you read the paragraph that applies
to what you are seeking.
How much simpler can it be than to read the titles of (c) and (d)

(c) Instrument experience: This is what you have to do to determine
your current state of required instrument experience. This is all it
addresses and nothing more. IF you decide that you are not current,
you are done with this paragraph and it does not apply to you any
longer (for the moment). Go to paragraph (d) for further guidance.

(d) IPC: This is what you have to look at and do to GET current,
depending on whether you are out of currency by more than 6 months,
(IPC), or less than six months, (do the damn approaches OR do an IPC
anyway). It says "a person who does not meet (c)", can't be PIC
until you do the stuff spelled out in (d), (not necessarily the
paragraph (c) stuff, unless you qualify). If you are doing an IPC,
you are not bound by the requirements of (c) or it would be included
in the verbage. This refers you back to (c), but only gives relief via
approaches if you are within 6 months of your last currency, and
provides the option of completing the 6 approaches. It is the
guideline for getting current, and the IPC does not mandate anything
outside of the task table in the Instrument PTS. Although it doesn't
state so, an IPC is ALWAYS an option, regardless of currency status,
Paragraph (d) is clearly relief from paragraph(c) via the IPC route
alone. It in no way suggests that you have to do both.

Since I am always willing to listen and learn, let me pose this to
the logic that applies to intrepretation of the FAR's.

Is it a violation of 91.126 (b) (1) when you make a right turn to join
a left downwind from a 45 degree entry? Strict interpretation says
yes, common sense says no.

On Wed, 30 Aug 2006 22:50:07 -0500, "Jim Macklin"
> wrote:

>see
>http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_101_00.pdf#search=%22site%3Awww.faa.gov%20instru ment%20competency%20check%22
>
>Which say in part...
>(b) an IFR currency record, a copy of
>
>logbook endorsement for 14 CFR § 61.57 instrument
>
>competency check, or a record of instrument currency
>
>(6 hours and 6 approaches) obtained within the past
>
>6 months.
>

Good job, Jim. An FAA order is law for inspectors. Granted the order
is outdated, but the intent is clear.
>
>
>
>
>
>
>
>
>
>
>"Gary Drescher" > wrote in message
. ..
>| "Bill Zaleski" > wrote in
>message
>| ...
>| > FAR 61.57 (d) sets the requirements to act as PIC if
>(c) is not met.
>|
>| No, it asserts *a* requirement that has to be met if (c)
>is not met (or
>| rather, if c has not been met for six months).
>|
>| > It does not state that (c) must also be met.
>|
>| Of course not. Why should (d) reaffirm (c)? Or reaffirm
>any other FARs? The
>| point is that nothing says that (c) *doesn't* still have
>to be met.
>|
>| In general, you're required to obey *every* regulation.
>You can't decide
>| that because you're complying with one, you can ignore
>another one (unless
>| the wording explicitly says that).
>|
>| > (d) is the controlling paragraph for one out of
>currency, not (c).
>|
>| There's nothing in the FARs that says (c) doesn't apply
>too.
>|
>| > (d) takes over and stands alone.
>|
>| But it doesn't say that anywhere in the FARs.
>|
>| > This is how it was explained to me.
>|
>| Did the explainers say how they arrived at their
>interpretation that (d)
>| sets forth a substitute requirement rather than an
>additional requirement?
>| If so, would you tell us their explanation?
>|
>| > If one can assume that 6 approches are also
>| > needed, then the verbiage of (d) could also be construed
>to mean that
>| > you must be 6 months out of currency in order to do an
>IPC.
>|
>| How would that follow? Where does (d) say that?
>|
>| > There are questions in the instrument knowledge test
>question pool
>| > whose correct answers support this. The faq's, that by
>letter of
>| > memorandum were once stated as FAA policy, used to
>support this.
>| > Advisory Circular 61-98A, although out of date, supports
>this.
>|
>| It may well be that the FAA takes that position. All I'm
>saying is that if
>| so, they're contradicting what the FARs clearly state.
>|
>| --Gary
>|
>|
>

Here is more from the FAA
http://www.faa.gov/safety/programs_initiatives/oversight/iasa/model_aviation/media/PART08.doc

Scroll to para 8.4.1.10



"Jim Macklin" > wrote
in message news:50tJg.6438$SZ3.1037@dukeread04...
| see
|
http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_101_00.pdf#search=%22site%3Awww.faa.gov%20instru ment%20competency%20check%22
|
| Which say in part...
| (b) an IFR currency record, a copy of
|
| logbook endorsement for 14 CFR § 61.57 instrument
|
| competency check, or a record of instrument currency
|
| (6 hours and 6 approaches) obtained within the past
|
| 6 months.
|
|
|
|
|
|
|
|
|
|
|
| "Gary Drescher" > wrote in message
| . ..
|| "Bill Zaleski" > wrote in
| message
|| ...
|| > FAR 61.57 (d) sets the requirements to act as PIC if
| (c) is not met.
||
|| No, it asserts *a* requirement that has to be met if (c)
| is not met (or
|| rather, if c has not been met for six months).
||
|| > It does not state that (c) must also be met.
||
|| Of course not. Why should (d) reaffirm (c)? Or reaffirm
| any other FARs? The
|| point is that nothing says that (c) *doesn't* still have
| to be met.
||
|| In general, you're required to obey *every* regulation.
| You can't decide
|| that because you're complying with one, you can ignore
| another one (unless
|| the wording explicitly says that).
||
|| > (d) is the controlling paragraph for one out of
| currency, not (c).
||
|| There's nothing in the FARs that says (c) doesn't apply
| too.
||
|| > (d) takes over and stands alone.
||
|| But it doesn't say that anywhere in the FARs.
||
|| > This is how it was explained to me.
||
|| Did the explainers say how they arrived at their
| interpretation that (d)
|| sets forth a substitute requirement rather than an
| additional requirement?
|| If so, would you tell us their explanation?
||
|| > If one can assume that 6 approches are also
|| > needed, then the verbiage of (d) could also be
construed
| to mean that
|| > you must be 6 months out of currency in order to do an
| IPC.
||
|| How would that follow? Where does (d) say that?
||
|| > There are questions in the instrument knowledge test
| question pool
|| > whose correct answers support this. The faq's, that by
| letter of
|| > memorandum were once stated as FAA policy, used to
| support this.
|| > Advisory Circular 61-98A, although out of date,
supports
| this.
||
|| It may well be that the FAA takes that position. All I'm
| saying is that if
|| so, they're contradicting what the FARs clearly state.
||
|| --Gary
||
||
|
|

Years ago, before the USGPO decided that the pages were
printed on solid gold, I subscribed to the FARs. It took 4
4 inch ring binders for parts 61 and 91, there were at least
a dozen pages of comments for each regulation...why it was
needed, what it meant and what the NPRM comments had said
and any revision made in response. Just reading a two or
three sentence regulation is only a small part of the law.



--
James H. Macklin
ATP,CFI,A&P

"Bill Zaleski" > wrote in message
...
| On Wed, 30 Aug 2006 22:50:07 -0500, "Jim Macklin"
| > wrote:
|
| >see
|
>http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_101_00.pdf#search=%22site%3Awww.faa.gov%20instru ment%20competency%20check%22
| >
| >Which say in part...
| >(b) an IFR currency record, a copy of
| >
| >logbook endorsement for 14 CFR § 61.57 instrument
| >
| >competency check, or a record of instrument currency
| >
| >(6 hours and 6 approaches) obtained within the past
| >
| >6 months.
| >
|
| Good job, Jim. An FAA order is law for inspectors.
Granted the order
| is outdated, but the intent is clear.
| >
| >
| >
| >
| >
| >
| >
| >
| >
| >
| >"Gary Drescher" > wrote in message
| . ..
| >| "Bill Zaleski" > wrote in
| >message
| >| ...
| >| > FAR 61.57 (d) sets the requirements to act as PIC if
| >(c) is not met.
| >|
| >| No, it asserts *a* requirement that has to be met if
(c)
| >is not met (or
| >| rather, if c has not been met for six months).
| >|
| >| > It does not state that (c) must also be met.
| >|
| >| Of course not. Why should (d) reaffirm (c)? Or reaffirm
| >any other FARs? The
| >| point is that nothing says that (c) *doesn't* still
have
| >to be met.
| >|
| >| In general, you're required to obey *every* regulation.
| >You can't decide
| >| that because you're complying with one, you can ignore
| >another one (unless
| >| the wording explicitly says that).
| >|
| >| > (d) is the controlling paragraph for one out of
| >currency, not (c).
| >|
| >| There's nothing in the FARs that says (c) doesn't apply
| >too.
| >|
| >| > (d) takes over and stands alone.
| >|
| >| But it doesn't say that anywhere in the FARs.
| >|
| >| > This is how it was explained to me.
| >|
| >| Did the explainers say how they arrived at their
| >interpretation that (d)
| >| sets forth a substitute requirement rather than an
| >additional requirement?
| >| If so, would you tell us their explanation?
| >|
| >| > If one can assume that 6 approches are also
| >| > needed, then the verbiage of (d) could also be
construed
| >to mean that
| >| > you must be 6 months out of currency in order to do
an
| >IPC.
| >|
| >| How would that follow? Where does (d) say that?
| >|
| >| > There are questions in the instrument knowledge test
| >question pool
| >| > whose correct answers support this. The faq's, that
by
| >letter of
| >| > memorandum were once stated as FAA policy, used to
| >support this.
| >| > Advisory Circular 61-98A, although out of date,
supports
| >this.
| >|
| >| It may well be that the FAA takes that position. All
I'm
| >saying is that if
| >| so, they're contradicting what the FARs clearly state.
| >|
| >| --Gary
| >|
| >|
| >
|

On Wed, 30 Aug 2006 23:29:53 -0500, "Jim Macklin"
> wrote:

>Years ago, before the USGPO decided that the pages were
>printed on solid gold, I subscribed to the FARs. It took 4
>4 inch ring binders for parts 61 and 91, there were at least
>a dozen pages of comments for each regulation...why it was
>needed, what it meant and what the NPRM comments had said
>and any revision made in response. Just reading a two or
>three sentence regulation is only a small part of the law.


Yup, the preamble usually tells more about the intent than the
finished product ever could. I have all of them via ATP IA software.

> Here is more from the FAA
> http://www.faa.gov/safety/programs_initiatives/oversight/iasa/model_aviation/media/PART08.doc
>
> Scroll to para 8.4.1.10

It says...

> 8.4.1.10 PILOT CURRENCY: IFR OPERATIONS
> (a) No person may act as PIC under IFR, nor in IMC, unless he or she has, within the past 6 calendar months—
> (1) Logged at least 6 hours of instrument flight time including at least 3 hours in flight in the category of aircraft; and
> (2) Completed at least 6 instrument approaches.
> (b) A pilot who has completed an instrument competency check with an authorised representative of the Authority retains currency for IFR operations for 6 calendar months following that check.

> 14 CFR: 61.57(c)

I note that it says "retains" and not "regains". If instrument currency
is lost prior to an ICC (now called IPC, no?), "retains" would not be
sufficient. "Regains" would be necessary.

I also note they refer to 61.57(c), and not (d), which involves the IPC.

> Years ago, before the USGPO decided that the pages were
> printed on solid gold, I subscribed to the FARs. It took 4
> 4 inch ring binders for parts 61 and 91, there were at least
> a dozen pages of comments for each regulation...why it was
> needed, what it meant and what the NPRM comments had said
> and any revision made in response. Just reading a two or
> three sentence regulation is only a small part of the law.

Alas, it's the part we're supposed to follow. Is this "full FAR" thing
available online?

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

Somewhere on-line, the FAA has them all, just haven't found
it yet. I think I need to go to the Library of Congress
ands the Congressional Record, that's where it is all
published. I'll find it and post a link before 2012.



"Bill Zaleski" > wrote in message
...
| On Wed, 30 Aug 2006 23:29:53 -0500, "Jim Macklin"
| > wrote:
|
| >Years ago, before the USGPO decided that the pages were
| >printed on solid gold, I subscribed to the FARs. It took
4
| >4 inch ring binders for parts 61 and 91, there were at
least
| >a dozen pages of comments for each regulation...why it
was
| >needed, what it meant and what the NPRM comments had said
| >and any revision made in response. Just reading a two or
| >three sentence regulation is only a small part of the
law.
|
|
| Yup, the preamble usually tells more about the intent than
the
| finished product ever could. I have all of them via ATP
IA software.

Follow what we say. An IPC [the name change did not change
the application, just the required content, the ICC could be
one approach]. Look in the Congressional Record or in the
FAA sites archives.
"Jose" > wrote in message
et...
|> Here is more from the FAA
| >
http://www.faa.gov/safety/programs_initiatives/oversight/iasa/model_aviation/media/PART08.doc
| >
| > Scroll to para 8.4.1.10
|
| It says...
|
| > 8.4.1.10 PILOT CURRENCY: IFR OPERATIONS
| > (a) No person may act as PIC under IFR, nor in IMC,
unless he or she has, within the past 6 calendar months—
| > (1) Logged at least 6 hours of instrument flight time
including at least 3 hours in flight in the category of
aircraft; and
| > (2) Completed at least 6 instrument approaches.
| > (b) A pilot who has completed an instrument competency
check with an authorised representative of the Authority
retains currency for IFR operations for 6 calendar months
following that check.
|
| > 14 CFR: 61.57(c)
|
| I note that it says "retains" and not "regains". If
instrument currency
| is lost prior to an ICC (now called IPC, no?), "retains"
would not be
| sufficient. "Regains" would be necessary.
|
| I also note they refer to 61.57(c), and not (d), which
involves the IPC.
|
| > Years ago, before the USGPO decided that the pages were
| > printed on solid gold, I subscribed to the FARs. It
took 4
| > 4 inch ring binders for parts 61 and 91, there were at
least
| > a dozen pages of comments for each regulation...why it
was
| > needed, what it meant and what the NPRM comments had
said
| > and any revision made in response. Just reading a two
or
| > three sentence regulation is only a small part of the
law.
|
| Alas, it's the part we're supposed to follow. Is this
"full FAR" thing
| available online?
|
| Jose
| --
| The monkey turns the crank and thinks he's making the
music.
| for Email, make the obvious change in the address.

"Jim Macklin" > wrote in message
news:m8vJg.6450$SZ3.2460@dukeread04...
>
> Somewhere on-line, the FAA has them all, just haven't found
> it yet. I think I need to go to the Library of Congress
> ands the Congressional Record, that's where it is all
> published. I'll find it and post a link before 2012.
>

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl

That link just leads back to the FAA website, it does not
include the annotated or NPRM discussion.



"Steven P. McNicoll" > wrote
in message
k.net...
|
| "Jim Macklin" > wrote
in message
| news:m8vJg.6450$SZ3.2460@dukeread04...
| >
| > Somewhere on-line, the FAA has them all, just haven't
found
| > it yet. I think I need to go to the Library of Congress
| > ands the Congressional Record, that's where it is all
| > published. I'll find it and post a link before 2012.
| >
|
|
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl
|
|

"Jim Macklin" > wrote in message
news:SQAJg.6465$SZ3.3563@dukeread04...
>
> That link just leads back to the FAA website, it does not
> include the annotated or NPRM discussion.
>

It's a link to the Code of Federal Regulations.

Yep, select chapter 14 and it goes to the FAA site
"Steven P. McNicoll" > wrote
in message
k.net...
|
| "Jim Macklin" > wrote
in message
| news:SQAJg.6465$SZ3.3563@dukeread04...
| >
| > That link just leads back to the FAA website, it does
not
| > include the annotated or NPRM discussion.
| >
|
| It's a link to the Code of Federal Regulations.
|
|

"Jim Macklin" > wrote in message
news:FlBJg.6466$SZ3.736@dukeread04...
>
> Yep, select chapter 14 and it goes to the FAA site
>

When I select "Title 14 - Aeronautics and Space" it just brings up the
various Parts of Title 14 on the GPO site.

"Jim Macklin" > wrote in message
news:OCoJg.6409$SZ3.3181@dukeread04...
> All that is required is for the pilot to record the name of
> the safety pilot, no endorsement is required, not even the
> certificate number.
>
> But after 12 months from the first day you were current [six
> months after currency lapsed] you must have an IPC.
> So, after 12 months, with no approaches in the mean time, an
> IPC makes you current.
>
> 61.57 says an IPC makes you current, it does not say an IPC
> and 6 approaches.
>
>
>
> "Allen" > wrote in message
> ...
> |
> | "Roy Smith" > wrote in message
> | >>> It works the other way too. Let's say you've only got
> 3 approaches
> | >>> logged in the last 6 months and come to me for an IPC.
> We fly 3 more
> | >>> approaches, I decide that you suck at instruments and
> decline to sign
> | >>> you off for an IPC.
> | >>>
> | >>> You're now legally current anyway, by virtue of having
> flown 6
> | >>> approaches.
> | >>
> | >>Not if the approaches were flown in VMC and you do not
> sign as safety
> | >>pilot.
> | >
> | > There's no such thing as "sign as safety pilot".
> |
> | Whether you write or he writes it your name will be in his
> logbook.

I know that Jim, it was a poor choice of words on my part. I was just
trying to point out that if the pilot who was declined the IPC logged the
three approaches to return to currency and then craters in the instructors
name will be in the logbook and will be sought out for questioning.

Allen

"Bill Zaleski" > wrote in message
...
> (c) Instrument experience: This is what you have to do to determine
> your current state of required instrument experience. This is all it
> addresses and nothing more. IF you decide that you are not current,
> you are done with this paragraph and it does not apply to you any
> longer (for the moment).

Of course it still applies. It applies by saying you can't be PIC under IFR
or IMC. And it keeps saying that as long as you haven't completed six
approaches within the past six months.

The whole crux of our disagreement is that you keep repeating that (c) stops
applying at some point, but you don't say *why* you think it stops applying.
That is, you don't cite any wording in the FARs saying that (c) stops
applying.

> (d) IPC: This is what you have to look at and do to GET current,

It's *one* of the things you have to do in order to be PIC under IFR or IMC.
Nothing says that all the *other* requirements don't still apply. For
instance, you'd still have to be medically qualified/certified, even though
(d) doesn't explicitly reaffirm that requirement. You agree with *that*,
don't you? So why don't you agree that the requirement in (c) also still
applies?

> It says "a person who does not meet (c)", can't be PIC
> until you do the stuff spelled out in (d),

Almost. It refers to a person who does not meet (c) *and* who has not done
so for six months. Let's say you're such a person. So now (d) says that if
you *don't* do the stuff in (d), you can't be PIC in IFR/IMC. But it never
says that if you *do* the stuff in (d), you can be PIC in IFR/IMC without
*also* meeting all *other* stated requirements (for example, the medical
requirement, or the six-in-six requirement). No requirement is waived unless
the wording *says* it's waived.

> Paragraph (d) is clearly relief from paragraph(c) via the IPC route
> alone. It in no way suggests that you have to do both.

Of course it doesn't say you have to do both, just like it doesn't say you
have to have a medical certificate. Those requirements are stated
*elsewhere*, and there's no need for (d) to repeat or reaffirm them. But
(d)--like any other regulatory paragraph--applies *in addition* to all the
other stated requirements, unless there's wording that specifically waives
those requirements. And there isn't.

(Again, I'm just addressing what the FARs actually say, which can be
different from how the FAA interprets or enforces them.)

--Gary

"Jim Macklin" > wrote in message
news:50tJg.6438$SZ3.1037@dukeread04...
> see
> http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_101_00.pdf#search=%22site%3Awww.faa.gov%20instru ment%20competency%20check%22
>
> Which say in part...
> (b) an IFR currency record, a copy of
> logbook endorsement for 14 CFR § 61.57 instrument
> competency check, or a record of instrument currency
> (6 hours and 6 approaches) obtained within the past
> 6 months.

Yup, and if the FARs said the same thing when listing currency requirements,
then the FAA's interpretation would be consistent with the FARS. But the
FARs *don't* say that, and the FAA's interpretation is *not* consistent with
the FARs. That's my only point here.

--Gary

On Thu, 31 Aug 2006 10:13:23 -0400, "Gary Drescher"
> wrote:

>"Bill Zaleski" > wrote in message
...
>> (c) Instrument experience: This is what you have to do to determine
>> your current state of required instrument experience. This is all it
>> addresses and nothing more. IF you decide that you are not current,
>> you are done with this paragraph and it does not apply to you any
>> longer (for the moment).
>
>Of course it still applies. It applies by saying you can't be PIC under IFR
>or IMC. And it keeps saying that as long as you haven't completed six
>approaches within the past six months.
>
>The whole crux of our disagreement is that you keep repeating that (c) stops
>applying at some point, but you don't say *why* you think it stops applying.
>That is, you don't cite any wording in the FARs saying that (c) stops
>applying.
>
>> (d) IPC: This is what you have to look at and do to GET current,
>
>It's *one* of the things you have to do in order to be PIC under IFR or IMC.
>Nothing says that all the *other* requirements don't still apply. For
>instance, you'd still have to be medically qualified/certified, even though
>(d) doesn't explicitly reaffirm that requirement. You agree with *that*,
>don't you? So why don't you agree that the requirement in (c) also still
>applies?
>
>> It says "a person who does not meet (c)", can't be PIC
>> until you do the stuff spelled out in (d),
>
>Almost. It refers to a person who does not meet (c) *and* who has not done
>so for six months. Let's say you're such a person. So now (d) says that if
>you *don't* do the stuff in (d), you can't be PIC in IFR/IMC. But it never
>says that if you *do* the stuff in (d), you can be PIC in IFR/IMC without
>*also* meeting all *other* stated requirements (for example, the medical
>requirement, or the six-in-six requirement). No requirement is waived unless
>the wording *says* it's waived.
>
>> Paragraph (d) is clearly relief from paragraph(c) via the IPC route
>> alone. It in no way suggests that you have to do both.
>
>Of course it doesn't say you have to do both, just like it doesn't say you
>have to have a medical certificate. Those requirements are stated
>*elsewhere*, and there's no need for (d) to repeat or reaffirm them. But
>(d)--like any other regulatory paragraph--applies *in addition* to all the
>other stated requirements, unless there's wording that specifically waives
>those requirements. And there isn't.
>
>(Again, I'm just addressing what the FARs actually say, which can be
>different from how the FAA interprets or enforces them.)
>
>--Gary

I have explained it to you exactly as it was explained to me by FAA
personel at the top of the regulatory chain. I understand it and
accept it. Do what you please.
>

Keep going, it goes to the FAA.



"Steven P. McNicoll" > wrote
in message
ink.net...
|
| "Jim Macklin" > wrote
in message
| news:FlBJg.6466$SZ3.736@dukeread04...
| >
| > Yep, select chapter 14 and it goes to the FAA site
| >
|
| When I select "Title 14 - Aeronautics and Space" it just
brings up the
| various Parts of Title 14 on the GPO site.
|
|

If the CFI doesn't endorse, the FAA has no action on the CFI
as long as the rules were followed. If a CFI endorses
without doing the IPC properly according to the PTS, then
the CFI is in violation. But if the CFI declines to
endorse and the time spent includes basic 61.57 6 and 6,
then that is the pilot's sole responsibility.



"Allen" > wrote in message
. net...
|
| "Jim Macklin" > wrote
in message
| news:OCoJg.6409$SZ3.3181@dukeread04...
| > All that is required is for the pilot to record the name
of
| > the safety pilot, no endorsement is required, not even
the
| > certificate number.
| >
| > But after 12 months from the first day you were current
[six
| > months after currency lapsed] you must have an IPC.
| > So, after 12 months, with no approaches in the mean
time, an
| > IPC makes you current.
| >
| > 61.57 says an IPC makes you current, it does not say an
IPC
| > and 6 approaches.
| >
| >
| >
| > "Allen" > wrote in message
| > ...
| > |
| > | "Roy Smith" > wrote in message
| > | >>> It works the other way too. Let's say you've only
got
| > 3 approaches
| > | >>> logged in the last 6 months and come to me for an
IPC.
| > We fly 3 more
| > | >>> approaches, I decide that you suck at instruments
and
| > decline to sign
| > | >>> you off for an IPC.
| > | >>>
| > | >>> You're now legally current anyway, by virtue of
having
| > flown 6
| > | >>> approaches.
| > | >>
| > | >>Not if the approaches were flown in VMC and you do
not
| > sign as safety
| > | >>pilot.
| > | >
| > | > There's no such thing as "sign as safety pilot".
| > |
| > | Whether you write or he writes it your name will be in
his
| > logbook.
|
| I know that Jim, it was a poor choice of words on my part.
I was just
| trying to point out that if the pilot who was declined the
IPC logged the
| three approaches to return to currency and then craters in
the instructors
| name will be in the logbook and will be sought out for
questioning.
|
| Allen
|
|

"Bill Zaleski" > wrote in message
...
> I have explained it to you exactly as it was explained to me by FAA
> personel at the top of the regulatory chain.

Sure, and I'm not disputing the accuracy of your report of what they said. I
just wanted to know if they ever explained how they get from what 61.57d
says (long-lapsed currency *not* reestablished *unless* IPC) to their
interpretation that an IPC *alone* suffices to reestablish long-lapsed
currency. Your report confirms that, as I expected, they asserted their
interpretation without ever justifying it.

--Gary

"Bill Zaleski" > wrote in message
...
> On Wed, 30 Aug 2006 19:08:11 -0500, Ben Jackson > wrote:
>
>>On 2006-08-30, Jim Macklin <> wrote:
>>> 61.57 says an IPC makes you current, it does not say an IPC
>>> and 6 approaches.
>>
>>You're wrong.
>
> Jim is right. I spent a week at the FAA examiner certification school
> at Oak City. All the teachers/FAA managers concurred that the initial
> instrument checkride, as well as an IPC alone, resets the clock to
> zero on instrument currency. FAR 61.57 (d) sets the requirements to
> act as PIC if (c) is not met. It does not state that (c) must also be
> met. (d) is the controlling paragraph for one out of currency, not
> (c). Paragraph (c) is the recency of experience requirements to
> operate IFR. Beyond 6 months, paragraph (d) now applies, as it
> contains the verbiage of what is required after the first 6 month
> period (6 more months to complete (c) OR IPC only beyond that).
> Paragraph (c) becomes a moot point after the time that you are allowed
> to comply with it passes. (d) takes over and stands alone. This is
> how it was explained to me. It was also brought up, (without need, I
> feel), that one can complete an IPC at any time, and not have to be
> out of currency to do so. If one can assume that 6 approches are also
> needed, then the verbiage of (d) could also be construed to mean that
> you must be 6 months out of currency in order to do an IPC. (Silly)
>
> There are questions in the instrument knowledge test question pool
> whose correct answers support this. The faq's, that by letter of
> memorandum were once stated as FAA policy, used to support this.
> Advisory Circular 61-98A, although out of date, supports this. Sure
> the FAR's are vague at times, but there have been plenty of references
> to policy that make the case. If you just understand that one
> paragraph is for maintaining currency, and the other to get back
> current, if you are not, the regulation's intent is clear.
>

I concur. My reference is thirty years dealing with the local GADO &
FSDO.

Al G

Turn it around...
example 61.57 a. No pilot may my fly under IFR or in
conditions less than basic VFR unless they have passed an
IPC.

b. Not withstanding a., if the pilot has flown 6 hours and 6
approaches within the previous 6 calendar months the IPC
need not be completed.

Gary, we have been doing this IFR thing for over 30 years
and we have taken many checkrides from the FAA for part 141
and 135 [and other parts] and this is a question that is
always covered.


The IPC replaces the 6 and 6. Every IPC starts the 6 month
clock again.



"Gary Drescher" > wrote in message
. ..
| "Bill Zaleski" > wrote in
message
| ...
| > (c) Instrument experience: This is what you have to do
to determine
| > your current state of required instrument experience.
This is all it
| > addresses and nothing more. IF you decide that you are
not current,
| > you are done with this paragraph and it does not apply
to you any
| > longer (for the moment).
|
| Of course it still applies. It applies by saying you can't
be PIC under IFR
| or IMC. And it keeps saying that as long as you haven't
completed six
| approaches within the past six months.
|
| The whole crux of our disagreement is that you keep
repeating that (c) stops
| applying at some point, but you don't say *why* you think
it stops applying.
| That is, you don't cite any wording in the FARs saying
that (c) stops
| applying.
|
| > (d) IPC: This is what you have to look at and do to GET
current,
|
| It's *one* of the things you have to do in order to be PIC
under IFR or IMC.
| Nothing says that all the *other* requirements don't still
apply. For
| instance, you'd still have to be medically
qualified/certified, even though
| (d) doesn't explicitly reaffirm that requirement. You
agree with *that*,
| don't you? So why don't you agree that the requirement in
(c) also still
| applies?
|
| > It says "a person who does not meet (c)", can't be PIC
| > until you do the stuff spelled out in (d),
|
| Almost. It refers to a person who does not meet (c) *and*
who has not done
| so for six months. Let's say you're such a person. So now
(d) says that if
| you *don't* do the stuff in (d), you can't be PIC in
IFR/IMC. But it never
| says that if you *do* the stuff in (d), you can be PIC in
IFR/IMC without
| *also* meeting all *other* stated requirements (for
example, the medical
| requirement, or the six-in-six requirement). No
requirement is waived unless
| the wording *says* it's waived.
|
| > Paragraph (d) is clearly relief from paragraph(c) via
the IPC route
| > alone. It in no way suggests that you have to do both.
|
| Of course it doesn't say you have to do both, just like it
doesn't say you
| have to have a medical certificate. Those requirements are
stated
| *elsewhere*, and there's no need for (d) to repeat or
reaffirm them. But
| (d)--like any other regulatory paragraph--applies *in
addition* to all the
| other stated requirements, unless there's wording that
specifically waives
| those requirements. And there isn't.
|
| (Again, I'm just addressing what the FARs actually say,
which can be
| different from how the FAA interprets or enforces them.)
|
| --Gary
|
|

Actually, the FAR does say that, you just don't know how to
read law.



"Gary Drescher" > wrote in message
. ..
| "Jim Macklin" > wrote
in message
| news:50tJg.6438$SZ3.1037@dukeread04...
| > see
| >
http://www.faa.gov/library/manuals/examiners_inspectors/8700/volume2/media/2_101_00.pdf#search=%22site%3Awww.faa.gov%20instru ment%20competency%20check%22
| >
| > Which say in part...
| > (b) an IFR currency record, a copy of
| > logbook endorsement for 14 CFR § 61.57 instrument
| > competency check, or a record of instrument currency
| > (6 hours and 6 approaches) obtained within the past
| > 6 months.
|
| Yup, and if the FARs said the same thing when listing
currency requirements,
| then the FAA's interpretation would be consistent with the
FARS. But the
| FARs *don't* say that, and the FAA's interpretation is
*not* consistent with
| the FARs. That's my only point here.
|
| --Gary
|
|

"Jim Macklin" > wrote in message
news:HvDJg.6479$SZ3.5382@dukeread04...
>
> Keep going, it goes to the FAA.
>

Nope. It never leaves the GPO site.

> I was just
> trying to point out that if the pilot who was declined the IPC logged the
> three approaches to return to currency and then craters in the instructors
> name will be in the logbook and will be sought out for questioning.

.... and he will say that he did not believe the pilot was up to snuff
for instrument flight, which is why (as documented in the logbook) he
was not signed off.

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

> http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl

This may be all the regulations, but what would be interseting is the
FAA regulations with all the commentary.

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

"Jim Macklin" > wrote in message
news:IvDJg.6480$SZ3.18@dukeread04...
> If the CFI doesn't endorse, the FAA has no action on the CFI
> as long as the rules were followed. If a CFI endorses
> without doing the IPC properly according to the PTS, then
> the CFI is in violation. But if the CFI declines to
> endorse and the time spent includes basic 61.57 6 and 6,
> then that is the pilot's sole responsibility.
>

That's the way I see it also, no violation, but, the CFI's name is still in
the pilot's logbook.

"Jim Macklin" > wrote in message
news:KvDJg.6482$SZ3.3506@dukeread04...
> Actually, the FAR does say that, you just don't know how to
> read law.

Jim, it's pointless for you to make statements like that while you refuse to
address any of the details of my argument (for instance, you still have not
addressed my analysis of 'not-P unless Q' as it applies to the current
question). Either debate or don't.

--Gary

"Jim Macklin" > wrote in message
news:JvDJg.6481$SZ3.2118@dukeread04...
> Turn it around...
> example 61.57 a. No pilot may my fly under IFR or in
> conditions less than basic VFR unless they have passed an
> IPC.
>
> b. Not withstanding a., if the pilot has flown 6 hours and 6
> approaches within the previous 6 calendar months the IPC
> need not be completed.

Yes, that would be totally different. In your hypothetical rewriting of the
FARs, the second clause explicitly states an *exception* to a requirement
("need not be completed"). But in the *actual* wording, the second clause
instead explicitly states a *requirement* ("may *not* serve *unless*").

That's been my point all along: you're trying to construe a *requirement* as
an *exception to other requirements*, but the wording doesn't express an
exception. Your hypothetical rewriting is actually a good illustration of
how an exception would be worded; that wording is precisely what's missing
from the actual FARs in question.

> Gary, we have been doing this IFR thing for over 30 years
> and we have taken many checkrides from the FAA for part 141
> and 135 [and other parts] and this is a question that is
> always covered.

As I have explained many, many times, that just tells us what the FAA's
position is. But I've never disputed what their position is. I just maintain
that their position does not match what the FARs say. Nothing about your 30
years of experience addresses *that* question. Rather, that question is
addressed by analyzing the wording of the FARs, as I have done here in
detail.

--Gary

Allen > wrote:
> I know that Jim, it was a poor choice of words on my part. I was just
> trying to point out that if the pilot who was declined the IPC logged the
> three approaches to return to currency and then craters in the instructors
> name will be in the logbook and will be sought out for questioning.

And what kind of questions will those be? I suppose I might be asked
to prove that I was properly qualified to act as safety pilot and to
instruct, but neither of those are hard to do.

If asked what we did on that flight, I would state that we had worked
towards completing an IPC but the pilot's performance was not up to
PTS standards. I would further state that I thus declined to endorse
his logbook for an IPC and advised the pilot that he should seek
additional instruction before flying IFR.

In article >,
Allen > wrote:
>
>"Jim Macklin" > wrote in message
>news:IvDJg.6480$SZ3.18@dukeread04...
>> If the CFI doesn't endorse, the FAA has no action on the CFI
>> as long as the rules were followed. If a CFI endorses
>> without doing the IPC properly according to the PTS, then
>> the CFI is in violation. But if the CFI declines to
>> endorse and the time spent includes basic 61.57 6 and 6,
>> then that is the pilot's sole responsibility.
>>
>
>That's the way I see it also, no violation, but, the CFI's name is still in
>the pilot's logbook.

If (after the flight) we go get some burgers and a couple of beers and
I pick up the tab, my name's going to be on the credit card receipt
too. So what?

> That's the way I see it also, no violation, but, the CFI's name is still in
> the pilot's logbook.

So?

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

Give that link again, I'll try it again.


"Steven P. McNicoll" > wrote
in message
k.net...
|
| "Jim Macklin" > wrote
in message
| news:HvDJg.6479$SZ3.5382@dukeread04...
| >
| > Keep going, it goes to the FAA.
| >
|
| Nope. It never leaves the GPO site.
|
|

Flight reviews and IPC are never signed off as failures,
they are just logged as dual.


"Jose" > wrote in message
. net...
|> I was just
| > trying to point out that if the pilot who was declined
the IPC logged the
| > three approaches to return to currency and then craters
in the instructors
| > name will be in the logbook and will be sought out for
questioning.
|
| ... and he will say that he did not believe the pilot was
up to snuff
| for instrument flight, which is why (as documented in the
logbook) he
| was not signed off.
|
| Jose
| --
| The monkey turns the crank and thinks he's making the
music.
| for Email, make the obvious change in the address.

But it was entered by the pilot, rather than being endorsed
by the CFI.



"Allen" > wrote in message
...
|
| "Jim Macklin" > wrote
in message
| news:IvDJg.6480$SZ3.18@dukeread04...
| > If the CFI doesn't endorse, the FAA has no action on the
CFI
| > as long as the rules were followed. If a CFI endorses
| > without doing the IPC properly according to the PTS,
then
| > the CFI is in violation. But if the CFI declines to
| > endorse and the time spent includes basic 61.57 6 and 6,
| > then that is the pilot's sole responsibility.
| >
|
| That's the way I see it also, no violation, but, the CFI's
name is still in
| the pilot's logbook.
|
|

Your argument is just wrong, so why debate it? Whether you
call Pluto a planet, a dwarf planet, or just a damn big ice
cube or a tiny ice cube, it still has the same gravitational
effect on the Earth.



"Gary Drescher" > wrote in message
. ..
| "Jim Macklin" > wrote
in message
| news:KvDJg.6482$SZ3.3506@dukeread04...
| > Actually, the FAR does say that, you just don't know how
to
| > read law.
|
| Jim, it's pointless for you to make statements like that
while you refuse to
| address any of the details of my argument (for instance,
you still have not
| addressed my analysis of 'not-P unless Q' as it applies to
the current
| question). Either debate or don't.
|
| --Gary
|
|

Then I suggest that you write the FAA and your congressman
to require that the FAA clarify, in the regulations, what
has been the regulation, policy and interpretation of FAR
61.57, so that you're pleased with the resulting text.
Understand that nothing will change, just an expenditure of
a few $100,000 for public hearings, and printing.


"Gary Drescher" > wrote in message
. ..
| "Jim Macklin" > wrote
in message
| news:JvDJg.6481$SZ3.2118@dukeread04...
| > Turn it around...
| > example 61.57 a. No pilot may my fly under IFR or in
| > conditions less than basic VFR unless they have passed
an
| > IPC.
| >
| > b. Not withstanding a., if the pilot has flown 6 hours
and 6
| > approaches within the previous 6 calendar months the IPC
| > need not be completed.
|
| Yes, that would be totally different. In your hypothetical
rewriting of the
| FARs, the second clause explicitly states an *exception*
to a requirement
| ("need not be completed"). But in the *actual* wording,
the second clause
| instead explicitly states a *requirement* ("may *not*
serve *unless*").
|
| That's been my point all along: you're trying to construe
a *requirement* as
| an *exception to other requirements*, but the wording
doesn't express an
| exception. Your hypothetical rewriting is actually a good
illustration of
| how an exception would be worded; that wording is
precisely what's missing
| from the actual FARs in question.
|
| > Gary, we have been doing this IFR thing for over 30
years
| > and we have taken many checkrides from the FAA for part
141
| > and 135 [and other parts] and this is a question that is
| > always covered.
|
| As I have explained many, many times, that just tells us
what the FAA's
| position is. But I've never disputed what their position
is. I just maintain
| that their position does not match what the FARs say.
Nothing about your 30
| years of experience addresses *that* question. Rather,
that question is
| addressed by analyzing the wording of the FARs, as I have
done here in
| detail.
|
| --Gary
|
|

On Thu, 31 Aug 2006 13:43:51 -0500, "Jim Macklin"
> wrote:

>Then I suggest that you write the FAA and your congressman
>to require that the FAA clarify, in the regulations, what
>has been the regulation, policy and interpretation of FAR
>61.57, so that you're pleased with the resulting text.
>Understand that nothing will change, just an expenditure of
>a few $100,000 for public hearings, and printing.
>

Jim: I am done now giving free ground school. How about you?
>
>"Gary Drescher" > wrote in message
. ..
>| "Jim Macklin" > wrote
>in message
>| news:JvDJg.6481$SZ3.2118@dukeread04...
>| > Turn it around...
>| > example 61.57 a. No pilot may my fly under IFR or in
>| > conditions less than basic VFR unless they have passed
>an
>| > IPC.
>| >
>| > b. Not withstanding a., if the pilot has flown 6 hours
>and 6
>| > approaches within the previous 6 calendar months the IPC
>| > need not be completed.
>|
>| Yes, that would be totally different. In your hypothetical
>rewriting of the
>| FARs, the second clause explicitly states an *exception*
>to a requirement
>| ("need not be completed"). But in the *actual* wording,
>the second clause
>| instead explicitly states a *requirement* ("may *not*
>serve *unless*").
>|
>| That's been my point all along: you're trying to construe
>a *requirement* as
>| an *exception to other requirements*, but the wording
>doesn't express an
>| exception. Your hypothetical rewriting is actually a good
>illustration of
>| how an exception would be worded; that wording is
>precisely what's missing
>| from the actual FARs in question.
>|
>| > Gary, we have been doing this IFR thing for over 30
>years
>| > and we have taken many checkrides from the FAA for part
>141
>| > and 135 [and other parts] and this is a question that is
>| > always covered.
>|
>| As I have explained many, many times, that just tells us
>what the FAA's
>| position is. But I've never disputed what their position
>is. I just maintain
>| that their position does not match what the FARs say.
>Nothing about your 30
>| years of experience addresses *that* question. Rather,
>that question is
>| addressed by analyzing the wording of the FARs, as I have
>done here in
>| detail.
>|
>| --Gary
>|
>|
>

> Then I suggest that you write the FAA and your congressman
> to require that the FAA clarify, in the regulations...

Be careful what you wish for.

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

"Jim Macklin" > wrote in message
news:L6GJg.6502$SZ3.992@dukeread04...
> Then I suggest that you write the FAA and your congressman
> to require that the FAA clarify, in the regulations, what
> has been the regulation, policy and interpretation of FAR
> 61.57, so that you're pleased with the resulting text.
> Understand that nothing will change, just an expenditure of
> a few $100,000 for public hearings, and printing.

Right, so why would I bother to make that request? Why do you suggest it?

--Gary

"Jim Macklin" > wrote in message
news:F6GJg.6501$SZ3.4496@dukeread04...
> Your argument is just wrong, so why debate it?

So you only debate against arguments you think are right?

If you were trying for self-parody here, you've certainly succeeded. :)

--Gary

"Jim Macklin" > wrote in message
news:B6GJg.6498$SZ3.2538@dukeread04...
>
> Give that link again, I'll try it again.
>

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl

Yes, you can lead a horse to water, but you can't make him
learn. Or, don't waste your time teaching a pig to sing, it
annoys the pig and wastes your time.




"Bill Zaleski" > wrote in message
...
| On Thu, 31 Aug 2006 13:43:51 -0500, "Jim Macklin"
| > wrote:
|
| >Then I suggest that you write the FAA and your
congressman
| >to require that the FAA clarify, in the regulations, what
| >has been the regulation, policy and interpretation of FAR
| >61.57, so that you're pleased with the resulting text.
| >Understand that nothing will change, just an expenditure
of
| >a few $100,000 for public hearings, and printing.
| >
|
| Jim: I am done now giving free ground school. How about
you?
| >
| >"Gary Drescher" > wrote in message
| . ..
| >| "Jim Macklin" >
wrote
| >in message
| >| news:JvDJg.6481$SZ3.2118@dukeread04...
| >| > Turn it around...
| >| > example 61.57 a. No pilot may my fly under IFR or in
| >| > conditions less than basic VFR unless they have
passed
| >an
| >| > IPC.
| >| >
| >| > b. Not withstanding a., if the pilot has flown 6
hours
| >and 6
| >| > approaches within the previous 6 calendar months the
IPC
| >| > need not be completed.
| >|
| >| Yes, that would be totally different. In your
hypothetical
| >rewriting of the
| >| FARs, the second clause explicitly states an
*exception*
| >to a requirement
| >| ("need not be completed"). But in the *actual* wording,
| >the second clause
| >| instead explicitly states a *requirement* ("may *not*
| >serve *unless*").
| >|
| >| That's been my point all along: you're trying to
construe
| >a *requirement* as
| >| an *exception to other requirements*, but the wording
| >doesn't express an
| >| exception. Your hypothetical rewriting is actually a
good
| >illustration of
| >| how an exception would be worded; that wording is
| >precisely what's missing
| >| from the actual FARs in question.
| >|
| >| > Gary, we have been doing this IFR thing for over 30
| >years
| >| > and we have taken many checkrides from the FAA for
part
| >141
| >| > and 135 [and other parts] and this is a question that
is
| >| > always covered.
| >|
| >| As I have explained many, many times, that just tells
us
| >what the FAA's
| >| position is. But I've never disputed what their
position
| >is. I just maintain
| >| that their position does not match what the FARs say.
| >Nothing about your 30
| >| years of experience addresses *that* question. Rather,
| >that question is
| >| addressed by analyzing the wording of the FARs, as I
have
| >done here in
| >| detail.
| >|
| >| --Gary
| >|
| >|
| >
|

Since you seem to think that the regulations need to be
re-written.


"Gary Drescher" > wrote in message
. ..
| "Jim Macklin" > wrote
in message
| news:L6GJg.6502$SZ3.992@dukeread04...
| > Then I suggest that you write the FAA and your
congressman
| > to require that the FAA clarify, in the regulations,
what
| > has been the regulation, policy and interpretation of
FAR
| > 61.57, so that you're pleased with the resulting text.
| > Understand that nothing will change, just an expenditure
of
| > a few $100,000 for public hearings, and printing.
|
| Right, so why would I bother to make that request? Why do
you suggest it?
|
| --Gary
|
|

Yes, but it is just the same as the FAA page, same content.
Still looking for all the comment and explanation pages.



"Steven P. McNicoll" > wrote
in message
nk.net...
|
| "Jim Macklin" > wrote
in message
| news:B6GJg.6498$SZ3.2538@dukeread04...
| >
| > Give that link again, I'll try it again.
| >
|
|
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl
|
|

"Jim Macklin" > wrote in message
news:lKIJg.6515$SZ3.5920@dukeread04...
> Since you seem to think that the regulations need to be
> re-written.

No, I never said that. If anything, I think it would make slightly more
sense for the FAA to keep the existing wording and adhere to it. But I don't
think it matters much either way.

--Gary


> "Gary Drescher" > wrote in message
> . ..
> | "Jim Macklin" > wrote
> in message
> | news:L6GJg.6502$SZ3.992@dukeread04...
> | > Then I suggest that you write the FAA and your
> congressman
> | > to require that the FAA clarify, in the regulations,
> what
> | > has been the regulation, policy and interpretation of
> FAR
> | > 61.57, so that you're pleased with the resulting text.
> | > Understand that nothing will change, just an expenditure
> of
> | > a few $100,000 for public hearings, and printing.
> |
> | Right, so why would I bother to make that request? Why do
> you suggest it?
> |
> | --Gary
> |
> |
>
>

They do follow their rules on 61.57. The only change has
been to tighten up on the content of an IPC [and the name
change].


"Gary Drescher" > wrote in message
. ..
| "Jim Macklin" > wrote
in message
| news:lKIJg.6515$SZ3.5920@dukeread04...
| > Since you seem to think that the regulations need to be
| > re-written.
|
| No, I never said that. If anything, I think it would make
slightly more
| sense for the FAA to keep the existing wording and adhere
to it. But I don't
| think it matters much either way.
|
| --Gary
|
|
| > "Gary Drescher" > wrote in
message
| > . ..
| > | "Jim Macklin" >
wrote
| > in message
| > | news:L6GJg.6502$SZ3.992@dukeread04...
| > | > Then I suggest that you write the FAA and your
| > congressman
| > | > to require that the FAA clarify, in the regulations,
| > what
| > | > has been the regulation, policy and interpretation
of
| > FAR
| > | > 61.57, so that you're pleased with the resulting
text.
| > | > Understand that nothing will change, just an
expenditure
| > of
| > | > a few $100,000 for public hearings, and printing.
| > |
| > | Right, so why would I bother to make that request? Why
do
| > you suggest it?
| > |
| > | --Gary
| > |
| > |
| >
| >
|
|

"Jim Macklin" > wrote in message
news:p7JJg.6518$SZ3.3885@dukeread04...
> They do follow their rules on 61.57.

Yes Jim, I get that you think so. But here's a constructive suggestion, in
the event that you'd like to make progress on this question. You've
mentioned you have friends who are lawyers. Why not show some of them my
message of 8/25 12:47PM (the one with the "not-P unless Q" analysis that you
refuse to address, even though it's the crux of the whole disagreement). If
they agree with me, perhaps they can explain the argument to you.
Alternatively, if they disagree with me, perhaps they could say why and you
could post their analysis here.

--Gary

Why address a premise that is wrong. Why bother lawyers, it
is your argument, you disagree with the answer you've been
given. It is up to you to resolve the issue. You contact
the FAA Regional office and ask for a legal opinion. They
have staff that will do that for you.


"Gary Drescher" > wrote in message
...
| "Jim Macklin" > wrote
in message
| news:p7JJg.6518$SZ3.3885@dukeread04...
| > They do follow their rules on 61.57.
|
| Yes Jim, I get that you think so. But here's a
constructive suggestion, in
| the event that you'd like to make progress on this
question. You've
| mentioned you have friends who are lawyers. Why not show
some of them my
| message of 8/25 12:47PM (the one with the "not-P unless Q"
analysis that you
| refuse to address, even though it's the crux of the whole
disagreement). If
| they agree with me, perhaps they can explain the argument
to you.
| Alternatively, if they disagree with me, perhaps they
could say why and you
| could post their analysis here.
|
| --Gary
|
|

Gary, I have just been lurking this thread. As it winds down (we hope), I
will just comment that you are absolutely correct, regarding what the
words of the regulation actually say, independent of how they may be applied
or interpreted or intended by the FAA. I have beat this horse a bit from
time to time myself.

Stan


"Gary Drescher" > wrote in message
...
> "Jim Macklin" > wrote in message
> news:p7JJg.6518$SZ3.3885@dukeread04...
>> They do follow their rules on 61.57.
>
> Yes Jim, I get that you think so. But here's a constructive suggestion, in
> the event that you'd like to make progress on this question. You've
> mentioned you have friends who are lawyers. Why not show some of them my
> message of 8/25 12:47PM (the one with the "not-P unless Q" analysis that
> you refuse to address, even though it's the crux of the whole
> disagreement). If they agree with me, perhaps they can explain the
> argument to you. Alternatively, if they disagree with me, perhaps they
> could say why and you could post their analysis here.
>
> --Gary
>
>