Is an IPC a substitute for 6 approaches?

"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/e...ncy%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/e...ncy%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.