"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Advisory Circular 61-98A, although out of date, supports this.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