Here is more from the FAA
http://www.faa.gov/safety/programs_i...dia/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/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.
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|
| "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|| Advisory Circular 61-98A, although out of date,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
||
||
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|