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
|
|