"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