Tom L. wrote:

ACs are advisory. I'm sure the courts would use them to clarify FARs
if needed, but in this case FARs are clear enough:
61.56(e) wants "FAA sponsored pilot proficiency program". FAA's web
site says "this is a pilot proficiency program". Good enough for me.

In fact there are two issues:

(1) Whether the new program does indeed qualify to fulfill the requirements
of 61.56(e); and I would tend to agree with you that it does, even though
it does not follow the description of the still current AC 91-61H; it is
indeed probably still good enough to satisfy a ramp check, but I wouldn't
like to test that in a more serious situation... (would it be good enough
in a court of law?)

(2) The other issue, my current problem, is whether or not having
completed a Wings phase with the old system qualifies as well; and
apparently, according to both the FSDO dude and the AOPA, it does not...
i.e., someone who, in good faith, did everything right, may still get
screwed royally.

There are two possibilities he someone who has completed said Wing phase
before the unofficial -- because it is not written anywhere in any official
publication from the FAA, unless someone can prove me wrong -- sunset date
of December 2007, and someone who did the same after that date (which
would be reasonable enough, since AC 61-91H has not been superseded);

There might still be quite a few people in the former situation (a wing
phase 'bought' you 24 months of happy legal flying); and I know that there
are quite a few folks out there in the latter situation. People, pilots
and instructors alike, who keep themselves up to date regulation wise, but
might not be aware of the latest (unofficial) goodies put online by our
dear administration... it could be argued that if it is not available in
print from your local FSDO, that it does not exist.

ok, no flying for me today; BFR scheduled tomorrow.

--Sylvain