"Ben Jackson" wrote in message
...
The way I read 61.57(d) (the requirement for an IPC), it's just an extra
requirement that kicks in under certain circumstances. It's not a subpart
of 61.57(c) (6 approaches etc in 6 months), and (c) does not have any
exceptions related to (d).

So if an IPC is essentially a checkride, it could be done by a proficient
pilot with (say) 3 approaches. Would that pilot be legal for IFR if he
had gone into the IPC needing it (no approaches within 6 months)?

Not as the regulation is written. As you note, 61.57d sets forth an
additional requirement, not a substitution for or exception to the
requirements of 61.57c. So an IPC might indeed include only three
approaches, but that wouldn't qualify the pilot to fly IFR unless the pilot
has flown three other approaches within the past six months.

--Gary