Is an IPC a substitute for 6 approaches?

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.











"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| Advisory Circular 61-98A, although out of date, supports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
|
|

On Wed, 30 Aug 2006 22:50:07 -0500, "Jim Macklin"
wrote:

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.


Good job, Jim. An FAA order is law for inspectors. Granted the order
is outdated, but the intent is clear.










"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
|
|

Years ago, before the USGPO decided that the pages were
printed on solid gold, I subscribed to the FARs. It took 4
4 inch ring binders for parts 61 and 91, there were at least
a dozen pages of comments for each regulation...why it was
needed, what it meant and what the NPRM comments had said
and any revision made in response. Just reading a two or
three sentence regulation is only a small part of the law.



--
James H. Macklin
ATP,CFI,A&P

"Bill Zaleski" wrote in message
...
| On Wed, 30 Aug 2006 22:50:07 -0500, "Jim Macklin"
| wrote:
|
| 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.
|
|
| Good job, Jim. An FAA order is law for inspectors.
Granted the order
| is outdated, but the intent is clear.
|
|
|
|
|
|
|
|
|
|
| "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
| |
| |
|
|

On Wed, 30 Aug 2006 23:29:53 -0500, "Jim Macklin"
wrote:

Years ago, before the USGPO decided that the pages were
printed on solid gold, I subscribed to the FARs. It took 4
4 inch ring binders for parts 61 and 91, there were at least
a dozen pages of comments for each regulation...why it was
needed, what it meant and what the NPRM comments had said
and any revision made in response. Just reading a two or
three sentence regulation is only a small part of the law.


Yup, the preamble usually tells more about the intent than the
finished product ever could. I have all of them via ATP IA software.

Somewhere on-line, the FAA has them all, just haven't found
it yet. I think I need to go to the Library of Congress
ands the Congressional Record, that's where it is all
published. I'll find it and post a link before 2012.



"Bill Zaleski" wrote in message
...
| On Wed, 30 Aug 2006 23:29:53 -0500, "Jim Macklin"
| wrote:
|
| Years ago, before the USGPO decided that the pages were
| printed on solid gold, I subscribed to the FARs. It took
4
| 4 inch ring binders for parts 61 and 91, there were at
least
| a dozen pages of comments for each regulation...why it
was
| needed, what it meant and what the NPRM comments had said
| and any revision made in response. Just reading a two or
| three sentence regulation is only a small part of the
law.
|
|
| Yup, the preamble usually tells more about the intent than
the
| finished product ever could. I have all of them via ATP
IA software.

"Jim Macklin" wrote in message
news:m8vJg.6450$SZ3.2460@dukeread04...

Somewhere on-line, the FAA has them all, just haven't found
it yet. I think I need to go to the Library of Congress
ands the Congressional Record, that's where it is all
published. I'll find it and post a link before 2012.


http://ecfr.gpoaccess.gov/cgi/t/text...l=%2Findex.tpl

That link just leads back to the FAA website, it does not
include the annotated or NPRM discussion.



"Steven P. McNicoll" wrote
in message
k.net...
|
| "Jim Macklin" wrote
in message
| news:m8vJg.6450$SZ3.2460@dukeread04...
|
| Somewhere on-line, the FAA has them all, just haven't
found
| it yet. I think I need to go to the Library of Congress
| ands the Congressional Record, that's where it is all
| published. I'll find it and post a link before 2012.
|
|
|
http://ecfr.gpoaccess.gov/cgi/t/text...l=%2Findex.tpl
|
|

http://ecfr.gpoaccess.gov/cgi/t/text...l=%2Findex.tpl

This may be all the regulations, but what would be interseting is the
FAA regulations with all the commentary.

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.

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.
|
|
|
|
|
|
|
|
|
|
|
| "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
||
||
|
|

Here is more from the FAA
http://www.faa.gov/safety/programs_i...dia/PART08.doc

Scroll to para 8.4.1.10

It says...

8.4.1.10 PILOT CURRENCY: IFR OPERATIONS
(a) No person may act as PIC under IFR, nor in IMC, unless he or she has, within the past 6 calendar months—
(1) Logged at least 6 hours of instrument flight time including at least 3 hours in flight in the category of aircraft; and
(2) Completed at least 6 instrument approaches.
(b) A pilot who has completed an instrument competency check with an authorised representative of the Authority retains currency for IFR operations for 6 calendar months following that check.

14 CFR: 61.57(c)

I note that it says "retains" and not "regains". If instrument currency
is lost prior to an ICC (now called IPC, no?), "retains" would not be
sufficient. "Regains" would be necessary.

I also note they refer to 61.57(c), and not (d), which involves the IPC.

Years ago, before the USGPO decided that the pages were
printed on solid gold, I subscribed to the FARs. It took 4
4 inch ring binders for parts 61 and 91, there were at least
a dozen pages of comments for each regulation...why it was
needed, what it meant and what the NPRM comments had said
and any revision made in response. Just reading a two or
three sentence regulation is only a small part of the law.

Alas, it's the part we're supposed to follow. Is this "full FAR" thing
available online?

Jose
--
The monkey turns the crank and thinks he's making the music.
for Email, make the obvious change in the address.