Is an IPC a substitute for 6 approaches?

On Thu, 31 Aug 2006 10:13:23 -0400, "Gary Drescher"
wrote:

"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

I have explained it to you exactly as it was explained to me by FAA
personel at the top of the regulatory chain. I understand it and
accept it. Do what you please.

"Bill Zaleski" wrote in message
...
I have explained it to you exactly as it was explained to me by FAA
personel at the top of the regulatory chain.

Sure, and I'm not disputing the accuracy of your report of what they said. I
just wanted to know if they ever explained how they get from what 61.57d
says (long-lapsed currency *not* reestablished *unless* IPC) to their
interpretation that an IPC *alone* suffices to reestablish long-lapsed
currency. Your report confirms that, as I expected, they asserted their
interpretation without ever justifying it.

--Gary