Is an IPC a substitute for 6 approaches?

On 2006-08-25, Jim Macklin wrote:

A IPC is valid for 6 months. You need to read legal documents using =
formal rules. The IPC rule says that a pilot who does not meet the 6-6 =
rule may take an IPC, the IPC becomes mandatory 12 months after the date =
currency was established.

Right, and it doesn't say anything about the previous rule, which
independently states that you have to have 6-in-6.

There are clearly many examples were the 6-6 rule is inadequate

Sure, the rules don't equal safety. I was just asking about the rules.

If you don't "see" the meaning of the words, suggest you find a =
qualified high school English teacher or a lawyer and have them show =
you. You carefully snipped the quoted regulation so it couldn't be seen =
by anyone else.

No need to be a jerk. I snipped the quoted regulation because you only
quoted part (d) which is not the whole story. Your comment (snipping
again):

The check is available at any time and fully meets the
requirements of legal currency...

is not supported by the regulation. You then paraphrase it in support:

a person who does not meet the instrument experience
requirements of paragraph (c) until that person passes an
instrument proficiency check

If it *said* that, then I'd agree. *Your* phrasing says you meet (c) if
you pass an IPC. But the reg says that a person who does not meet (c) in
time, or within 6 months, may not serve as PIC under IFR until ... an IPC.
So what passing an IPC does is remove the restriction in (d) about not
serving as PIC under IFR. Independently, section (c) has rules about
recency of experience for IFR. Just like section (b) has rules about
night takeoffs and landings. Just passing the IPC to lift one "may
not serve as PIC" restriction does not lift them all.

--
Ben Jackson AD7GD

http://www.ben.com/

Now another question: Can the IPC be used as part of a Wings phase?

One of the parts of a wings phase is one hour of instrument instruction.
If the IPC takes an hour or more, then it counts.

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

My wife is an English Master and an English teacher at the
college level and I've been answering questions to the Feds
about what their regulations mean for many years. I have
taken so many annual and 6 month checks under FAR 141 and
135 that I've lost count. I have a number of friends who
are lawyers.

We have told you the answer, you may contact the FAA
Regional office and get a letter from their legal staff.


"Gary Drescher" wrote in message
...
| "Jim Macklin" wrote
in message
| news:hqBHg.5978$SZ3.5107@dukeread04...
| A IPC is valid for 6 months. You need to read legal
documents using formal
| rules.
|
| Nothing in the FARs says anything about a validity period
(6 months or
| otherwise) for an IPC. There is a 6-month validity period
for the 6
| approaches (and holds and tracking).
|
| The IPC rule says that a pilot who does not meet the 6-6
rule may take an
| IPC,
|
| Yes.
|
| the IPC becomes mandatory 12 months after the date
currency was
| established.
|
| That's a confusing way to put it, since currency may have
been established
| years ago, and maintained ever since. The IPC becomes
mandatory six months
| after currency has expired.
|
| But that's not the question at issue. We all agree when
the IPC is required.
| We all agree that an IPC might include only 3 approaches.
The question is
| whether, *in addition* to the IPC (when the IPC is
required), you have to
| satisfy the 6-in-6 requirement of 61.57c in order to be
instrument current.
| My point is that nothing in 61.57c (or in 61.57d) asserts
that the 6-in-6
| requirement is waived by the completion of an IPC. As the
regs are written
| (though perhaps not as they're interpreted in practice),
the 6-in-6
| requirement has to be met even if you've just had an IPC.
|
| You carefully snipped the quoted regulation so it
couldn't be seen by
| anyone else.
|
| Uh, sure Jim. No one here is familiar with 61.57d, or
knows how to find it
| unless we keep repeating it in each of our posts.
|
| The check is available at any time
|
| Yes.
|
| and fully meets the requirements of legal currency...
|
| No. That's exactly what the regs *don't* say. If you
disagree, please
| explain what part of 61.57c or 61.57d (or any other FAR)
supports your claim
| that an IPC by itself suffices to reestablish currency.
|
| What 61.57d says is that if your instrument currency
expired six months ago,
| then you're *not* instrument-current again *unless* you
pass an IPC. Nowhere
| does it say that you *are* current if you *do* pass an IPC
but *do not* meet
| the *other* instrument-currency requirements (such as the
6-in-6 rule in
| 61.57c).
|
| You need to read legal documents using formal rules.
| If you don't "see" the meaning of the words, suggest you
find a
| qualified high school English teacher
|
| Good advice. Please heed it yourself. In the meantime, the
relevant formal
| principle is that "not-P unless Q" is equivalent to "not-Q
implies not-P",
| but is *not* equivalent to "Q implies P". But the latter
is how you're
| (incorrectly) interpreting it. (Here, P is
"instrument-current again after
| currency lapsed for at least six months" and Q is "passed
an IPC".)
|
| --Gary
|
|

You're wrong.


"Ben Jackson" wrote in message
...
| On 2006-08-25, Jim Macklin wrote:
|
| A IPC is valid for 6 months. You need to read legal
documents using =
| formal rules. The IPC rule says that a pilot who does
not meet the 6-6 =
| rule may take an IPC, the IPC becomes mandatory 12
months after the date =
| currency was established.
|
| Right, and it doesn't say anything about the previous
rule, which
| independently states that you have to have 6-in-6.
|
| There are clearly many examples were the 6-6 rule is
inadequate
|
| Sure, the rules don't equal safety. I was just asking
about the rules.
|
| If you don't "see" the meaning of the words, suggest you
find a =
| qualified high school English teacher or a lawyer and
have them show =
| you. You carefully snipped the quoted regulation so it
couldn't be seen =
| by anyone else.
|
| No need to be a jerk. I snipped the quoted regulation
because you only
| quoted part (d) which is not the whole story. Your
comment (snipping
| again):
|
| The check is available at any time and fully meets the
| requirements of legal currency...
|
| is not supported by the regulation. You then paraphrase
it in support:
|
| a person who does not meet the instrument experience
| requirements of paragraph (c) until that person passes
an
| instrument proficiency check
|
| If it *said* that, then I'd agree. *Your* phrasing says
you meet (c) if
| you pass an IPC. But the reg says that a person who does
not meet (c) in
| time, or within 6 months, may not serve as PIC under IFR
until ... an IPC.
| So what passing an IPC does is remove the restriction in
(d) about not
| serving as PIC under IFR. Independently, section (c) has
rules about
| recency of experience for IFR. Just like section (b) has
rules about
| night takeoffs and landings. Just passing the IPC to lift
one "may
| not serve as PIC" restriction does not lift them all.
|
| --
| Ben Jackson AD7GD
|
| http://www.ben.com/

"Jim Macklin" wrote in message
news:hbHHg.5999$SZ3.1815@dukeread04...
My wife is an English Master and an English teacher at the
college level and I've been answering questions to the Feds
about what their regulations mean for many years. I have
taken so many annual and 6 month checks under FAR 141 and
135 that I've lost count. I have a number of friends who
are lawyers.

Instead of appealing to authority, you would do well to try to address the
arguments that Ben and I have presented. In particular, if you (or your wife
or your friends) disagree somehow with my analysis of "not-P unless Q", it
would be helpful to see what your reasoning is.

But you have steadfastly refused to say *anything at all* about the
reasoning by which you get from the wording of the regs to your conclusion
about the sufficiency of an IPC even if the 6-in-6 requirement is not met.
Instead, you repeatedly just quote the regs and then assert your
interpretation, with zero explanation of how you get from the former to the
latter. (And when Ben and I carefully explain how we get to *our*
interpretation, you just reply with "You're wrong".)

We have told you the answer, you may contact the FAA
Regional office and get a letter from their legal staff.

That might tell me how the FAA interprets the regs in practice, but I've
said repeatedly that I'm not making any claims about that question (nor is
Ben). I'm just addressing the separate question of what the regs actually
say.

--Gary

"Gary Drescher" wrote in message
...
| "Jim Macklin" wrote
in message
| news:hqBHg.5978$SZ3.5107@dukeread04...
| A IPC is valid for 6 months. You need to read legal
documents using formal
| rules.
|
| Nothing in the FARs says anything about a validity period
(6 months or
| otherwise) for an IPC. There is a 6-month validity period
for the 6
| approaches (and holds and tracking).
|
| The IPC rule says that a pilot who does not meet the 6-6
rule may take an
| IPC,
|
| Yes.
|
| the IPC becomes mandatory 12 months after the date
currency was
| established.
|
| That's a confusing way to put it, since currency may have
been established
| years ago, and maintained ever since. The IPC becomes
mandatory six months
| after currency has expired.
|
| But that's not the question at issue. We all agree when
the IPC is required.
| We all agree that an IPC might include only 3 approaches.
The question is
| whether, *in addition* to the IPC (when the IPC is
required), you have to
| satisfy the 6-in-6 requirement of 61.57c in order to be
instrument current.
| My point is that nothing in 61.57c (or in 61.57d) asserts
that the 6-in-6
| requirement is waived by the completion of an IPC. As the
regs are written
| (though perhaps not as they're interpreted in practice),
the 6-in-6
| requirement has to be met even if you've just had an IPC.
|
| You carefully snipped the quoted regulation so it
couldn't be seen by
| anyone else.
|
| Uh, sure Jim. No one here is familiar with 61.57d, or
knows how to find it
| unless we keep repeating it in each of our posts.
|
| The check is available at any time
|
| Yes.
|
| and fully meets the requirements of legal currency...
|
| No. That's exactly what the regs *don't* say. If you
disagree, please
| explain what part of 61.57c or 61.57d (or any other FAR)
supports your claim
| that an IPC by itself suffices to reestablish currency.
|
| What 61.57d says is that if your instrument currency
expired six months ago,
| then you're *not* instrument-current again *unless* you
pass an IPC. Nowhere
| does it say that you *are* current if you *do* pass an IPC
but *do not* meet
| the *other* instrument-currency requirements (such as the
6-in-6 rule in
| 61.57c).
|
| You need to read legal documents using formal rules.
| If you don't "see" the meaning of the words, suggest you
find a
| qualified high school English teacher
|
| Good advice. Please heed it yourself. In the meantime, the
relevant formal
| principle is that "not-P unless Q" is equivalent to "not-Q
implies not-P",
| but is *not* equivalent to "Q implies P". But the latter
is how you're
| (incorrectly) interpreting it. (Here, P is
"instrument-current again after
| currency lapsed for at least six months" and Q is "passed
an IPC".)
|
| --Gary
|
|

John Godwin wrote:
"Robert M. Gary" wrote in
ups.com:

For Land Wings it would certainly count as the 1 hour required for
instrument training. It wouldn't do you any good for Sea Wings.

AC61-91H(7)(b) shows a one hour requirement of instrument instruction
under certain circumstances, see "Note".

Hi John. My reading of that is just that a non-instrument rated pilot
does not need to shoot approaches, but still needs to do 1 hour of
"basic instrument training" (their words).
However, for SeaWings there is no instrument requirement at all (I just
did my Seawings yesterday)...


b. Seaplanes and Amphibians.
(1) One hour of flight training in a seaplane or amphibian
to include a demonstration by the applicant of a complete
seaplane or amphibian passenger safety briefing, a weight
and balance computation and interpretation for the actual
flight, a review and evaluation of current and forecast
weather, and on-the-water training in docking, beaching
and anchoring, and maneuvering in confined areas.
(2) One hour of flight training in a seaplane or amphibian
to include landing area assessment, safe approaches and
departures, takeoffs, and landings, including crosswind,
rough water, and glassy water techniques. (Conditions
may be simulated.)
(3) One hour of flight training in a seaplane or amphibian
to include power-on and power-offstalls in various configurations with
minimum altitude loss,
power-off emergency landings, step taxi, step turns, rapid
decelerations from the step, and emergency procedures.
In addition to the 1 hour of flight time (not included in the 1
hour), there must be a discussion of stall avoidance and
prevention techniques,

-Robert

"Robert M. Gary" wrote in
ps.com:

Hi John. My reading of that is just that a non-instrument rated
pilot does not need to shoot approaches, but still needs to do 1
hour of "basic instrument training" (their words).
However, for SeaWings there is no instrument requirement at all (I
just did my Seawings yesterday)...

NOTE: If the applicant is not qualified
and current in accordance with 61.57 for
instrument flight, 1 additional hour of
basic instrument training with emphasis
on partial panel approaches, inadvertent
penetration into instrument
meteorological conditions (180 turn),
descent into visual meteorological
conditions, and safe operations shall he
accomplished in an airplane, seaplane,
FAAapproved aircraft simulator, or
training device for each odd-numbered
award phase (Phase 1, III, V, etc.).

--

John Godwin wrote:
"Robert M. Gary" wrote in
ps.com:

Hi John. My reading of that is just that a non-instrument rated
pilot does not need to shoot approaches, but still needs to do 1
hour of "basic instrument training" (their words).
However, for SeaWings there is no instrument requirement at all (I
just did my Seawings yesterday)...

NOTE: If the applicant is not qualified
and current in accordance with 61.57 for
instrument flight, 1 additional hour of
basic instrument training with emphasis
on partial panel approaches, inadvertent
penetration into instrument
meteorological conditions (180 turn),
descent into visual meteorological
conditions, and safe operations shall he
accomplished in an airplane, seaplane,
FAAapproved aircraft simulator, or
training device for each odd-numbered
award phase (Phase 1, III, V, etc.).

Yes, but none of that applies to Seawings because there is no
instrument requirement whatsoever for Seawings.

-Robert

Going back and re-reading that, you're right. I'll bet most seaplane
operations are not aware of that. It appears that if a pilot is not
instrument current, and is doing an odd phase of sea wings (1,3,5,7,..)
he must do an additional hour of instrument training. That becomes very
hard since many seaplane operators remove all gyros from their
airplanes because they get beat to crap by the impact of water
landings. It also messes up their "fix price" wings offering.

-Robert

John Godwin wrote:
"Robert M. Gary" wrote in
ps.com:
NOTE: If the applicant is not qualified
and current in accordance with 61.57 for
instrument flight, 1 additional hour of
basic instrument training with emphasis
on partial panel approaches, inadvertent
penetration into instrument
meteorological conditions (180 turn),
descent into visual meteorological
conditions, and safe operations shall he
accomplished in an airplane, seaplane,
FAAapproved aircraft simulator, or
training device for each odd-numbered
award phase (Phase 1, III, V, etc.).

--

Interesting. That an IPC would make a pilot current for IFR for 6
months, regardless of the number of approaches done, is something that
I've always just thought I've "known". But looking at the regs, to my
surprise, they just don't seem to say that.

So where did the notion come from? Well, I think I know where it got
stuck in my head, at least, namely from an FAA IR knowledge test bank
question, which goes a little something like this:

4021 A20
How long does a pilot meet the recency of experience requirements
for IFR flight
after successfully completing an instrument proficiency check if no
further
IFR flights are made?
A. 90 days.
B. 6 calendar months.
C. 12 calendat months.

I think the "intent" is that the IPC resets the clock, regardless of
number of approaches. It would be "nice", though, if the rules actually
stated what many of us are assuming they mean.
-harry