Holds for currency

[poadeleted20]

The approach I fly regularly has a Hold-in-loo. I don't really have to worry about that one.

Just make sure you log that you did that HPILPT, not just logging the approach which contains it.

 

[poadeleted20]

It was funny, on my IR check ride I was given an intersection hold with a single Kx 170b, I found the intersection, turned and the DE says, "That's good enough, if you found the intersection and turned the right way, I'm sure you can fly the hold."

Don't count on this happening on anyone else's IR practical test. FWIW, I was given a single-VOR partial panel hold at an intersection on my IR practical test, and we did enough turns to show I could do the wind corrections (both drift and timing) before moving on to a partial-panel VOR approach.

 

[poadeleted20]

And I don't think that the hold-in-loo maneuver qualifies as "holding procedures".
It is a type of procedure turn for an approach. The turn only needs to be on the depicted side, and must not EXCEED one minute.
You are not issued holding instructions with an EFC, the initial outbound MUST be one minute, and you are not maneuvering for a final approach to landing. You are trying to establish a one minute holding pattern.
Counting a hold-in-leu type procedure turn as a holding pattern is like counting a radar approach as one of the required approaches.

You mean it's legal, but you don't think it should be?

 

[Gucci Pilot]

And I don't think that the hold-in-loo maneuver qualifies as "holding procedures".

HOLDING-in-lieu(instead)-of-procedure-turn

It is a hold...through and through

It is a type of procedure turn for an approach.

Its a hold instead of a procedure turn

The turn only needs to be on the depicted side

Pretty sure a hold need to be on the depicted side too

and must not EXCEED one minute.

It must not exceed whatever is published. That could very well be a DME distance and could very well be over a minute.

You are not issued holding instructions...

The holding instructions are the depiction of the holding pattern. Have everything you need to do it right there.

...with an EFC

Wasn't aware of a minimum amount of time holding to count it as holding last time I checked.

and you are not maneuvering for a final approach to landing. You are trying to establish a one minute holding pattern.

What you do before you cross the holding fix to descend for the approach is identical to normal "holding procedures." You still have to correct for winds.

Have you ever had to hold at an IAF? Its the same thing as a HILO. As is timed approaches from a holding fix.

 

[nosehair]

• It is the same instructions as "hold as published;" I don't think the concept of an EFC time is enough difference to make it not a hold. Is the missed approach hold also "not a hold" to you? No holding instruction with an EFC there either.

yes, "hold as published" may seem very similar to "fly as depicted", but what about a full holding instruction at an undepicted place with radials and directions and including an EFC in case of lost comm during the hold, which you would get.if you actually had to get a holding clearance on the missed.

• The turn needs to be done "as depicted." It's not "only on he depicted side" like the barbed procedure turn; it's a holding pattern with 1 minutes legs that requires the same entry and maneuvering to remain in protected airspace as any other hold.

We disagree here, and I may be wrong, but to me, it is a procedure turn that is limited to no more than one minute outbound, meaning you have only the airspace normally assigned to holding.
But "as depicted" means on the side as depicted. Nothing more. When I turn outbound, I can turn back inbound immediately if I want. I am not concerned with trying to establish a 1 minute inbound leg.
When I turn inbound establishing myself in a holding pattern, I am noticing the crab angle so I can adjust the next outbound leg.
When I turn inbound on an approach , I only care about getting established before crossing the FAF. I am concerned with approach and landing procedures.

This whole thread is mostly about how one can "meet the minimum requirement", with most comments being about how little you can do to get by.

Like how these same folks probably counted ASR s before "intercepting and tracking" were added.
Sheesh! It's common sense. "Approach procedures" for currency and training means any and all possible procedures, not just your same old easy stuff.
As is "holding procedures".

 

[LDJones]

This whole thread is mostly about how one can "meet the minimum requirement", with most comments being about how little you can do to get by.

Isn't that what "minimum requirements" are all about? No one is arguing you're automatically proficient by meeting them....but you ARE legal.

 

[nosehair]

but you ARE legal.

That's what you say, because the reg is written without enough specificity, so that you can apply the actual execution in the most training experience.

The bottom line is what would a jury think?
That's the question I pose to all my students who are looking for the least minimum paper requirement, and then have an accident relatable the inadequate training experience.

Legal becomes how well your lawyer can present your case.
That's really the only reason we log stuff anyway.

 

[Gucci Pilot]

...but what about a full holding instruction at an undepicted place with radials and directions and including an EFC in case of lost comm during the hold, which you would get.if you actually had to get a holding clearance on the missed.

That's why you are suppose to get five minutes to figure out the hold. Even if the holding instruction is given two minutes before the fix. That is plenty of time to figure out the hold. You are only gonna get a EFC if a delay is expected(which you will probably get anyways otherwise you wouldn't be holding), but it's not solely given for the purpose of lost comm.

If you are told to hold on the missed and it isn't the published missed, the published alternate missed, or given to you before commencing the approach(which 9 out of 10 is gonna be a climb and a heading), that controller sucks and I'm pulling the "unable" card and flying the published missed. That is too much work for me to get the jet climbing away from the ground, cleaned up, sped up, and trying to figure out some arbitrary holding instruction.

Legal becomes how well your lawyer can present your case. That's really the only reason we log stuff anyway.

I think it would be a cakewalk for a lawyer to present that a "Holding in lieu of a procedure turn" is a holding procedure.

 

[midlifeflyer]

That's what you say, because the reg is written without enough specificity, so that you can apply the actual execution in the most training experience.

The bottom line is what would a jury think?.

It mostly doesn't matter. The issue of whether you got an ETC time 4 months before the accident is typically not much of an issue if you are the defendant in a lawsuit alleging negligent operation of an aircraft and caused damage or injury.

 

[RotorAndWing]

You guys make this so much more difficult than it actually is.

 

[midlifeflyer]

You guys make this so much more difficult than it actually is.

Haven't' you noticed that, as pilots, it's one of the things we are best at? We start by over-complicating the way we teach student pilots ground reference maneuvers and then graduate to hold entries and DME arcs during instrument training. The biggest downside to NDBs going away is the loss of one of most fruitful things to make more difficult than it is.

 

[RotorAndWing]

Haven't' you noticed that, as pilots, it's one of the things we are best at? We start by over-complicating the way we teach student pilots ground reference maneuvers and then graduate to hold entries and DME arcs during instrument training. The biggest downside to NDBs going away is the loss of one of most fruitful things to make more difficult than it is.

Actually you are correct on this when it comes to the non professional pilots who revel in making relatively simple matters very complex and complicated.

 

[midlifeflyer]

Actually you are correct on this when it comes to the non professional pilots who revel in making relatively simple matters very complex and complicated.

I don't know... I've been on a few boards that cater to professional pilots and they seem to do just as good a job at over-thinking. And know plenty of non-pros who cut to the chase.

One doesn't have to be a professional pilot to fly like a professional pilot.

To be fair, most of the complexity in this thread is from those who forget that currency <> proficiency and are thinking in terms of what "currency" should require to make it into a true "proficiency" requirement rather than what it does require. OTOH, I always try to remember that the 6 approaches and holding procedures don't even have to be any good in order to count!

 

[RotorAndWing]

To be fair, most of the complexity in this thread is from those who forget that currency <> proficiency and are thinking in terms of what "currency" should require to make it into a true "proficiency" requirement rather than what it does require. OTOH, I always try to remember that the 6 approaches and holding procedures don't even have to be any good in order to count!

Yep, under Part 61/91 it doesn't matter whether the currency requirements even meet the PTS standards, just say you did it and that's good enough...

 

[poadeleted20]

Yep, under Part 61/91 it doesn't matter whether the currency requirements even meet the PTS standards, just say you did it and that's good enough...

Yup. And this example of the lower standards for pilots flying not in a commercial operation is just one of the reasons why the FAA is so hard-over against pilots taking money from passengers outside an operation with either a commercial operating certificate or a Letter of Authorization -- they want everyone paying for the ride to get what they pay for, including a higher mandatory standard of safety. The problem with this is many pilots seem to feel they should get something for nothing, i.e., be able to take money from passengers without meeting the higher standards for commercial operations. As Heinlein said, "There ain't no such thing as a free lunch" -- if you want to avoid all the extra requirements like six-month instrument checks, you have to give up the privilege of taking money from passengers other than under some very narrow exceptions.

 

[ChrisK]

And I don't think that the hold-in-loo maneuver qualifies as "holding procedures".
It is a type of procedure turn for an approach. The turn only needs to be on the depicted side, and must not EXCEED one minute.
You are not issued holding instructions with an EFC, the initial outbound MUST be one minute, and you are not maneuvering for a final approach to landing. You are trying to establish a one minute holding pattern.
Counting a hold-in-leu type procedure turn as a holding pattern is like counting a radar approach as one of the required approaches.

I don't buy this. I can fly an entirely loggable procedure including hold without talking to ATC once. There is no need for a clearance, holding instructions, or EFC to make a IAP or hold loggable. In fact, with a safety pilot, I don't see any reason I can't just go hold at whatever identifiable fix I please with whatever leg length and turn direction I desire and log it for currency.

Just because we usually do practice approaches in contact with ATC (as we should!) doesn't mean we can't do them on our own out of contact.

 

[nosehair]

I think it would be a cakewalk for a lawyer to present that a "Holding in lieu of a procedure turn" is a holding procedure.

Yes, if you are actually entering into a hold prior to being cleared for approach.
My response is to those who believe that flying a hold-in-lieu type procedure turn on an approach counts as a hold.
No holding. "Cleared for the xx approach...." You hit the IAF, do a teardrop or whatever type turn as if it were a holding pattern entry, but it is not.
You can make any (most) procedure turn as if it were a holding pattern entry, but many of the holding procedures are not present.
So when you turn inbound on this approach you are establishing yourself on final and executing final approach procedures, waiting to cross the FAF or intercept the glideslope.
You don't care about timing and crab angle in preparation for the next lap.
Of course, I'm talking about a PTS holding pattern, as I would any maneuver or procedure which is required to maintain or demonstrate currency.
Its a standard.

 

[nosehair]

It mostly doesn't matter.

I know. I throw that in for dramatic effect. But it is a concept. Personal responsibility.

 

[Gucci Pilot]

My response is to those who believe that flying a hold-in-lieu type procedure turn on an approach counts as a hold....Of course, I'm talking about a PTS holding pattern, as I would any maneuver or procedure which is required to maintain or demonstrate currency.
Its a standard.

According to the PTS it counts.

The examiner is not required to follow the precise order in which the
AREAS OF OPERATION and TASKS appear in this book. The examiner
may change the sequence or combine TASKS with similar Objectives
to have an orderly and efficient flow of the practical test. For example,
holding procedures may be combined with an approach or missed
approach procedures if a holding entry is part of the procedure.

 

[nosehair]

OK, if an actual entry into a "holding pattern", with intent to hold, not simply doing a PT shaped like a holding entry.
That is the examiners call. If enough skill and knowledge of both procedures are demonstrated.

 

[poadeleted20]

OK, if an actual entry into a "holding pattern", with intent to hold, not simply doing a PT shaped like a holding entry.
That is the examiners call. If enough skill and knowledge of both procedures are demonstrated.

The question under discussion in this thread (see the title: "Holds for currency") isn't what you have to do for an IR practical test (which is clearly spelled out in the IR PTS including several elements) but what you have to do to meet 61.57(c) (where it merely says "holding procedures and tasks"). Note that while 61.57(d) on IPC's specifically requires compliance with the IR PTS, 61.57(c) regarding recent experience does not.

 

[coloradobluesky]

Ron have you got all these FAR sites memorized? Either way it is really pretty damn good.

You like this legal FAR interpretation. I asked you if an instructor could "sign a student off for an IFR flight test" if the instructors rating had expired. Note I didn't say "give instruction". Just "sign him off". So lets say this instructor gave the instruction when his cert was current, but signed him off for the test AFTER the cert expired. Legal sign off yea or nea?

(Ive got some others too)

 

[midlifeflyer]

Ron have you got all these FAR sites memorized? Either way it is really pretty damn good.

You like this legal FAR interpretation. I asked you if an instructor could "sign a student off for an IFR flight test" if the instructors rating had expired. Note I didn't say "give instruction". Just "sign him off". So lets say this instructor gave the instruction when his cert was current, but signed him off for the test AFTER the cert expired. Legal sign off yea or nea?

(Ive got some others too)

You're asking whether an endorsement that needs to be signed by an authorized instructor can be signed by someone who is not an authorized instructor?

 

[flyingron]

No holding. "Cleared for the xx approach...." You hit the IAF, do a teardrop or whatever type turn as if it were a holding pattern entry, but it is not.

You keep saying this but it is NOT TRUE. If there were just a PT barb on the approach, what you are saying is correct, you can do any kind of reversal you want as long as you stay on the other side.

If there is a charted TEARDROP PT or Holding Pattern (In lieu of the PT) then you have to fly it AS DEPICTED. The holding pattern requirements in the hold-in-loo is NO DIFFERENT than an enroute hold elsehwere.

The FAA does not appear to care whether you are skillful in maintaining perfect oval racetracks on outbound legs or they would require you to do so. In fact, nothing in the currency requirements says anything about EITHER proficiency NOR complete coverage. I can do 6 ILS approaches and never fly a NDB approach if I want. They don't care if I track a VOR course looking like I'm doing S-turns across a road.

 

[poadeleted20]

Ron have you got all these FAR sites memorized?

You teach them a couple of times a month for 10 or 15 years and you get to know them.

You like this legal FAR interpretation. I asked you if an instructor could "sign a student off for an IFR flight test" if the instructors rating had expired. Note I didn't say "give instruction". Just "sign him off". So lets say this instructor gave the instruction when his cert was current, but signed him off for the test AFTER the cert expired. Legal sign off yea or nea?

My opinion is "no". Per 61.193(f):

Sec. 61.193

Flight instructor privileges.

A person who holds a flight instructor certificate is authorized within the limitations of that person's flight instructor certificate and ratings to train and issue endorsements that are required for:
...
(f) An instrument rating;

...so signing that endorsement is a privilege of someone who holds a flight instructor certificate, and if that certificate has expired, the holder no longer has that privilege.

That said, if the training was all completed and the instructor was satisfied that the trainee was good to go before the instructor's CFI ticket expired, I suppose s/he could enter the endorsement in the trainee's logbook later and backdate it to the date those conditions were met while the instructor's certificate was still valid, and the FAA would probably never know the difference. OTOH, if the FAA caught that instructor giving backdated endorsements (and let's not get into nit-picking discussion about how that might happen and just assume for argument's sake that it did), that instructor would probably be done as both an instructor and as a pilot. Further, IACRA isn't going to let someone with an expired CFI enter an "Instructor's Recommendation" on the on-line 8710-1.

 

[nosehair]

You keep saying this but it is NOT TRUE. If there were just a PT barb on the approach, what you are saying is correct, you can do any kind of reversal you want as long as you stay on the other side.

If there is a charted TEARDROP PT or Holding Pattern (In lieu of the PT) then you have to fly it AS DEPICTED. The holding pattern requirements in the hold-in-loo is NO DIFFERENT than an enroute hold elsehwere.

The FAA does not appear to care whether you are skillful in maintaining perfect oval racetracks on outbound legs or they would require you to do so. In fact, nothing in the currency requirements says anything about EITHER proficiency NOR complete coverage. I can do 6 ILS approaches and never fly a NDB approach if I want. They don't care if I track a VOR course looking like I'm doing S-turns across a road.

Ahh, there's the rub. I thought it was. Flying a procedure turn shaped like a holding pattern is not holding. Ask ATC. If AT wanted you to enter a hold over the fix prior to the approach, they would tell you. But absent holding instructions, you are making a course reversal shaped like a holding pattern, but it is merely a course reversal with no real currency review of holding as described in the AIM.
To combine the the hold with an approach procedure, if the pilot gets holding instructions first, flies a good pattern entry and establishes himself inbound, then is cleared for the approach procedure, and is able to transition from inbound in holding to inbound on final, then it can count because you were actually holding long enough to satisfy being established in holding.

 

[Gucci Pilot]

Flying a procedure turn shaped like a holding pattern is not holding.

^^^How did you get that...^^^

If there were just a PT barb on the approach, what you are saying is correct, you can do any kind of reversal you want as long as you stay on the other side.

^^^From this...^^^

It(a HILOPT) is holding by its definition "Holding instead of a procedure turn." It doesn't get much more black and white...

 

[Palmpilot]

Ahh, there's the rub. I thought it was. Flying a procedure turn shaped like a holding pattern is not holding. Ask ATC. If AT wanted you to enter a hold over the fix prior to the approach, they would tell you. But absent holding instructions, you are making a course reversal shaped like a holding pattern, but it is merely a course reversal with no real currency review of holding as described in the AIM.
To combine the the hold with an approach procedure, if the pilot gets holding instructions first, flies a good pattern entry and establishes himself inbound, then is cleared for the approach procedure, and is able to transition from inbound in holding to inbound on final, then it can count because you were actually holding long enough to satisfy being established in holding.

ATC is not the arbiter of what fulfills currency requirements and what doesn't. Approach charts are incorporated into the regulations by reference, and that means that from a legal point of view, if a PT is depicted as a hold, it is a hold. This is reinforced by the FAA's use of the word "hold" in it's description of such procedures, which is "hold in lieu of procedure turn."

If you can find anything contrary to that in the regulations or FAA published guidance, let's see it. I don't think plausibility arguments are sufficient to counter what the FAA has actually published on the subject.

 

[ChrisK]

ATC is not the arbiter of what fulfills currency requirements and what doesn't.

Exactly. I can go hold wherever I damn well please and talk to no one but my safety pilot. If I'm wrong about this, please explain!

 

[flyingron]

There are all sorts of holds other than ones issued by ATC. In addition to the Hold-in-loos, nearly every missed approach procedure has a hold at the end of it, and some departure procedures have them as well (My hold on my instrument checkride was the "climb in the hold" departure procedure at KSHD).

ATC can clear you out of the hold explicitly at any time (or implicitly by the fact you've made the requisite one turn or reached the required altitude). The FAA has never expressed any qualification on the number of turns being required, just that you execute an entry procedure and that you don't leave it without appropriate authorization.

 

[nosehair]

ATC is not the arbiter of what fulfills currency requirements and what doesn't.

No, and I only mentioned ATC because they have not issued holding instructions, so they do not expect a pilot to "make a complete loop of the holding pattern".
And neither should we think so, as the OP was asking, as I have heard so many pilots ask. Because some pilots think they have to fly a complete holding patter just because it is depicted as the Procedure Turn.

from a legal point of view, if a PT is depicted as a hold, it is a hold. This is reinforced by the FAA's use of the word "hold" in it's description of such procedures, which is "hold in lieu of procedure turn."

This is the misconception that has created the confusion; the word "hold" in the description of the Approach Procedure.
In the standard procedure that shows a straight line 10 nm out the inbound radial with the 45 barbed arrow towards the maneuvering side, you can make the turn any way you want as long as it is on the maneuvering side. You can do a PT exactly like a holding pattern entry. But that is not a hold, is it? Is that what you, and everyone is saying? Make the PT like holding pattern entry and it counts for a holding pattern for currency?

Anyway, to clear up confusion about the "hold-in-lieu", that is a misunderstanding of "hold". The PT airspace for that approach does not have the standard 10 nm from the fix, so they shorten up the available aiespace for the Approach Procedure,so you are limited in your course reversal technique to the standard outbound distance of the standard holding pattern. Holding is not required to execute the approach.
If ATC wants you to hold there, they will issue holding instructions like any other approach.
Nothing, no, NOTHING is different about this type approach except your course reversal technique.
None of the other elements of holding enter into the procedure.
If you are satisfied with that as counting for holding, it's on you.

But why would I stop there?
I don't think that doing the same approach six times over should count for currency either.

 

[flyingron]

In the standard procedure that shows a straight line 10 nm out the inbound radial with the 45 barbed arrow towards the maneuvering side, you can make the turn any way you want as long as it is on the maneuvering side. You can do a PT exactly like a holding pattern entry. But that is not a hold, is it? Is that what you, and everyone is saying?

Nope, that is what nobody but you is saying. We are talking about an approach that has a EXPLICIT holding pattern depicted as the procedure turn NOT the barb.
This has been stated at least three times. This is called by the FAA a Holding Pattern In Lieu of a Procedure Turn. This is not a term we are making up.

Anyway, to clear up confusion about the "hold-in-lieu", that is a misunderstanding of "hold". The PT airspace for that approach does not have the standard 10 nm from the fix, so they shorten up the available aiespace for the Approach Procedure,so you are limited in your course reversal technique to the standard outbound distance of the standard holding pattern. Holding is not required to execute the approach.

You seem to be bent around the axle that an INFINITE DURATION HOLD is required to constitute a holding pattern. Such a definition has never been promulgated by the FAA. "approaches," "HOLDING PROCEDURES" is as intentionally vague as "tracing courses." The FAA isn't requiing you to fully explore all aspects of either. Entering the holding pattern is what the rules say for the HILPT.

 

[midlifeflyer]

I don't think that doing the same approach six times over should count for currency either.

But like it or not, it does. Even if you let the autopilot fly it and take a nap.

For better or for worse, "currency" is a minimum and usually a minimal regulatory standard. It should never be equated with proficiency. A pilot who's only night experience was during his private training 5 years ago is not night "proficient" after three takeoffs and landings and is an idiot if he takes the wife and kids on a night cross country after a day of work based on having landed 3 times at the home drome..

I think of currency solely as an FAA limitation on PIC authority – limiting the decisions a pilot is authorized to make.

Instrument currency is a good example. Without currency a pilot is not allowed to fly “in the system” even on a CAVU day. With currency, a pilot is given the authority to determine how proficient he or she is and what forecast weather he or she is capable and willing to fly in.

I know you'd like to see currency = proficiency. Admirable goal. But in the real world it doesn't. Hopefully it won't. Regulating proficiency would probably triple the size of Part 61 (assuming you could get an agreement on all the "shoulds" to put in the regs) and the cost of flying and, based on how most GA accidents take place, not do a heck of a lot for safety in return.

 

[Palmpilot]

You can do a PT exactly like a holding pattern entry. But that is not a hold, is it? Is that what you, and everyone is saying? Make the PT like holding pattern entry and it counts for a holding pattern for currency?

No, that's not what I'm saying (and based on their replies, it's apparently not what others are saying). As I wrote in the post you replied to, "if a PT is depicted as a hold, it is a hold." [emphasis added] Please don't convert what I'm saying into the position you would LIKE to argue against. That's called "setting up a straw man."

Anyway, to clear up confusion about the "hold-in-lieu", that is a misunderstanding of "hold". The PT airspace for that approach does not have the standard 10 nm from the fix, so they shorten up the available aiespace for the Approach Procedure,so you are limited in your course reversal technique to the standard outbound distance of the standard holding pattern. Holding is not required to execute the approach.
If ATC wants you to hold there, they will issue holding instructions like any other approach.
Nothing, no, NOTHING is different about this type approach except your course reversal technique.
None of the other elements of holding enter into the procedure.
If you are satisfied with that as counting for holding, it's on you.

I would be satisfied if they eliminated the holding requirement altogether. In all the decades before that requirement was created, were people dying because of lack of holding proficiency?

That having been said, when I ask ATC for a hold, I generally stay in the holding pattern long enough to satisfy myself that I can fly a reasonable facsimile of a holding pattern. As long as I'm there, I figure, "Why not?"

 

[Everskyward]

Years ago I had an observed (by the FAA) checkride. I heard later that the FAA guy criticized the TCE (training center examiner), who is a designee, for only having me do the hold entry instead of making me go around at least once. This was a hold at the end of a missed approach, not a HILPT. These two guys had different opinions of what was necessary. Did I need to get back in the sim and do a complete holding pattern? No. So it really must not have been that important. Just like many of the things we discuss here.

 

[olasek]

Of course, you ain't gonna do all that in an hour and a half.

But in some qualified FTD you probably could have managed to accomplisdh all the above it in that time :wink2:

 

[nosehair]

For better or for worse, "currency" is a minimum and usually a minimal regulatory standard. It should never be equated with proficiency..

Oh, what a tangled web we weave...

Oh, contraire, my friend, "currency" is all about "proficiency".
Proficiency is the sole reason for currency regulations.
3 landings in 90 days, 6 approaches in 6 mos., etc. are minimum requirements when you are proficient. Being proficient overrides meeting minimums.
Ask any passenger.
We are all responsible to maintain "proficiency" within the basic law of 91.3 and 91.103,
Authority and Responsibility.
Can't have one without the other

 

[poadeleted20]

Oh, what a tangled web we weave...

Oh, contraire, my friend, "currency" is all about "proficiency".
Proficiency is the sole reason for currency regulations.
3 landings in 90 days, 6 approaches in 6 mos., etc. are minimum requirements when you are proficient. Being proficient overrides meeting minimums.

I don't see any way to justify those statements. One can point to any number of examples in the accident files where someone was "current" but clearly not proficient, and being proficient is never a legal excuse for not being "current".

We are all responsible to maintain "proficiency" within the basic law of 91.3 and 91.103,

I've read both those sections, and I see nothing there about proficiency, especially 91.103, which covers nothing other than preflight planning. I guarantee that no amount of familiarization with available information pertinent to the flight to be made will make up for any lack of proficiency (from a safety perspective) or currency (from a legality perspective).

 

[midlifeflyer]

Oh, what a tangled web we weave...

Oh, contraire, my friend, "currency" is all about "proficiency".
Proficiency is the sole reason for currency regulations.
3 landings in 90 days, 6 approaches in 6 mos., etc. are minimum requirements when you are proficient.

I guess we'll have to disagree. Meeting those minimum requirements does not mean one is proficient and those minimums don't change depending on the pilot's skill level.

If you want to argue that they "should" that's a different issue. The reality is that they don't.

 

[azure]

If you want to argue that they "should" that's a different issue. The reality is that they don't.

IOW, necessary, but not sufficient...