Lindberg
Final Approach
I know I've said this before, but one of law school's most practical lessons was, "Never paraphrase the statute."
Where Is The "6 Month Grace Period" Spelled Out?
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First year. First course where we worked extensively with statutes or regulations (commercial law/UCC). Prof explicitly said, "Don't tell me what you think it says. Read it." That was about 53 years ago. Like you, a lesson I never forgot.
(c) Is very clear to determine if you are current you review your logbook for the prior 6 months to see if you meet the requirements to be instrument current.
(d) is very clear that if you don't meet the requirements for more than 6 months you must do an IPC.
What I don't find anywhere in the regs anymore is *specifically* what you CAN and MUST do, if anything, in the 6 months in the middle. Yes, I know what we've all been taught and read in publications. But I'm looking for it in the regs. It is possible it was removed in various rewrites.
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I’m sure I was taught the same as a 1L but my Insurance professor third year did a better job of pounding it into my feeble mind. On the first day, he wrote “Read the policy.” on the board and told us “Write this down. It will be the answer to at least one question on your final exam.”
I agree that it’s almost certainly practically moot. Even if I only owed one approach because of an unfortunate stretch of good weather, I would want the IPC I’m paying for to challenge me more than a single approach. But in the spirit of the thread…
61.57(d) says “a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check.” There is no language here that allows a person who has not failed to meet the requirements of (c) for more than 6 months to become current by completing an IPC.
Going a step further, it also does not say that you are not subject to the currency requirements of (c) after you complete an IPC. The “only by” does imply “by” of course, but then we have this problem: What does the regulation say about how long your currency lasts after an IPC?
I think we all treat this as meaning an IPC completed at any time makes you current for 6 months without anything other than the IPC in your logbook, even if the regulation is silent or in conflict with that understanding. But I’ve seen plenty of cases where everyone thought a law meant something for ages only to have a court tell the world they were wrong the whole time. Sometimes it’s the same judge on the same court with the same question about the same words deciding that his first opinion years ago was wrong. So I’m probably above-average paranoid about unclear regulations.
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The missing link here is to start with only (c). Pretend (d) isn’t there at all. Under what conditions would you be current? Get a safety pilot or simulator and fly until you can log 6 approaches, a hold, and a course intercept within the past 6 months. Now you’re current. It didn’t matter that you temporarily lost currency. And, under (c), you could have been out of currency for 20 years, much less 6 months.
The only reason 6 months matters is because of (d). And because of that, there is no need for a separate rule about what you can or must do in that 6-month window before (d) kicks in. It’s covered fully by (c).
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You forgot getting the rating. These days when it's hard to schedule timely checkrides, you might not have 6 in the 6 calendar months before passing the ride and - in the spirit of this thread - might not be current the day you pass. Someone actually asked the Chief Counsel that one. The answer covered both the newly-minted and the recipient of an IPC. If anyone is wondering, yes you are.
Fortunately, at least with respect to this regulation - the interpretations don't challenge reasonableness. And the only time I've seen people parsing too tightly, it's been on the losing side. The too-tight parsers I've seen in the legal system tend to be non-lawyers - jailhouse lawyers and pro se litigants. Most of the lawyers I've seen do it were grasping at straws or trying to be a PITA.
Lindberg
Final Approach
Take a look at 61.57(a) for passengers, which is simpler. By your logic it tells you how you know if you're current, but it doesn't tell you what you need in order to get current. But everyone else seems to understand that those are the same thing.
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Six months or 7 months. Since I messed it up earlier, here is the explanation. For a moment, forget the FAA "calendar month" concept. Suppose it was date-to-date normal months.
It is now July 14, You want to fly IFR. What date do you look back to? What is 6 months to the day before July 14?
Now just take away the date within the month.
It is now July 14, You want to fly IFR. What date do you look back to? What is 6 months to the day before July 14?
Now just take away the date within the month.
MauleSkinner
Touchdown! Greaser!
(c) tells you that you can use certain flight experience to gain/maintain currency. (d) tells you the only time that you can’t, which is more than 6 calendar months after you were last current.
Since the six months in the middle is not part of (d), it is part of (c).
MauleSkinner
Touchdown! Greaser!
What I don’t see is where it says you can take an IPC to regain currency within the 6 months after becoming non-current under (c).
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RussR
Final Approach
True, it doesn't, but the Chief Counsel apparently believes it is reasonable that an IPC resets the clock, as does a checkride. See especially the last sentence.
2008 Wynne interpretation:
Dynamic Regulatory System
bonefishpete
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Probably the hardest part of being and flying in Florida was the 6 hours required.
Approaches were easy but that 6 hours actual was hard especially if you were being honest about it.
Approaches were easy but that 6 hours actual was hard especially if you were being honest about it.
Show me where it says this? Going with (c) only, you look back at the "preceding" 6 months. So you're good for 7 months. But (c) says nothing about what happens if you didn't fly in the 7th month and you're now in the 8th month. And if your currency all took place in what is now 7 months prior, so you are not current in the preceding 6 months. There is no *documented* way on how you get current again.
I was taught and I know of a few publications that state if you let your currency lapse, you have 6 months to get current again. And yes, lots of logical ways that the FAA will not go after you for doing, but still the question remains about where is this information in the regs or legal interpretation. But show me where it actually stipulates that in the regs? @midlifeflyer showed in Msg #9 the changes in the regs over the years that confirmed that I wasn't crazy, the wording has changed from when I was doing my Inst. training.
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I deliberately omitted it but it does fall into the same overall crack between the boards. And, while writing my response to @M20K in this post, I noticed yet another nonsensical pedantic thing to worry about: If you log approaches, holds, or course interceptions to regain currency, you can’t file IFR until the next calendar month. The currency-supporting tasks must be “within the 6 calendar months preceding the month of the flight.”
Thank you. I would have reached a different conclusion, but that’s the good thing about asking the Chief Counsel because they can employ common sense in ways an outsider might be laughed out of court for.
@midlifeflyer is absolutely right about prison lawyers and their ilk, though. I would add represented persons with crazy uncles (whose name varies but can be ChatGPT).
Let’s say I flew 6 approaches, a hold, and a course interception back in December 2025 but I haven’t flown since then. It’s now August 2026, so I have 0 approaches, 0 holds, and 0 course interceptions in the preceding 6 months. I am not current now under 61.57(c), but I was current within the past 6 months so 61.57(d) doesn’t apply.
Now, tomorrow, August 10, I go out and fly (and log) 6 approaches, 1 hold, and 1 course interception. Assume that I want to file IFR on September 1. If you read only 61.57(c), does it say that I am current? If not, what do you think I’m missing under 61.57(c) only?
If you next read 61.67(d), does it change the answer? If so, what part of 61.57(d) do you think takes my currency away?
Where does it says you can do that.... please show me.
Again, not disputing this is what a lot of us were taught many decades ago. And not disputing it is in lots of articles. But this is a discussion about what the regs say, or don't say. So show me where it SAYS you are legal to go fly if you do that? Right now it says 6 months prior or after 12 months you do an IPC. If you find something else, that is exactly what I'm looking for. Again, not practical or common sense, but regulatory.
So do you now see what the question is? (Yes, this is an "in the weeds" discussion.)
MauleSkinner
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Show me the reg that says you can fly on Sundays.Where does it says you can do that.... please show me.
Again, not disputing this is what a lot of us were taught many decades ago. And not disputing it is in lots of articles. But this is a discussion about what the regs say, or don't say. So show me where it SAYS you are legal to go fly if you do that? Right now it says 6 months prior or after 12 months you do an IPC. If you find something else, that is exactly what I'm looking for. Again, not practical or common sense, but regulatory.
So do you now see what the question is? (Yes, this is an "in the weeds" discussion.)
Regulations generally restrict operations. If they don’t tell you that you can’t do something, it’s generally allowed.
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I’ve seen the question all along. I’ve answered it in numerous ways. This one is not in the weeds. The post you quoted leads you to the water and, if you answer the questions in that post by reading the regulation, you’ll find yourself drinking.
MackMooney
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smh
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Ah, the olden days!
This is very true and I'm a firm believer in this as well!! But it used to say what to do, now it doesn't. So I'm just curious if they blew it or if there is somewhere else that it is <cough> allowed.
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Really? That’s not necessary. Just treat it as an academic discussion on over-parsing regulatory language until you get bored with it.
MauleSkinner
Touchdown! Greaser!
So your position is that when the FAA changes wording that doesn’t match general guidelines that they should add regulations that don’t match general guidelines?
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