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Instrument currency in an FTD

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UndauntedFlyer said:
Nowhere does it say in the FAR's that an ICC must be signed by the person who gave the check.
Sir, I have seen you suggest this idea that an ICC does not require a signature before. I have to assume that you are making this point because 61.57(d) does not use the words "logbook endorsement" as does the Flight Review reg, 61.56.
61.57(d) does say, in part:"...may not serve as pilot in command under IFR...until that person passes an IPC...required by the instrument PTS."

So, as you have already said, it was not an IPC because was only some approaches. It probably did not meet the IPC PTS requirements. The original poster probably does not know that the IPC requirements are mandated in the instrument PTS, but that is another story.

Back to the IPC signature requirement. You might win the case that a signature is not required by a specific regulation, but how do you show that you passed by an authorized instructor, as the regulation requires?

O, yeah, you could just have the authorized instructor call the FSDO and verify that he was actually on board and that you did pass; is that your thinking? What are you thinking? ...and, of course, in this case, the authorized instructor would probably say, "No, I was not doing an IPC, it was only an interview. It wasn't even dual instruction."

That is why you should not write stuff in a logbook concerning dual instruction unless the instructor himself knowingly signs for it.

Also, 61.51(g)(4) says: "A flight sim or FTD may be used by a person to log instrument time provided an authorized instructor is present."
I think you might be legal to log that as time without a signature, but you would have to be able to produce some kind of record or proof that an instructor was present.

I'm just saying, Sir, that it promotes problems, mis-understandings, and can be down right unsafe to indicate that you can log sim time without an instructor's signature. Especially an IPC. No matter how you might like to twist the regulation.
 
UndauntedFlyer said:
Nowhere does it say in the FAR's that an ICC must be signed by the person who gave the check. Therefore you could enter that yourself that you satisfactorily passed that check if an when that ever happens.

Until someone can come up with a bona-fide legal interpretation from FAA counsel which agrees with this, I think it is best if everyonge ignores this advice. I know that it's one of Undaunted Flyer's pet opinions, and I agree that there is an ambiguity which *could* be interpreted as not prohibiting someone signing thier own ICC, but it's a stretch, and I certainly wouldn't want to put myself in the position of defending my certificate with only an ambiguity in the regs to justify my position. Remember, when you are facing the FAA in an NTSB hearing, the FAA's attorney may issue an interpretation of the regs, right there on the spot, which "interprets" away your ambiguity, and that interpretation becomes binding upon the NTSB.

That's not the sort of gamble that I'd care to take.
 
A Squared said:
Until someone can come up with a bona-fide legal interpretation from FAA counsel which agrees with this, I think it is best if everyonge ignores this advice. I know that it's one of Undaunted Flyer's pet opinions, and I agree that there is an ambiguity which *could* be interpreted as not prohibiting someone signing thier own ICC, but it's a stretch, and I certainly wouldn't want to put myself in the position of defending my certificate with only an ambiguity in the regs to justify my position. Remember, when you are facing the FAA in an NTSB hearing, the FAA's attorney may issue an interpretation of the regs, right there on the spot, which "interprets" away your ambiguity, and that interpretation becomes binding upon the NTSB.

That's not the sort of gamble that I'd care to take.

Actually, ASquared and the others do give good advice on this subject. It is probably best to follow their advice to be safe. Not that I'm wrong but their advice is the safest when you're in a gray area.
 
I'm convinced that no one really knows what is going on at the FAA.

I swear the FARs were written by the bastard children of our founding fathers.
 

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