Originally Posted by
B2N2
Ask yourself what would satisfy a
- NTSB judge
- Judge in a civil liability case
- Judge in a criminal case
Rather then trying to read into minutiae and mismatching regulations?
I find it especially ironic that the alleged “evidence” is in FAA council letters that concern accidents.
I think a legal opinion from an FAA assistant chief council for regulations would tick those boxes.
Part 61.75 clearly states that the holder "
Is subject to the limitations and restrictions on the person's U.S. certificate and foreign pilot license"
The FAA have clearly ruled that limitations and restrictions must be annotated on the licence and even given examples such as "not valid for night operation" etc. If a
total lack of an EASA PA46 type rating isn't considered a limitation then clearly neither is a lack of currency.
Part 61 Requires that flight review be conducted which takes care of the proficiency aspect - which makes perfect sense - its an FAA certificate so they want you to meet FAA currency requirements. The underlying licence must be
valid (not surrendered or revoked) and have no limitations (as per FAA definition of limitations). Currency is irrelevant.
Why not write to the FAA for an opinion?