Their thinking is that someone who hasn't flown - well, taken off and landed 3 times - in the preceding 90 days could be a serious risk, for himself and his passengers. A pilot can assess those risks, but a non pilot can't.......
Although this seems a logical and sensible point of view, it is in conflict with the letter of the rule, and I would want it in writing from the LBA before relying on it.
MJ
