The faa's chief counsel has issued a legal interpretation on when an instrument pilot must pass an instrument proficiency check in order to meet the instrument experience required to act as pilot in command of an instrument flight. Because of some apparent confusion in the rule's language, this issue has commanded attention a number of times in the past several years. The language was changed in 2007, again in 2009, and in 2011 when the FAA again acted to amend the rule. This most recent chief counsel's interpretation, issued in February 2012, is worth noting.
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