The FAA has just released a revised version of the instrument rating
practical test standards to become effective October 1, 2004:



http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-4d.pdf



Included in the footnotes of this new PTS is a substantial change in the
requirements for an Instrument Proficiency Check.



Currently a CFII conducting an IPC is permitted to use his discretion in
asking a pilot to demonstrate a reasonable selection of items from the PTS.
This seems reasonable in order to adjust the IPC to pilot
strengths/weaknesses which are perceived by either the pilot or the CFII, as
well as to adjust the IPC to items particularly important given a particular
pilot's airplane, avionics, and missions. In other words, the IPC can be
both a learning experience and a proficiency check.



The PTS now itemizes specific tasks which must be accomplished on an IPC.
Among these tasks, a circling approach is now required. I see this as
having several significant effects on the flight training industry, although
as a principal and instructor in a simulator-based flight school I am
interested in input from others not quite as directly affected:



(1) By granting discretion to a CFII, an IPC can currently serve not only
as a proficiency check but also as an opportunity for instruction or for a
pilot to try a new skill relevant to his IFR operations. In rigidly
defining the tasks to be included in an IPC, the FAA has removed the CFII's
discretion and turned the IPC into just another hurdle to overcome.



(2) Recently the FAA granted approval to a new class of inexpensive
training device called an Advanced ATD - An Advanced ATD is a PC
computer-based trainer approved among other purposes to conduct an entire
Instrument Proficiency Check, and an Advanced ATD is much less expensive
than more traditional full-scale Flight Training Devices or Simulators. An
Advanced ATD will no longer be able to function to conduct an entire IPC
because no Advanced ATD is approved for circling approaches. Thus schools
or individuals who very recently bought an Advanced ATD will not be able to
utilize such a device for the intended purpose, nor does there appear to be
a grandfather clause in the PTS.



(3) There exist a number of flight schools (including my own --- full
disclosure) which offer advanced simulator-based training in either
full-motion or non-motion Flight Training Devices or Simulators. These
devices cost anywhere from $100,000 to over $1,000,000 and are typically
approved to conduct a full Instrument Proficiency Check. With the new IFR
PTS, these devices will no longer be legal to conduct a full Instrument
Proficiency Check because many (most?) do not have a wide wraparound visual
display. Adding such a visual display would cost tens of thousands of
dollars and might still not be feasible at any price in the case of the more
expensive devices with enclosed cockpits. One workaround would be to use
these devices to log IFR Currency instead of an IPC, but that would not work
if a pilot is more than 6 months out of currency. Another workaround would
be to conduct a circling approach in an airplane, yet weather or maintenance
issues might make that impractical in some situations. Imagine traveling
hundreds of miles for specialized recurrent training in a sophisticated
training device but being unable to be signed off for an IPC due to a
technical change in FAA rules. Or imagine investing a 6-digit or 7-digit
sum in a training device, only to have the FAA quickly change the rules and
make the device suddenly illegal for its originally approved purpose.



(4) Is it desirable for the FAA to require IFR pilots to practice circling
approaches at every IPC? High visibility circling approaches are far less
critical a skill to maintain than flying a partial panel non-precision
approach. Low visibility circling approaches are risky enough that many
corporate and airline flight departments do not permit such approaches. By
requiring circling approaches at each IPC, will we be encouraging a circling
approach as a "normal" IFR procedure alongside straight-in ILS approaches?



--------------

Richard Kaplan, CFII, MCFI

Flight Level Aviation, Inc.



www.flyimc.com

This is typical FAA bull-puckie empire building, and by incompetents at that.
The original concept was an instrument competency check; simply do it until it
all fits.

Now, they want to progress towards an ATP check ride it seems. Where is AOPA
when we need them?

Richard Kaplan wrote:

> The FAA has just released a revised version of the instrument rating
> practical test standards to become effective October 1, 2004:
>
> http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-4d.pdf
>
> Included in the footnotes of this new PTS is a substantial change in the
> requirements for an Instrument Proficiency Check.
>
> Currently a CFII conducting an IPC is permitted to use his discretion in
> asking a pilot to demonstrate a reasonable selection of items from the PTS.
> This seems reasonable in order to adjust the IPC to pilot
> strengths/weaknesses which are perceived by either the pilot or the CFII, as
> well as to adjust the IPC to items particularly important given a particular
> pilot's airplane, avionics, and missions. In other words, the IPC can be
> both a learning experience and a proficiency check.
>
> The PTS now itemizes specific tasks which must be accomplished on an IPC.
> Among these tasks, a circling approach is now required. I see this as
> having several significant effects on the flight training industry, although
> as a principal and instructor in a simulator-based flight school I am
> interested in input from others not quite as directly affected:
>
> (1) By granting discretion to a CFII, an IPC can currently serve not only
> as a proficiency check but also as an opportunity for instruction or for a
> pilot to try a new skill relevant to his IFR operations. In rigidly
> defining the tasks to be included in an IPC, the FAA has removed the CFII's
> discretion and turned the IPC into just another hurdle to overcome.
>
> (2) Recently the FAA granted approval to a new class of inexpensive
> training device called an Advanced ATD - An Advanced ATD is a PC
> computer-based trainer approved among other purposes to conduct an entire
> Instrument Proficiency Check, and an Advanced ATD is much less expensive
> than more traditional full-scale Flight Training Devices or Simulators. An
> Advanced ATD will no longer be able to function to conduct an entire IPC
> because no Advanced ATD is approved for circling approaches. Thus schools
> or individuals who very recently bought an Advanced ATD will not be able to
> utilize such a device for the intended purpose, nor does there appear to be
> a grandfather clause in the PTS.
>
> (3) There exist a number of flight schools (including my own --- full
> disclosure) which offer advanced simulator-based training in either
> full-motion or non-motion Flight Training Devices or Simulators. These
> devices cost anywhere from $100,000 to over $1,000,000 and are typically
> approved to conduct a full Instrument Proficiency Check. With the new IFR
> PTS, these devices will no longer be legal to conduct a full Instrument
> Proficiency Check because many (most?) do not have a wide wraparound visual
> display. Adding such a visual display would cost tens of thousands of
> dollars and might still not be feasible at any price in the case of the more
> expensive devices with enclosed cockpits. One workaround would be to use
> these devices to log IFR Currency instead of an IPC, but that would not work
> if a pilot is more than 6 months out of currency. Another workaround would
> be to conduct a circling approach in an airplane, yet weather or maintenance
> issues might make that impractical in some situations. Imagine traveling
> hundreds of miles for specialized recurrent training in a sophisticated
> training device but being unable to be signed off for an IPC due to a
> technical change in FAA rules. Or imagine investing a 6-digit or 7-digit
> sum in a training device, only to have the FAA quickly change the rules and
> make the device suddenly illegal for its originally approved purpose.
>
> (4) Is it desirable for the FAA to require IFR pilots to practice circling
> approaches at every IPC? High visibility circling approaches are far less
> critical a skill to maintain than flying a partial panel non-precision
> approach. Low visibility circling approaches are risky enough that many
> corporate and airline flight departments do not permit such approaches. By
> requiring circling approaches at each IPC, will we be encouraging a circling
> approach as a "normal" IFR procedure alongside straight-in ILS approaches?
>
> --------------
>
> Richard Kaplan, CFII, MCFI
>
> Flight Level Aviation, Inc.
>
>
>
> www.flyimc.com

"Currently a CFII conducting an IPC is permitted to use his discretion
in
asking a pilot to demonstrate a reasonable selection of items from the
PTS".


This is not true. Since change 2 of the current instrument PTS came
out, there has been NO discretion as to the content of an IPC. The
rating task table, on page 15 of the current PTS specifically states
which tasks in each area of operation must be accomplished. Nothing
has changed in this requirement.

Perhaps you might re-evaluate the way you are performing your IPC's






On Thu, 27 May 2004 00:43:17 GMT, "Richard Kaplan"
> wrote:

>
>
>
>The FAA has just released a revised version of the instrument rating
>practical test standards to become effective October 1, 2004:
>
>
>
>http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-4d.pdf
>
>
>
>Included in the footnotes of this new PTS is a substantial change in the
>requirements for an Instrument Proficiency Check.
>
>
>
>Currently a CFII conducting an IPC is permitted to use his discretion in
>asking a pilot to demonstrate a reasonable selection of items from the PTS.
>This seems reasonable in order to adjust the IPC to pilot
>strengths/weaknesses which are perceived by either the pilot or the CFII, as
>well as to adjust the IPC to items particularly important given a particular
>pilot's airplane, avionics, and missions. In other words, the IPC can be
>both a learning experience and a proficiency check.
>
>
>
>The PTS now itemizes specific tasks which must be accomplished on an IPC.
>Among these tasks, a circling approach is now required. I see this as
>having several significant effects on the flight training industry, although
>as a principal and instructor in a simulator-based flight school I am
>interested in input from others not quite as directly affected:
>
>
>
>(1) By granting discretion to a CFII, an IPC can currently serve not only
>as a proficiency check but also as an opportunity for instruction or for a
>pilot to try a new skill relevant to his IFR operations. In rigidly
>defining the tasks to be included in an IPC, the FAA has removed the CFII's
>discretion and turned the IPC into just another hurdle to overcome.
>
>
>
>(2) Recently the FAA granted approval to a new class of inexpensive
>training device called an Advanced ATD - An Advanced ATD is a PC
>computer-based trainer approved among other purposes to conduct an entire
>Instrument Proficiency Check, and an Advanced ATD is much less expensive
>than more traditional full-scale Flight Training Devices or Simulators. An
>Advanced ATD will no longer be able to function to conduct an entire IPC
>because no Advanced ATD is approved for circling approaches. Thus schools
>or individuals who very recently bought an Advanced ATD will not be able to
>utilize such a device for the intended purpose, nor does there appear to be
>a grandfather clause in the PTS.
>
>
>
>(3) There exist a number of flight schools (including my own --- full
>disclosure) which offer advanced simulator-based training in either
>full-motion or non-motion Flight Training Devices or Simulators. These
>devices cost anywhere from $100,000 to over $1,000,000 and are typically
>approved to conduct a full Instrument Proficiency Check. With the new IFR
>PTS, these devices will no longer be legal to conduct a full Instrument
>Proficiency Check because many (most?) do not have a wide wraparound visual
>display. Adding such a visual display would cost tens of thousands of
>dollars and might still not be feasible at any price in the case of the more
>expensive devices with enclosed cockpits. One workaround would be to use
>these devices to log IFR Currency instead of an IPC, but that would not work
>if a pilot is more than 6 months out of currency. Another workaround would
>be to conduct a circling approach in an airplane, yet weather or maintenance
>issues might make that impractical in some situations. Imagine traveling
>hundreds of miles for specialized recurrent training in a sophisticated
>training device but being unable to be signed off for an IPC due to a
>technical change in FAA rules. Or imagine investing a 6-digit or 7-digit
>sum in a training device, only to have the FAA quickly change the rules and
>make the device suddenly illegal for its originally approved purpose.
>
>
>
>(4) Is it desirable for the FAA to require IFR pilots to practice circling
>approaches at every IPC? High visibility circling approaches are far less
>critical a skill to maintain than flying a partial panel non-precision
>approach. Low visibility circling approaches are risky enough that many
>corporate and airline flight departments do not permit such approaches. By
>requiring circling approaches at each IPC, will we be encouraging a circling
>approach as a "normal" IFR procedure alongside straight-in ILS approaches?
>
>
>
>--------------
>
>Richard Kaplan, CFII, MCFI
>
>Flight Level Aviation, Inc.
>

>
>www.flyimc.com
>
>
>
>
>

"Bill Zaleski" > wrote in message
...>

> This is not true. Since change 2 of the current instrument PTS came
> out, there has been NO discretion as to the content of an IPC. The

You are correct that the current PTS lists items which are required on an
IPC; however, those items are few enough and important enough that it is
unlikely any CFII would want to conduct an IPC without those items. It is
also clear that the CFII has the discretion to add additional items as
appropriate, and indeed most IPCs likely do include such additional items.

The newest PTS to take effect in October requires more tasks, enough tasks
in fact that in a typical 60-90 minute IPC flight it is probably not
practical to include much beyond the specifically required items.

--------------------
Richard Kaplan, CFII

www.flyimc.com

>>
(4) Is it desirable for the FAA to require IFR pilots to practice circling
approaches at every IPC?
<<

I think so. I suspect (but do not know as a fact) that the changes are coming
about because of a realization that circling approaches are not as benign as
they were first thought to be, and pilots should be proficient in them.
Perhaps too few pilots have any experience at all with them in training, and
then in real life are unprepared for the transition to visual while circling in
low visibilty at low altitude. The first time I did a circling approach (in an
IPC, at my request) it was an eye opener.

I'm much less concerned with the profits of businesses that have invested in
devices that are more expensive than airplanes and now complan that they need
to use a real airplane. There's plenty a sim can do (and some things done
better in a sim), but there's no beating an airplane.

I'm actually a bit more bothered by the "if it's in the airplane, you have to
demonstrate it, but if it's not in the airplane, you don't" mentality, though I
don't really have much to say for the alternative either and have no answer.

Jose



--
(for Email, make the obvious changes in my address)

"Teacherjh" > wrote in message
...>


> Perhaps too few pilots have any experience at all with them in training,
and
> then in real life are unprepared for the transition to visual while
circling in
> low visibilty at low altitude. The first time I did a circling approach
(in an
> IPC, at my request) it was an eye opener.

I agree with this completely, but then the same argument applies to flying
in actual IMC and especially to flying in night-time actual IMC. Why not
require an IPC be conducted at night or in IMC? Indeed, it is not even
required to EVER fly in IMC to get an IFR rating. It is not even required
to ever fly in IMC to get a CFII certificate.


> I'm much less concerned with the profits of businesses that have invested
in
> devices that are more expensive than airplanes and now complan that they
need
> to use a real airplane. There's plenty a sim can do (and some things done
> better in a sim), but there's no beating an airplane.

I agree completely that a combination of simulator and airplane time is
ideal, just like training in IMC is ideal. Does that mean an IPC should be
impossible to obtain in a flight training device or an IFR rating should be
impossible to obtain under the hood?

It sounds altruistic to say that it the profits of businesses are not
relevant, but actually the issue at hand is whether it is reasonable to
change the rules in the middle of the game, especially on such short notice.
How about if the FAA declared that in the interest of safety all airplane
owners need to install a Mode S transponder and inertia seatbelts by October
1? You say you agree there are some things done better in a simulator --
well, how likely do you think it is that new/innovative simulators will be
developed/installed if the owner cannot have reasonable confidence in the
legal uses of that simulator for a reasonably long enough period of time to
obtain a return on his investment?


--------------------
Richard Kaplan, CFII

www.flyimc.com

<<The PTS now itemizes specific tasks which must be accomplished on an
IPC. Among these tasks, a circling approach is now required.>>

It's not clear to me that there is any regulatory requirement to use
the PTS, since the FARs don't require it.

> You are correct that the current PTS lists items which are required on an
> IPC; however, those items are few enough and important enough that it is
> unlikely any CFII would want to conduct an IPC without those items. It is
> also clear that the CFII has the discretion to add additional items as
> appropriate, and indeed most IPCs likely do include such additional items.
>
> The newest PTS to take effect in October requires more tasks, enough tasks
> in fact that in a typical 60-90 minute IPC flight it is probably not
> practical to include much beyond the specifically required items.

I don't see much difference from the current PTS - in fact it looks like the
new PTS actually requires fewer tasks for an IPC. The current PTS already
requires a circling approach on an IPC, which seemed to be your biggest
objection to the new PTS.

Barry

"Greg Esres" > wrote in message
...

> It's not clear to me that there is any regulatory requirement to use
> the PTS, since the FARs don't require it.

Well, if that were true then that would indeed end the whole discussion.
Yet FAR 61.57 does reference the IFR PTS:


"until that person passes an instrument proficiency check consisting of a
representative number of tasks required by the instrument rating practical
test"

I suppose you are saying that all that is regulatory is that there be some
number of tasks listed in the PTS but the IPC task list is not regulatory?
Does anyone else agree here?


--------------------
Richard Kaplan, CFII

www.flyimc.com

>>
but then the same argument applies to flying
in actual IMC and especially to flying in night-time actual IMC
<<

The hood (badly) simulates IMC. How would you simulate a circling approach?
Anything which works would be ok with me (including a more expensive simulator,
or a real airplane). It is a task that should be tested.

I also think that to get the instrument rating, some night IMC or hood time
should be included. I'd leave this as an optional task for an IPC, based on
the performance on other tasks and the recency of other night experience and
other night IMC experience.

>>
I agree completely that a combination of simulator and airplane time is
ideal, just like training in IMC is ideal. Does that mean an IPC should be
impossible to obtain in a flight training device or an IFR rating should be
impossible to obtain under the hood?
<<

No, of course not. But it should require a device that does what it needs to
do. If you use a simulator, it should simulate all the tasks. If the
simulator doesn't simulate all the tasks, this should be remedied by modifying
the simulator, not the tasks. Ditto if the hood doesn't work.

>>
the issue at hand is whether it is reasonable to
change the rules in the middle of the game
<<

It's always the middle of the game.

Jose


--
(for Email, make the obvious changes in my address)

"Barry" > wrote in message
...

> I don't see much difference from the current PTS - in fact it looks like
the
> new PTS actually requires fewer tasks for an IPC. The current PTS already
> requires a circling approach on an IPC, which seemed to be your biggest
> objection to the new PTS.

Do you have an online link to the current PTS?

As best I can tell it has been removed from the FAA website.

The newest PTS just released in April 2004 is numbered FAA-S-8081-4D

The prior one which I can locate was released in October 1998 and is
numbered FAA-S-8081-4C -- this seems to be the one immediately prior to the
April 2004 PTS by the FAA numbering system (i.e. 4D vs. 4C) and it is also
the newest version which was published with an ISBN number and available on
Amazon:

http://www.amazon.com/exec/obidos/tg/detail/-/1560273666/qid=1085630600/sr=8-2/ref=sr_8_xs_ap_i2_xgl14/102-5605544-0393734?v=glance&s=books&n=507846

This October 1998 PTS outlines a Circling Approach on page 1-15 but does not
list a "PC" to indicate that it is required on an instrument proficiency
check.

Was there a newer version of the IFR PTS which was issued in between with a
number betweeen 8081-4C and 8081-4D and which requires a circling approach?
If so, then I stand corrected in that regard but then I ask the question
regarding how in August 2003 my Level 3 FTD was granted authorization for an
instrument proficiency check and I ask the question regarding how the very
recently approved Advanced ATD devices have been approved for conducting an
instrument proficiency check.


--------------------
Richard Kaplan, CFII

www.flyimc.com

> Do you have an online link to the current PTS?
>
> Was there a newer version of the IFR PTS which was issued in between with a
> number betweeen 8081-4C and 8081-4D and which requires a circling approach?
> If so, then I stand corrected in that regard but then I ask the question
> regarding how in August 2003 my Level 3 FTD was granted authorization for an
> instrument proficiency check and I ask the question regarding how the very
> recently approved Advanced ATD devices have been approved for conducting an
> instrument proficiency check.

The current PTS is FAA-S-8081-4C with changes 1 and 2. Change 2 added the
Rating Task Table and was issued 3/11/99. I couldn't find it online so I
posted it on alt.binaries.pictures.aviation.

The question about FTD authorization for an IPC is interesting. The PTS
includes an appendix showing task credit for simulation devices, and the only
ones that count for circling approach or landing (both required for IPC
according to the Rating Task Table) are Levels C and D.

Barry

"Teacherjh" > wrote in message
...>

> The hood (badly) simulates IMC. How would you simulate a circling
approach?
> Anything which works would be ok with me (including a more expensive
simulator,
> or a real airplane). It is a task that should be tested.

There are two reasonably practical ways to simulate a circling approach in
an FTD or Advanced ATD, yet neither is "legal" for logging a circling
approach.

First, some devices (i.e. the Elite series Advanced ATD) allow the
instructor to switch the visuals between a left, forward, or right view at
the request of the pilot.

Second, an FTD with a moving map GPS, i.e. a Garmin 530, can display the
runway reasonably well enough to allow the pilot to maintain situational
awareness when not on final.

I think either of these techniques combined with night low IMC weather
conditions reasonably makes the point a pilot regarding the difficulty of
completing a low visibility circling approach.


> No, of course not. But it should require a device that does what it needs
to
> do. If you use a simulator, it should simulate all the tasks. If the

An FTD or Advanced ATD simulates all the tasks that were until recently
required on an IPC. What has changed is that the required tasks have now
been modified.

Historically very, very few simulators have been able to simulate "all" the
tasks. To this day many airline-quality true simulators only have night
visual displays with few if any ground references; such an advanced
simulator cannot be used for the very simple student pilot task of daytime
pilotage. Should we decide that such a simulator can no longer be used to
conduct an ATP 6-month line check? Would it be reasonable to add daytime
pilotage to the ATP line check and thus render the simulator incapable of
completing the task?

> It's always the middle of the game.

True, but how much notification is reasonable?

I suspect we will all be required to have Mode S transponders someday but I
am quite sure there would be an uproar if today it were announced that they
are required by October... ditto for any major airplane hardware requirement
which has been phased in by the FAA.


--------------------
Richard Kaplan, CFII

www.flyimc.com

"Barry" > wrote in message
...>

> The current PTS is FAA-S-8081-4C with changes 1 and 2. Change 2 added the
> Rating Task Table and was issued 3/11/99. I couldn't find it online so I
> posted it on alt.binaries.pictures.aviation.

Thank you... much appreciated.

In reviewing the original version 4C as well as changes 1 and 2, I think it
could reasonably be said that the "IPC task list" is the list of items from
which FAR 61.57 allows the instructor to select a "representative" number of
tasks. I believe that is how/why an IPC can be conducted today in an FTD or
advanced ATD without a circling approach; there is no explicit statement
that all of the IPC tasks must be included in an IPC, so I would conclude a
CFII has the discretion to select a representative number of the tasks from
the IPC task list.

The new "gotcha" item which grabs my attention in the new version 4D PTS is
the following on page 16 -- note in particular the last sentence which I
have quoted:

Instrument Proficiency Check. 14 CFR part 61.57(d) sets forth the
requirements for an instrument proficiency check. The person giving that
check shall use the standards and procedures contained in ths PTS when
administering the check. A representative number of TASKs, as determined by
the examiner/instructor, must be selected to assure the competence of the
applicant to operate in the IFR environment. As a minimum, the applicant
must demonstrate the ability to perform the TASKs as listed in the above
chart.


--------------------
Richard Kaplan, CFII

www.flyimc.com

<<all that is regulatory is that there be some number of tasks listed
in the PTS but the IPC task list is not regulatory? >>

Yes. I mean, why use the phraseology of "representative number of
tasks" if the actual list is spelled out? Obviously the framers of
the reg didn't anticipate the PTS saying explicity what to do.

Be interesting to solicit a letter of interp on this.

"Greg Esres" > wrote in message
...

> Yes. I mean, why use the phraseology of "representative number of
> tasks" if the actual list is spelled out? Obviously the framers of
> the reg didn't anticipate the PTS saying explicity what to do.

I think this gets PRECISELY to the heart of the matter.

As I mentioned as well elsewhere in this thread, the new PTS effective in
October does indeed now try to supercede the FARs by stating explicitly how
to perform an IPC -- read the last sentence of this quote from the newest
PTS:

Instrument Proficiency Check. 14 CFR part 61.57(d) sets forth the
requirements for an instrument proficiency check. The person giving that
check shall use the standards and procedures contained in ths PTS when
administering the check. A representative number of TASKs, as determined by
the examiner/instructor, must be selected to assure the competence of the
applicant to operate in the IFR environment. As a minimum, the applicant
must demonstrate the ability to perform the TASKs as listed in the above
chart.

> Be interesting to solicit a letter of interp on this

Yes, it would be interesting.

--------------------
Richard Kaplan, CFII

www.flyimc.com

> In reviewing the original version 4C as well as changes 1 and 2, I think it
> could reasonably be said that the "IPC task list" is the list of items from
> which FAR 61.57 allows the instructor to select a "representative" number of
> tasks. I believe that is how/why an IPC can be conducted today in an FTD or
> advanced ATD without a circling approach; there is no explicit statement
> that all of the IPC tasks must be included in an IPC, so I would conclude a
> CFII has the discretion to select a representative number of the tasks from
> the IPC task list.
>
> The new "gotcha" item which grabs my attention in the new version 4D PTS is
> the following on page 16 -- note in particular the last sentence which I
> have quoted:
>
> Instrument Proficiency Check. 14 CFR part 61.57(d) sets forth the
> requirements for an instrument proficiency check. The person giving that
> check shall use the standards and procedures contained in ths PTS when
> administering the check. A representative number of TASKs, as determined by
> the examiner/instructor, must be selected to assure the competence of the
> applicant to operate in the IFR environment. As a minimum, the applicant
> must demonstrate the ability to perform the TASKs as listed in the above
> chart.

The old PTS doesn't include that wording, but on page 3 it says:

"Applicants for an instrument proficiency check required by 14 CFR section
61.57, must perform to the standards of the TASKS listed under PC in the
Rating Task Table on page 15."

The FAA's Part 61 FAQ (http://www.faa.gov/avr/afs/afs800/docs/pt61FAQ.doc)
says :

----------------------
QUESTION: Request guidance on the meaning/intent of the wording ". . . a
representative number of tasks. . ."

ANSWER: Ref. § 61.57(d): First of all, neither the regulation nor the preamble
of the regulation covers what you're asking. The answer is to be found in the
Instrument Rating Practical Test Standards, FAA-S-8081-4C on page 15 of the
Introduction (effective with change 2 as of 03/11/99). The right hand column
of the Rating Task Table indicates the required Tasks for the Areas of
Operation.

Historically, the wording ". . .a representative number of tasks . . ."
requires an objective decision to be made by the CFII/examiner that is
dependent on the applicant's ability. If it becomes obvious during the conduct
of the instrument proficiency check that a pilot who has not flown instruments
in over a year or more is extremely weak, then the check may need to be more
extensive than the required list. The CFII/examiner needs to be able to say at
the conclusion of the check that yes this pilot can operate safely in the
national airspace system.
--------------------

These both indicate to me that the FAA intends for the IPC to require all of
the listed items. However, it's not clear that this is legally binding on a
CFII. Page 1 of the current PTS says:

"The Flight Standards Service of the Federal Aviation Administration (FAA) has
developed this practical test standards book to be used by FAA inspectors and
designated pilot examiners when conducting instrument rating—airplane,
helicopter, and powered lift practical tests, and instrument proficiency
checks for all aircraft."

There's no mention of instructors, so one could argue that it's mandatory for
examiners but not plain old CFIIs. I have been treating it as mandatory.

I suppose you could ask your local FSDO (who I assume approved your FTD) for
their interpretation, but you might not like the answer you get.

Barry

"Barry" > wrote in message
...>

> There's no mention of instructors, so one could argue that it's mandatory
for
> examiners but not plain old CFIIs. I have been treating it as mandatory.

Interesting.. the latest version of the PTS seems even more permissive in
that regard:

-------------------------

FAA inspectors and designated pilot examiners shall conduct practical tests
in compliance with these standards. Flight instructors and applicants
should find these standards helpful during training and when preparing for
practical tests.

-------------------------


This preamble seems to imply that the PTS is just a helpful reference,
presumably a reference from which to draw "representative tasks" per 61.57.



--------------------
Richard Kaplan, CFII

www.flyimc.com

"Barry" > wrote in message
...

> These both indicate to me that the FAA intends for the IPC to require all
of
> the listed items. However, it's not clear that this is legally binding on
a
> CFII. Page 1 of the current PTS says:

If all the listed items were legally binding on a CFII, then a huge number
of IPCs issued by FlightSafety, Simcom, and RTC since 1999 would be invalid
because landing out of an approach is required, yet only Level C and Level D
simulators qualify to log landings according to the chart at the end of the
1999 PTC.


--------------------
Richard Kaplan, CFII

www.flyimc.com

>>
First, some devices (i.e. the Elite series Advanced ATD) allow the
instructor to switch the visuals between a left, forward, or right view at
the request of the pilot.

Second, an FTD with a moving map GPS, i.e. a Garmin 530, can display the
runway reasonably well enough to allow the pilot to maintain situational
awareness when not on final.

I think either of these techniques combined with night low IMC weather
conditions reasonably makes the point a pilot regarding the difficulty of
completing a low visibility circling approach.
<<

I've never used an "official" sim, just Microsoft FS 2002 on my computer. That
said...'

Switching visuals that remain in front of me is no simulation of looking around
the cockpit. The visuals have to be in their proper places, and continuous.
And as for including a GPS, that doesn't do anything for simulating the
transition from IMC to visual. I don't understand your second point at all.

And the idea isn't to "make the point" about the difficulty of circling
approaches. It is to TEST the pilot and see how well he or she does.

>>
Would it be reasonable to add daytime
pilotage to the ATP line check and thus
render the simulator incapable of
completing the task?
<<

If daytime pilotage competence were a problem with airline transport pilots,
yes. Otherwise, if those skills can be reasonably inferred from the completion
of other tasks, no.

>>
I suspect we will all be required to have Mode S transponders someday but I
am quite sure there would be an uproar if today it were announced that they
are required by October.
<<

Apples and oranges. The sim thing has to do with currency checks only. Mode S
affects flying itself. You are just complaining that your profit center got
weaker.

Jose


--
(for Email, make the obvious changes in my address)

"Teacherjh" > wrote in message
...>

> Apples and oranges. The sim thing has to do with currency checks only.
Mode S
> affects flying itself. You are just complaining that your profit center
got
> weaker.

The underlying concept is far more significant and widespread than just my
particular business model -- it affects everyone involved in any area of
aviation.

Actually, my particular business model would be minimally affected even if
there were a definitive ruling that the PTS is binding upon a CFII; most of
my students are within 6 months of currency so using my FTD to log IFR
Currency would serve the same purpose as an IPC, and I also try to fly in an
airplane with my students whenever possible in addition to the FTD.

The much bigger issue though is the question of the the FAA arbitrarily and
on relatively short notice changing some standard or rule in the name of
safety. What if they all of a sudden required all A&P mechanics to have a
repair station license and prohibited indepdendent A&Ps? What if they
prohibited Part 61/91 training and required all instruction to be in a Part
141/142 environment? What if they decided as of next year your airplane had
to be modified to meet today's certification requirements instead of the
requirements as of the day your airplane received its type certificate? You
could make an argument in the name of "safety" for all of these situations.


--------------------
Richard Kaplan, CFII

www.flyimc.com

"Richard Kaplan" > wrote
> (1) By granting discretion to a CFII, an IPC can currently serve not only
> as a proficiency check but also as an opportunity for instruction or for a
> pilot to try a new skill relevant to his IFR operations.

True. On the other hand, it can also allow a CFII to sign off an ICC
that consists of a single full-panel vectors-to-final ILS approach.
I've seen it done. There is a very real reason why the discretion
CFII's have on an IPC has been reduced - too many CFII's were abusing
it, and signing off people who did not meet even the very minimal PTS
standards. In fact, I would argue that those CFII's were always far
more numerous than those who made the IPC a true advanced training
experience. This is always the problem with rules - removing the
discretion assures some minimum standard for those doing it wrong, at
the expense of making things worse for those genuinely trying to do it
right. Once you accept that having rules is a good thing (I don't),
it's a bit late to argue that a new rule change removes too much of
your discretion.

> (2) Recently the FAA granted approval to a new class of inexpensive
> training device called an Advanced ATD - An Advanced ATD is a PC
> computer-based trainer approved among other purposes to conduct an entire
> Instrument Proficiency Check, and an Advanced ATD is much less expensive
> than more traditional full-scale Flight Training Devices or Simulators. An
> Advanced ATD will no longer be able to function to conduct an entire IPC
> because no Advanced ATD is approved for circling approaches.

Yeah, that's rough. Some aviation businesses/individuals made
investments in equipment whose capability was reduced due to FAA fiat.
However, once you accept that it's legitimate for the FAA to change
the rules, such as by issuing emergency AD's, (and again I don't) it's
a little too late to make the argument that people who made
investments assuming the old rules would apply are now hurt
financially. Think of all the people who bought T-34's, complied with
the first series of AD's, and now have had the value of their
investment dramatically reduced - all because of an accident that
occurred to a T-34 that DID NOT have the AD's complied with and was
probably being operated outside the design envelope in any case.

> (4) Is it desirable for the FAA to require IFR pilots to practice circling
> approaches at every IPC?

I think this is really the crux of the issue, and the only valid point
you have made. Is recurrent training on circling approaches a
safety-critical issue? I think it's worth exploring in detail.

> High visibility circling approaches are far less
> critical a skill to maintain than flying a partial panel non-precision
> approach.

I agree completely, but the partial panel non-precision approach is
also required.

> Low visibility circling approaches are risky enough that many
> corporate and airline flight departments do not permit such approaches.

I concur with your observation but not with your reasoning. The
elimination of low visibility circling approaches dates to the time
when training in the airplane was superseded by training in the
simulator. The simulators of the time simply didn't have adequate
visuals to realistically simulate circling approaches. Nobody really
wanted to keep training in the airplanes for financial reasons, and
circling approaches were not considered important for the kinds of
destinations the airlines served.

Those corporate flight departments that have a need to serve airports
where circle to land is often required train for them and do them;
those that don't have a need don't bother.

Circling approaches are inherently more difficult to do, and provide a
reduced margin of error, in heavier and faster airplanes with poor
outside visibility. They are not all that difficult to do in the
light piston airplanes we fly, and in fact lots of corporate flight
departments that operate piston singles and twins train for and allow
circling approaches.

> By
> requiring circling approaches at each IPC, will we be encouraging a circling
> approach as a "normal" IFR procedure alongside straight-in ILS approaches?

At my home field, a circling approach is a normal IFR procedure - in
fact the only IFR procedure available. Such airports are non-existent
for the airlines, rare for major corporate flight departments, but
quite common for GA use. Further, while GPS may eliminate this out in
the boonies, it will never do so in major metropolitan areas where the
position of the final approach course is all about minimizing impact
on the major Class B fields.

Therefore, I forsee the necessity for circling approaches extending
into the forseeable future, and thus think that recurrent training in
them is important. It is certainly a part of my recurrent training
cycle, under maximally adverse conditions (single engine and partial
panel). I do not consider it unreasonable to include the circling
approach as an IPC requirements.

Michael

>> What if ....

Then I would have a separate opinion on each of these proposals. Some I might
favor, some I might not. However the thrust of the original post is that it
impacts the business of simulator IPCs. I don't have much sympathy for that.

Jose

--
(for Email, make the obvious changes in my address)

"Michael" > wrote in message
om...>

> experience. This is always the problem with rules - removing the
> discretion assures some minimum standard for those doing it wrong, at
> the expense of making things worse for those genuinely trying to do it
> right. Once you accept that having rules is a good thing (I don't),
> it's a bit late to argue that a new rule change removes too much of
> your discretion.

I do not think there is any profession that has been improved by removing
discretion or judgment.

Come to think of it, maybe that is why this new PTS hit such a nerve with
me -- it seems as if the FAA is starting to micro-manage CFIs just like
managed care tries to micro-manage my judgment as a physician. Neither is
likely to improve the quality of the underlying service.

CFIs who will sign off an IPC today based on only a vectored ILS will still
do so after October 1 and would still do so even if 61.57(d) were made more
restrictive; limiting CFI judgment only hurts those CFIs who are trying to
do it right to the best of their ability and judgment.

While we are at it though, why not require specific tasks for a BFR as well
as an IPC?


--------------------
Richard Kaplan, CFII

www.flyimc.com

"Michael" > wrote in message
om...>

> Therefore, I forsee the necessity for circling approaches extending
> into the forseeable future, and thus think that recurrent training in
> them is important. It is certainly a part of my recurrent training

How helpful do you think practicing a circling approach on a CAVU day is in
preparing you to fly a circling approach on a low visibility day?

Circling in CAVU weather is basically a matter of flying a tight pattern at
a lower than usual pattern altitude. There is somewhat of a learning curve
needed especially in a hilly or mountainous area, but this is not
particularly challenging in my opinion for it to take precedence over any
number of other items not mandated in the new PTS.

On the other hand, a circling approach in low visibility is indeed a
challenge even in a piston airplane. One of the reasons it is a challenge
is that it is so difficult to train for this effectively either in the
airplane or in a piston FTD/simulator. I do not think the new PTS solves
this problem.



--------------------
Richard Kaplan, CFII

www.flyimc.com

"Richard Kaplan" > wrote
> I do not think there is any profession that has been improved by removing
> discretion or judgment.

I don't disagree. However, it's a mistake to call the average CFII a
professional. He is at best an apprentice.

> Come to think of it, maybe that is why this new PTS hit such a nerve with
> me -- it seems as if the FAA is starting to micro-manage CFIs just like
> managed care tries to micro-manage my judgment as a physician. Neither is
> likely to improve the quality of the underlying service.

I don't think this is the same thing at all - after all, the goal of
managed care is reduced cost. Quality is irrelevant. The goal here
is to improve quality, and the need is real. The solution, like most
FAA solutions, is incompetent. Remember when the decision was made to
have all initial CFI rides done with the FAA?

> CFIs who will sign off an IPC today based on only a vectored ILS will still
> do so after October 1 and would still do so even if 61.57(d) were made more
> restrictive

That's the one area where I do not concur. I think that setting out
specific rules will stop that in most cases. It won't stop the CFII
willing to lie to sign off his buddy (you would be amazed how many
BFR's are done in a bar rather than an airplane, though I know of no
ICC's being done that way - yet) but it will stop the CFII who doesn't
know any better.

> While we are at it though, why not require specific tasks for a BFR as well
> as an IPC?

It would not surprise me in the least if this were to happen.

Michael

"Richard Kaplan" > wrote
> How helpful do you think practicing a circling approach on a CAVU day is in
> preparing you to fly a circling approach on a low visibility day?

Better than nothing, but far from optimal. On the other hand, you can
get about a 90% simulation on an overcast night with a little haze
and/or mist. Even a clear night gets you a good simulation if you
pick your airport carefully (meaning in a poorly lit area).

> Circling in CAVU weather is basically a matter of flying a tight pattern at
> a lower than usual pattern altitude. There is somewhat of a learning curve
> needed especially in a hilly or mountainous area, but this is not
> particularly challenging in my opinion for it to take precedence over any
> number of other items not mandated in the new PTS.

I have two issues with this argument. First, there is the transition
issue. There's a pretty big difference between circling in a
Skyhawk-class airplane and a Bonanza-class airplane, and much of that
difference can be taught in CAVU. Practically all of it can be taught
at night.

Second, I can't think of anything more important than circling (even
in CAVU) that is not already required.

> On the other hand, a circling approach in low visibility is indeed a
> challenge even in a piston airplane. One of the reasons it is a challenge
> is that it is so difficult to train for this effectively either in the
> airplane or in a piston FTD/simulator. I do not think the new PTS solves
> this problem.

The FAA doesn't ever solve problems. At best, by taking action it
might raise awareness that the problem exists without making it
substantially worse. The new PTS has, in fact, raised awareness -
people are discussing this, and that's positive. The question is, has
the FAA made the problem substantially worse. I'm not sure about
that. I doubt that the people getting recurrent sim training really
NEED an IPC from a regulatory standpoint anyway, so I doubt much
damage is being done.

Michael

"Richard Kaplan" > wrote in message >...
> The FAA has just released a revised version of the instrument rating
> practical test standards to become effective October 1, 2004:
>
>
>
> http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-4d.pdf
>
>
>
> Included in the footnotes of this new PTS is a substantial change in the
> requirements for an Instrument Proficiency Check.
>
>
>
> Currently a CFII conducting an IPC is permitted to use his discretion in
> asking a pilot to demonstrate a reasonable selection of items from the PTS.
> This seems reasonable in order to adjust the IPC to pilot
> strengths/weaknesses which are perceived by either the pilot

My PTS that is almost 4 years old had this. I think this has always
been there, I think people just haven't noticed. You need to look at
the table that talks about what items have to be done for an airplane
instrument if you already have a rotocraft instrument. There is
another table called PC that is for IPC. It spells out the IPC pretty
easily.

-Robert, CFI

(Michael) wrote in message >...
> "Richard Kaplan" > wrote
> > (1) By granting discretion to a CFII, an IPC can currently serve not only
> > as a proficiency check but also as an opportunity for instruction or for a
> > pilot to try a new skill relevant to his IFR operations.
>
> True. On the other hand, it can also allow a CFII to sign off an ICC
> that consists of a single full-panel vectors-to-final ILS approach.
> I've seen it done. There is a very real reason why the discretion
> CFII's have on an IPC has been reduced - too many CFII's were abusing
> it, and signing off people who did not meet even the very minimal PTS
> standards.


I"m not sure how far back you're going. My IFR PTS is pretty old but
still includes a table of things required for a PC. I think that a lot
of CFIIs just didn't know what an IPC was.

-Robert, CFI

"Richard Kaplan" > wrote in message >...
> The FAA has just released a revised version of the instrument rating
> practical test standards to become effective October 1, 2004:
>
>
>
> http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-4d.pdf
>
>
>
> Included in the footnotes of this new PTS is a substantial change in the
> requirements for an Instrument Proficiency Check.
>

Hey, it looks like they greatly reduced the items required for an IPC.
The old IFR PTS included a lot more items on the proficiency check!
This will make IPCs go much faster.

Our local DE claims the FAA is working on a PTS standard for BFRs
right now. It will be from the private/commercial PTS. That will mean
that a commercial rated pilot will have a higher standard BFR than a
private.
-Robert

Robert:

I mentioned this same thing when the thread was new, however my
comments fell on deaf ears. There has even been an article on Avweb
stating how the "new requirements" will impact the process. The
process has been in place since 1999 when the task pable came into
existance. Yes, the IPC is actually being relaxed as of October, not
expanded, as the original poster stated. Just shows you how alert
some of the CFII's are. There has not been any descretion in the IPC
process for a long time. As it stands now, an IPC is an instrument
practical test in it's entirety except for X-C flight planning, WX
information, timed turns, and steep turns. The dreaded circling
approach is nothing new in the requirement. The IPC is an open book
test, but nobody is reading the book.


On 4 Jun 2004 21:42:28 -0700, (Robert M. Gary) wrote:

(Michael) wrote in message >...
>> "Richard Kaplan" > wrote
>> > (1) By granting discretion to a CFII, an IPC can currently serve not only
>> > as a proficiency check but also as an opportunity for instruction or for a
>> > pilot to try a new skill relevant to his IFR operations.
>>
>> True. On the other hand, it can also allow a CFII to sign off an ICC
>> that consists of a single full-panel vectors-to-final ILS approach.
>> I've seen it done. There is a very real reason why the discretion
>> CFII's have on an IPC has been reduced - too many CFII's were abusing
>> it, and signing off people who did not meet even the very minimal PTS
>> standards.
>
>
>I"m not sure how far back you're going. My IFR PTS is pretty old but
>still includes a table of things required for a PC. I think that a lot
>of CFIIs just didn't know what an IPC was.
>
>-Robert, CFI

> > The FAA has just released a revised version of the instrument rating
> > practical test standards to become effective October 1, 2004:
> >
> > http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-4d.pdf

Does anybody know where I can download the current instrument PTS, i.e.
the one that's effective today?

"Roy Smith" > wrote in message
...
> > > The FAA has just released a revised version of the instrument rating
> > > practical test standards to become effective October 1, 2004:
> > >
> > > http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-4d.pdf
>
> Does anybody know where I can download the current instrument PTS, i.e.
> the one that's effective today?

I have put it here
http://www.quantity-surveyor.org.uk/AC61-111A.pdf

In article >,
"S Green" > wrote:

> http://www.quantity-surveyor.org.uk/AC61-111A.pdf

Thanks

Roy: If your email address is legit, it should be in your inbox. If
not, email me. I have it. Enjoy!

Bill


On Sat, 05 Jun 2004 18:11:17 -0400, Roy Smith > wrote:

>> > The FAA has just released a revised version of the instrument rating
>> > practical test standards to become effective October 1, 2004:
>> >
>> > http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-4d.pdf
>
>Does anybody know where I can download the current instrument PTS, i.e.
>the one that's effective today?

"Robert M. Gary" > wrote in message
om...>

> I"m not sure how far back you're going. My IFR PTS is pretty old but
> still includes a table of things required for a PC. I think that a lot
> of CFIIs just didn't know what an IPC was.

The difference is that the prior PTS versions did not state that all the IPC
items in the table are required for an IPC; thus a reasonable interpretation
has been that 61.57(d) givet a CFII the discretion to choose among those
items.

The newest PTS now explicitly states that all IPC items in the table must be
included in an IPC.



--------------------
Richard Kaplan, CFII

www.flyimc.com

"Bill Zaleski" > wrote in message
...>

> some of the CFII's are. There has not been any descretion in the IPC
> process for a long time. As it stands now, an IPC is an instrument

The current PTS does NOT explicitly state that all IPC items in the task
list are required. The newest PTS effective in October DOES state that;
thus it is a substantial change IF one is of the opinion that the PTS is
regulatory instead of advisory.



--------------------
Richard Kaplan, CFII

www.flyimc.com

--
--------------------
Richard Kaplan, CFII

www.flyimc.com
"Robert M. Gary" > wrote in message
om...
> "Richard Kaplan" > wrote in message
>...
> > The FAA has just released a revised version of the instrument rating
> > practical test standards to become effective October 1, 2004:
> >
> >
> >
> > http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-4d.pdf
> >
> >
> >
> > Included in the footnotes of this new PTS is a substantial change in the
> > requirements for an Instrument Proficiency Check.
> >
>
> Hey, it looks like they greatly reduced the items required for an IPC.
> The old IFR PTS included a lot more items on the proficiency check!
> This will make IPCs go much faster.
>
> Our local DE claims the FAA is working on a PTS standard for BFRs
> right now. It will be from the private/commercial PTS. That will mean
> that a commercial rated pilot will have a higher standard BFR than a
> private.
> -Robert

"Robert M. Gary" > wrote in message
om...>

> Hey, it looks like they greatly reduced the items required for an IPC.
> The old IFR PTS included a lot more items on the proficiency check!
> This will make IPCs go much faster.

No, it won't.

Previously the large list was a list from which a CFII could choose
representative items per 61.57(d).

The newest PTS has a new and explicit statement that all IPC items in the
list are required.

--------------------
Richard Kaplan, CFII

www.flyimc.com

In article >,
"Richard Kaplan" > wrote:

> "Robert M. Gary" > wrote in message
> om...>
>
> > I"m not sure how far back you're going. My IFR PTS is pretty old but
> > still includes a table of things required for a PC. I think that a lot
> > of CFIIs just didn't know what an IPC was.
>
> The difference is that the prior PTS versions did not state that all the IPC
> items in the table are required for an IPC; thus a reasonable interpretation
> has been that 61.57(d) givet a CFII the discretion to choose among those
> items.
>
> The newest PTS now explicitly states that all IPC items in the table must be
> included in an IPC.

I seem to remember there used to be wording to the effect that an
ICC/IPC needed to include a "representative sample" of the PTS checkride
tasks. I can't remember if that was in the PTS itself or part 61/91
somewhere. Or maybe it's just a faulty memory circuit?

That being said, I'm about to give my first IPC in an plane with an
approach certified GPS. I spent some time re-reading the PTS to make
sure my plan is up to snuff, and here's what I came up with for the
flight portion:

------------
Two flight legs, each with full route clearance on ground, flight to
another airport, at least one approach, and full stop landing. One
leg done with NAV radio only, another with GPS.

VOR leg will include airway intercept and tracking, partial panel VOR
approach, p/p missed, and p/p hold. Partial panel unusual attitudes.
Full panel ILS to a full stop.

GPS leg will include programming flight plan, constant airspeed and
rate climbs and descents, in-flight reroute, GPS approach, full
procedure, circle-to-land to a full stop.
------------

The rest of the PTS material will be covered in the oral.

The bizarre thing is that, AFAICT, the PTS lets me have the guy do a
VOR, LOC, and ILS, and never touch the GPS once. Given that all our club
planes are now equipped with approach-certified GPS, I just can't see
doing that. The hard question is where to draw the line.

If I require a GPS approach at all, the PTS would be perfectly happy to
have us punch in Direct Destination and get vectors to the approach.
But that only exercises a miniscule portion of what you really need to
know to fly IFR with the box. I think the selection of GPS tasks listed
above is a reasonable compromise, but it still leaves a lot untouched.
I guess at some point you need to trust the checkee's PIC judgement to
practice on his own and not attempt things in IMC that are beyond his
abilities.

Roy Smith wrote:

> In article >,
> "Richard Kaplan" > wrote:
>
>
>>"Robert M. Gary" > wrote in message
om...>
>>
>>>I"m not sure how far back you're going. My IFR PTS is pretty old but
>>>still includes a table of things required for a PC. I think that a lot
>>>of CFIIs just didn't know what an IPC was.
>>
>>The difference is that the prior PTS versions did not state that all the IPC
>>items in the table are required for an IPC; thus a reasonable interpretation
>>has been that 61.57(d) givet a CFII the discretion to choose among those
>>items.
>>
>>The newest PTS now explicitly states that all IPC items in the table must be
>>included in an IPC.
>
>
> I seem to remember there used to be wording to the effect that an
> ICC/IPC needed to include a "representative sample" of the PTS checkride
> tasks. I can't remember if that was in the PTS itself or part 61/91
> somewhere. Or maybe it's just a faulty memory circuit?
>
> That being said, I'm about to give my first IPC in an plane with an
> approach certified GPS. I spent some time re-reading the PTS to make
> sure my plan is up to snuff, and here's what I came up with for the
> flight portion:
>
> ------------
> Two flight legs, each with full route clearance on ground, flight to
> another airport, at least one approach, and full stop landing. One
> leg done with NAV radio only, another with GPS.
>
> VOR leg will include airway intercept and tracking, partial panel VOR
> approach, p/p missed, and p/p hold. Partial panel unusual attitudes.
> Full panel ILS to a full stop.
>
> GPS leg will include programming flight plan, constant airspeed and
> rate climbs and descents, in-flight reroute, GPS approach, full
> procedure, circle-to-land to a full stop.
> ------------
>
> The rest of the PTS material will be covered in the oral.
>
> The bizarre thing is that, AFAICT, the PTS lets me have the guy do a
> VOR, LOC, and ILS, and never touch the GPS once. Given that all our club
> planes are now equipped with approach-certified GPS, I just can't see
> doing that. The hard question is where to draw the line.
>
> If I require a GPS approach at all, the PTS would be perfectly happy to
> have us punch in Direct Destination and get vectors to the approach.
> But that only exercises a miniscule portion of what you really need to
> know to fly IFR with the box. I think the selection of GPS tasks listed
> above is a reasonable compromise, but it still leaves a lot untouched.
> I guess at some point you need to trust the checkee's PIC judgement to
> practice on his own and not attempt things in IMC that are beyond his
> abilities.

Based on my flight yesterday, depending on which GPS you have, I'd want
to see the approach with the IAF being the fix in the middle of the "T",
and I'd want to see the MAP flown as well rather than a full stop
landing. The reason being that, at least with the King 89B radio, there
are a couple of things that come into play in these two circumstances.
If you fly to one of the fixes at the ends of the "T", you don't fly the
PT for reversal an thus can fly the approach in leg mode. This is very
straightforward. However, to fly a course reversal you must enter OBS
mode prior to arriving at the IAF. If you don't, it gets very
confusing. Same with flying the missed. The 89B stops autosequencing
at the MAP and you have to manually select the fix that defines the
hold. These are both easy to overlook in the heat of battle. :-)


Matt

"Roy Smith" > wrote in message
...>

> I seem to remember there used to be wording to the effect that an
> ICC/IPC needed to include a "representative sample" of the PTS checkride
> tasks. I can't remember if that was in the PTS itself or part 61/91

That wording is in 61.57(d). If the PTS is advisory and not binding, then
the CFII's discretion will not have been significantly hampered.

On Mon, 07 Jun 2004 02:30:39 GMT, "Richard Kaplan"
> wrote:

>
>
>
>"Roy Smith" > wrote in message
...>
>
>> I seem to remember there used to be wording to the effect that an
>> ICC/IPC needed to include a "representative sample" of the PTS checkride
>> tasks. I can't remember if that was in the PTS itself or part 61/91
>
>That wording is in 61.57(d). If the PTS is advisory and not binding, then
>the CFII's discretion will not have been significantly hampered.
>
>
The current FAR 61,57(d) was last revised in 1997. The change 2 of
the current PTS became effective in March 1999. AFS 640, the branch
of the FAA that sets training policy, told me during the last examiner
recertification seminar that the PTS is binding, and the task table
provided within sets the minimum areas of operation required to
complete an IPC. The term "representative tasks" are not at the
descretion of the CFI, but are the tasks already set out and dictated
by the task table. Nothing has changed with the upcomming change of
the task table except that the tasks have been reduced, not increased.

Don't take my word for it, call Oak City if you like, but don't hide
your head in the sand and say it isn't so out of wishful thinking. To
say that a Practical test STANDARD is not binding is laughable. Read
the top of the current task table. It specifically states which tasks
are required and MUST be tested during an IPC. You just never read it
before.

"Bill Zaleski" > wrote in message
...>

> the current PTS became effective in March 1999. AFS 640, the branch
> of the FAA that sets training policy, told me during the last examiner
> recertification seminar that the PTS is binding, and the task table

Bill,

The question of whether the PTS is legally binding upon a CFII is a bit more
complex than this, as is often the case for areas where law and
administrative regulations overlap.


Your answer is sort of like saying you called a specific division of the IRS
for a ruling on a complex taxation and that gave you a definitive answer.
Actually, getting a definitive answer on federal tax regulations is quite
complex and often has gray areas until a court reaches a final decision.
Sometimes courts even give different answers in different districts around
the country.

It is very clear that the Advanced ATD concept was introduced after the 1999
PTS and that the Advanced ATD was intended for completing a full IPC. Yet
if the PTS is considered to be legally binding, the Advanced ATD cannot be
used for an IPC because a literal interpretation of the PTS requires landing
out of an approach for an IPC, yet no Advanced ATD and no FTD is approved
for landings. Thus if the PTS is legally binding then a huge percentage of
piston IPCs done at virtually every major simulator center in the past 5
years are invalid. And if the PTS is legally binding then the whole concept
of approving the Advanced ATD is inconsistent within the FAA's regulatory
framework.

I think the best answer is that there are some unclear or gray areas here
which need to be resolved.

Saying the PTS is obviously legally binding rather than advisory is like
saying the AIM is obviously legally binding. Do you believe items in the
AIM are advisory or binding?



--------------------
Richard Kaplan, CFII

www.flyimc.com

>>
Do you believe items in the
AIM are advisory or binding?
<<

They are advisory until there is an accident. Then they were binding.

I say this tongue in cheek, but it does seem to be the FAA way.

Jose

--
(for Email, make the obvious changes in my address)

Roy Smith > wrote in message >...
> In article >,
> "Richard Kaplan" > wrote:
>
> > "Robert M. Gary" > wrote in message
> > om...>
> >
> > > I"m not sure how far back you're going. My IFR PTS is pretty old but
> > > still includes a table of things required for a PC. I think that a lot
> > > of CFIIs just didn't know what an IPC was.
> >
> > The difference is that the prior PTS versions did not state that all the IPC
> > items in the table are required for an IPC; thus a reasonable interpretation
> > has been that 61.57(d) givet a CFII the discretion to choose among those
> > items.
> >
> > The newest PTS now explicitly states that all IPC items in the table must be
> > included in an IPC.
>
> I seem to remember there used to be wording to the effect that an
> ICC/IPC needed to include a "representative sample" of the PTS checkride
> tasks. I can't remember if that was in the PTS itself or part 61/91
> somewhere. Or maybe it's just a faulty memory circuit?
>
> That being said, I'm about to give my first IPC in an plane with an
> approach certified GPS. I spent some time re-reading the PTS to make
> sure my plan is up to snuff, and here's what I came up with for the
> flight portion:


Actually, if you read the current PTS, you will notice that in the
table of tasks to be done, there is a column for IPC. Today, the PTS
spells out the IPC. You can call AOPA and hear it for yourself. Of
course you can argue the PTS is not regulatory. One guy tried to argue
that the AIM wasn't regulatory too. The NASA admin law judge didn't
seem to buy that story either. Right or wrong doesn't make any
difference, its all what the judge is going to say when you plead to
keep your ticket.

-Robert

"Robert M. Gary" > wrote in message
om...>

> Actually, if you read the current PTS, you will notice that in the
> table of tasks to be done, there is a column for IPC. Today, the PTS
> spells out the IPC. You can call AOPA and hear it for yourself. Of

There is nothing in the current PTS which states that the ENTIRE table has
to be conducted on every IPC; 61.57(d) allows a CFII the discretion to
select representative tasks from that list.


--------------------
Richard Kaplan, CFII

www.flyimc.com

"Bill Zaleski" > wrote in message
...>


> recertification seminar that the PTS is binding, and the task table
> provided within sets the minimum areas of operation required to
> complete an IPC. The term "representative tasks" are not at the

I have now spoken with most of the simulator/FTD manufacturers in the
industry. The consensus overall based upon multiple contact with various
FAA sources is that existing FTDs will remain legal for a full IPC. The
basis for this is that in the newest PTS there is a footnote to Appendix 1-1
indicating that FTDs which are now operating via a letter from the FAA
Administrator may continue to be used for their original acceptable use. In
other words, my FTD was originally approved for an IPC and therefore it will
remain approved for an IPC even with then new PTS goes into effect.


--------------------
Richard Kaplan, CFII

www.flyimc.com

(Robert M. Gary) wrote
> One guy tried to argue that the AIM wasn't regulatory too.
> The NASA admin law judge didn't seem to buy that story either.
> Right or wrong doesn't make any difference, its all what the
> judge is going to say when you plead to keep your ticket.

NASA law judge????? I trust that you meant to say "the NTSB
administrative law judge".....right?

Bob Moore

It appears that there is a written basis to support an IPC containing a
representative number of items from the PTS rather than the complete list.

The inspector's handbook 8700.1 allows approval of a Level 1 FTD (clearly
not approved for circling approaches or for landing out of an instrumetn
approach) to be used for a COMPLETE IPC. This order remains valid today
with the current PTS:


--
--------------------
Richard Kaplan, CFII

www.flyimc.com
"Bill Zaleski" > wrote in message
...
> Robert:
>
> I mentioned this same thing when the thread was new, however my
> comments fell on deaf ears. There has even been an article on Avweb
> stating how the "new requirements" will impact the process. The
> process has been in place since 1999 when the task pable came into
> existance. Yes, the IPC is actually being relaxed as of October, not
> expanded, as the original poster stated. Just shows you how alert
> some of the CFII's are. There has not been any descretion in the IPC
> process for a long time. As it stands now, an IPC is an instrument
> practical test in it's entirety except for X-C flight planning, WX
> information, timed turns, and steep turns. The dreaded circling
> approach is nothing new in the requirement. The IPC is an open book
> test, but nobody is reading the book.
>
>
> On 4 Jun 2004 21:42:28 -0700, (Robert M. Gary) wrote:
>
> (Michael) wrote in message
>...
> >> "Richard Kaplan" > wrote
> >> > (1) By granting discretion to a CFII, an IPC can currently serve not
only
> >> > as a proficiency check but also as an opportunity for instruction or
for a
> >> > pilot to try a new skill relevant to his IFR operations.
> >>
> >> True. On the other hand, it can also allow a CFII to sign off an ICC
> >> that consists of a single full-panel vectors-to-final ILS approach.
> >> I've seen it done. There is a very real reason why the discretion
> >> CFII's have on an IPC has been reduced - too many CFII's were abusing
> >> it, and signing off people who did not meet even the very minimal PTS
> >> standards.
> >
> >
> >I"m not sure how far back you're going. My IFR PTS is pretty old but
> >still includes a table of things required for a PC. I think that a lot
> >of CFIIs just didn't know what an IPC was.
> >
> >-Robert, CFI
>

This is the text in the inspector's handbook authorizing use of an FTD for a
COMPLETE IPC -- it remains valid today.


B. For use under 14 CFR§ 61.57(d)(1)(ii). Regulatory authorization for pilot
use of a level 1 FTD to conduct all or part of an instrument competency
check, consisting of a representative number of tasks required for the
instrument rating practical test when given by an authorized instructor:
. Aviation Simulation Technology, Inc.: AST 201 and 300 Models
. ATC Flight Simulator Company: ATC 112H, 610, 710, 810, and 920 Models
. Frasca International, Inc.: 121, 122, 131, 132, 141, 142, 241, 242,
242T, and 342 Models
. Pacer Systems Corporation: MK II Models


--------------------
Richard Kaplan, CFII

www.flyimc.com

> I have now spoken with most of the simulator/FTD manufacturers in the
> industry. The consensus overall based upon multiple contact with various
> FAA sources is that existing FTDs will remain legal for a full IPC. The
> basis for this is that in the newest PTS there is a footnote to Appendix 1-1
> indicating that FTDs which are now operating via a letter from the FAA
> Administrator may continue to be used for their original acceptable use. In
> other words, my FTD was originally approved for an IPC and therefore it will
> remain approved for an IPC even with then new PTS goes into effect.

There are two relevant notes in that appendix:

NOTE: Users of the following chart are cautioned that use of the chart alone
is incomplete. The description and Objective of each TASK as listed in the
body of the practical test standard, including all NOTEs, must also be
incorporated for accurate simulation device use.

NOTE: 1. Level 1 FTDs that have been issued a letter authorizing their use by
the FAA Administrator, may continue to be used only for those TASKs originally
found acceptable.

It seems to me that these notes are intended to RESTRICT FTD use, by
preventing someone with a Level 1 FTD from doing something that wasn't
originally approved. I don't see how it would grandfather in all FTDs for any
original acceptable use.

Barry

"Barry" > wrote in message ...>

> It seems to me that these notes are intended to RESTRICT FTD use, by
> preventing someone with a Level 1 FTD from doing something that wasn't
> originally approved. I don't see how it would grandfather in all FTDs for
any
> original acceptable use.

Yes, but per the FAA Inspector's Handbook one of the original acceptable
uses is a complete IPC so now an FTD will remain "restricted" to this use.
So for example an IPC will remain possible in a Level 1 FTD but for the
purpose of an IFR checkride the FTD will not be usable for a circling
approach because a circling approach was not originally an explicitly
approved maneuver. This is the text from the Inspector's handbook:


B. For use under 14 CFR§ 61.57(d)(1)(ii). Regulatory authorization for pilot
use of a level 1 FTD to conduct all or part of an instrument competency
check, consisting of a representative number of tasks required for the
instrument rating practical test when given by an authorized instructor:
. Aviation Simulation Technology, Inc.: AST 201 and 300 Models
. ATC Flight Simulator Company: ATC 112H, 610, 710, 810, and 920 Models
. Frasca International, Inc.: 121, 122, 131, 132, 141, 142, 241, 242,
242T, and 342 Models
. Pacer Systems Corporation: MK II Models



--------------------
Richard Kaplan, CFII

www.flyimc.com

> There is nothing in the current PTS which states that the ENTIRE table has
> to be conducted on every IPC; 61.57(d) allows a CFII the discretion to
> select representative tasks from that list.

Page 2 of the current PTS states:

Applicants for an instrument proficiency check required by 14 CFR section
61.57, must perform to the standards of the TASKS listed under PC in the
Rating Task Table on page 15.

The Rating Task Table heading states:

Required TASKS are indicated by either the TASK letter(s) that apply(s) or an
indication that all or none of the TASKS must be tested.

Note the word "required". These two statements, taken together, indicate to
me that the intent was to require all items on the table. (The FAA's Part 61
FAQ, though admittedly not regulatory, also supports this view.) One can
claim that there's some ambiguity, and that the list is not legally binding.
However, if this interpretation is wrong, the CFII jeopardizes not just
himself, but also the pilots to whom he provides the endorsement. Is this
something a conscientious CFII should do? In the absence of a formal FAA
interpretation, I feel obligated to make a good faith effort to comply by
including all the "required" items.

Barry

"Barry" > wrote in message ...>

> himself, but also the pilots to whom he provides the endorsement. Is
this
> something a conscientious CFII should do? In the absence of a formal FAA
> interpretation, I feel obligated to make a good faith effort to comply by
> including all the "required" items.

How about if I do an IPC in an airplane on a day when weather is below
circling minimums at the aiport where the IPC is conducted?

That seems like an excellent way to assess an instrument pilot's
capabilities, yet there is no way to conduct a circling approach.

Should the conscientious CFII not do the IPC and thus miss this opportunity?

Should the conscientious CFII require a return to conduct a circling
approach on another day to complete the IPC?

And how do we reconcile this with the FAA Inspector's Handbook clearly
approves of an IPC in a Level 1 FTD which cannot perform circling
approaches?



--------------------
Richard Kaplan, CFII

www.flyimc.com

>>
B. For use under 14 CFR§ 61.57(d)(1)(ii). Regulatory authorization for pilot
use of a level 1 FTD to conduct all or part of an instrument competency
check, consisting of a representative number of tasks required for the
instrument rating practical test when given by an authorized instructor:
<<

Seems to me that the phrase "consisting of a representative number of tasks"
modifies "instrument competency check", and the correct English parsing of the
sentense would restrict the use only to those IPCs which consist of a
representative number of tasks. IPCs which do not would not be permitted.

It could (of course) be argued that since "all the tasks" is representative of
the required tasks, that an IPC which consists of all the tasks is also an IPC
which consists of a representative number of tasks.

Isn't language wonderful!

Jose
--
(for Email, make the obvious changes in my address)

"Teacherjh" > wrote in message
...>

> They are advisory until there is an accident. Then they were binding.

OK, then let me ask a question which is now extremely appropriate to this
thread.

Suppose I am flying a real circling approach to minimums at an uncontrolled
field and the only way I can safely comply with the circling visibility and
runway distance requirements is by flying a non-standard pattern. Is it
OK to consider the AIM advisory only in this case?
--------------------
Richard Kaplan, CFII

www.flyimc.com

> How about if I do an IPC in an airplane on a day when weather is below
> circling minimums at the aiport where the IPC is conducted?
>
> That seems like an excellent way to assess an instrument pilot's
> capabilities, yet there is no way to conduct a circling approach.
>
> Should the conscientious CFII not do the IPC and thus miss this opportunity?
>
> Should the conscientious CFII require a return to conduct a circling
> approach on another day to complete the IPC?

I'd say this should be treated the same way one would treat a failure of the
glide slope transmitter - go to another airport where the requirement can be
met. If all requirements can't be met, don't sign off the IPC. I'm not
claiming this all makes sense, but it seems to be required.

> And how do we reconcile this with the FAA Inspector's Handbook clearly
> approves of an IPC in a Level 1 FTD which cannot perform circling
> approaches?

I don't know. It sounds like whoever updated the PTS didn't talk to whoever's
in charge of the Handbook. Maybe there's some kind of waiver. The best way
to find out is probably to ask the FSDO that approved the FTD.

"Barry" > wrote in message ...>

> I don't know. It sounds like whoever updated the PTS didn't talk to
whoever's
> in charge of the Handbook. Maybe there's some kind of waiver. The best
way
> to find out is probably to ask the FSDO that approved the FTD.

A FSDO inspector just does what the Handbook says he is authorized to do.
The Handbook is a national document; that is much more authoritative than
any one FSDO's opinion.

It seems very clear that an FTD can be approved today for a complete
instrument proficiency check. The newest PTS document states that an FTD
will remain approved for previously approved tasks. Thus an FTD approved
today for a full IPC will remain approved for a full IPC under the new PTS.


--------------------
Richard Kaplan, CFII

www.flyimc.com

On Mon, 07 Jun 2004 16:41:32 GMT, "Richard Kaplan"
> wrote:

>
>
>"Robert M. Gary" > wrote in message
om...>
>
>> Actually, if you read the current PTS, you will notice that in the
>> table of tasks to be done, there is a column for IPC. Today, the PTS
>> spells out the IPC. You can call AOPA and hear it for yourself. Of
>
>There is nothing in the current PTS which states that the ENTIRE table has
>to be conducted on every IPC; 61.57(d) allows a CFII the discretion to
>select representative tasks from that list.
>
>
>--------------------
>Richard Kaplan, CFII

>www.flyimc.com
>



Once again, READ the info at the top of the current rating task table.
It states"AREA
OF
OPERATION
Required TASKS are indicated by either the TASK letter(s)
that apply(s) or an indication that all or none of the TASKS
must be tested.

What does the word "MUST" mean to you?

On Mon, 07 Jun 2004 22:16:55 GMT, "Richard Kaplan"
> wrote:

>"Teacherjh" > wrote in message
...>
>
>> They are advisory until there is an accident. Then they were binding.
>
>OK, then let me ask a question which is now extremely appropriate to this
>thread.
>
>Suppose I am flying a real circling approach to minimums at an uncontrolled
>field and the only way I can safely comply with the circling visibility and
>runway distance requirements is by flying a non-standard pattern. Is it
>OK to consider the AIM advisory only in this case?
>--------------------
>Richard Kaplan, CFII

>www.flyimc.com
>
What do you mean by "non-standard pattern"? Outside of any circling
restrictions placed on the approach chart, there are no restrictions
to type of pattern or direction, as long as you stay within circling
visibility radius. Left/right traffic is irrelevant. You can circle
the field multiple times in both directions, if you really want to.

"Bill Zaleski" > wrote in message
...>


> What does the word "MUST" mean to you?

Take a look at page 4 of the current PTS or page 6 of the October 2004 PTS:

"All TASKs in these practical test standards are required for the issuance
of an instrument rating in airplanes, helicopters, and powered lift.
However, when a particular element is not appropriate to the aircraft, its
equipment, or operational capability, that element may be omited."

Thus in the current PTS not all tasks are required.

Actually, this is yet another argument supporting an IPC in an FTD in the
October 2004 PTS. The confusion comes about with the new paragraph on page
16 stating that the table comprises the minimum standard. But then the
footnote in the Appendix reverses this again and clarifies that an FTD
previously approved for a complete IPC remains approved for a complete IPC.

So I conclude that an IPC in an FTD after October 2004 will be "not not not
unauthorized" and thus will be legal.



--------------------
Richard Kaplan, CFII

www.flyimc.com

"Bill Zaleski" > wrote in message
...>

On Mon, 07 Jun 2004 22:16:55 GMT, "Richard Kaplan"

> What do you mean by "non-standard pattern"? Outside of any circling
> restrictions placed on the approach chart, there are no restrictions
> to type of pattern or direction, as long as you stay within circling
> visibility radius. Left/right traffic is irrelevant. You can circle
> the field multiple times in both directions, if you really want to.

From AIM 4-3-4 -- Is this regulatory or advisory?

c. Preparatory to landing at an airport without a control tower, or when the
control tower is not in operation, pilots should concern themselves with the
indicator for the approach end of the runway to be used. When approaching
for landing, all turns must be made to the left unless a traffic pattern
indicator indicates that turns should be made to the right. If the pilot
will mentally enlarge the indicator for the runway to be used, the base and
final approach legs of the traffic pattern to be flown immediately become
apparent. Similar treatment of the indicator at the departure end of the
runway will clearly indicate the direction of turn after takeoff.

--------------------
Richard Kaplan, CFII

www.flyimc.com

On Mon, 07 Jun 2004 11:48:39 GMT, "Richard Kaplan"
> wrote:

>"Bill Zaleski" > wrote in message
...>
>
>> the current PTS became effective in March 1999. AFS 640, the branch
>> of the FAA that sets training policy, told me during the last examiner
>> recertification seminar that the PTS is binding, and the task table
>
>Bill,
>
>The question of whether the PTS is legally binding upon a CFII is a bit more
>complex than this, as is often the case for areas where law and
>administrative regulations overlap.
>
>
>Your answer is sort of like saying you called a specific division of the IRS
>for a ruling on a complex taxation and that gave you a definitive answer.
>Actually, getting a definitive answer on federal tax regulations is quite
>complex and often has gray areas until a court reaches a final decision.
>Sometimes courts even give different answers in different districts around
>the country.
>
>It is very clear that the Advanced ATD concept was introduced after the 1999
>PTS and that the Advanced ATD was intended for completing a full IPC. Yet
>if the PTS is considered to be legally binding, the Advanced ATD cannot be
>used for an IPC because a literal interpretation of the PTS requires landing
>out of an approach for an IPC, yet no Advanced ATD and no FTD is approved
>for landings. Thus if the PTS is legally binding then a huge percentage of
>piston IPCs done at virtually every major simulator center in the past 5
>years are invalid. And if the PTS is legally binding then the whole concept
>of approving the Advanced ATD is inconsistent within the FAA's regulatory
>framework.
>
>I think the best answer is that there are some unclear or gray areas here
>which need to be resolved.
>
>Saying the PTS is obviously legally binding rather than advisory is like
>saying the AIM is obviously legally binding. Do you believe items in the
>AIM are advisory or binding?
>
>
>
>--------------------
>Richard Kaplan, CFII

>www.flyimc.com
>
>
So, in effect, you are saying that those who wrote the PTS are not in
a position to provide accurate information on it's use, validity, or
legality. Again, laughable. Who do you plan to go to for any
meaningful guidance? You've already said that the FSDO's don't know
how to handle queries on this issue. I recall giving you information
on the use of the FTD without an instructor present for currency that
you were steadfast against until the simulator branch confirmed to you
what you didn't want to hear. Time to use common sense here. It
wouldn't be called an STANDARD (PTS). if it wasn't a standard. Yup,
it's binding. Call 'em up like you finally did last time.

On Tue, 08 Jun 2004 03:04:42 GMT, "Richard Kaplan"
> wrote:

>
>"Bill Zaleski" > wrote in message
...>
>
>
>> What does the word "MUST" mean to you?
>
>Take a look at page 4 of the current PTS or page 6 of the October 2004 PTS:
>
>"All TASKs in these practical test standards are required for the issuance
>of an instrument rating in airplanes, helicopters, and powered lift.
>However, when a particular element is not appropriate to the aircraft, its
>equipment, or operational capability, that element may be omited."
>
>Thus in the current PTS not all tasks are required.
>
>Actually, this is yet another argument supporting an IPC in an FTD in the
>October 2004 PTS. The confusion comes about with the new paragraph on page
>16 stating that the table comprises the minimum standard. But then the
>footnote in the Appendix reverses this again and clarifies that an FTD
>previously approved for a complete IPC remains approved for a complete IPC.
>
>So I conclude that an IPC in an FTD after October 2004 will be "not not not
>unauthorized" and thus will be legal.
>
>
>
>--------------------
>Richard Kaplan, CFII

>www.flyimc.com
>
"for the issuance
of an instrument rating"

Seems like they are not talking about an IPC here.
Your point?

"Bill Zaleski" > wrote in message
...>

> This does not apply to IFR arrivals desiring to circle in instrument
> conditions. The approach chart limitations/notations are the only
> limitation. What are you teaching your students? You should read the
> TERPS.

I agree with you completely and I do not teach my students any differently
than you suggest.

I am simply giving an example of how FAA publications/documents/regulations
need to be interpreted in an overall context rather than in isolation.


--------------------
Richard Kaplan, CFII

www.flyimc.com

On Tue, 08 Jun 2004 03:20:51 GMT, "Richard Kaplan"
> wrote:

>
>"Bill Zaleski" > wrote in message
...>
>
>On Mon, 07 Jun 2004 22:16:55 GMT, "Richard Kaplan"
>
>> What do you mean by "non-standard pattern"? Outside of any circling
>> restrictions placed on the approach chart, there are no restrictions
>> to type of pattern or direction, as long as you stay within circling
>> visibility radius. Left/right traffic is irrelevant. You can circle
>> the field multiple times in both directions, if you really want to.
>
>From AIM 4-3-4 -- Is this regulatory or advisory?
>
>c. Preparatory to landing at an airport without a control tower, or when the
>control tower is not in operation, pilots should concern themselves with the
>indicator for the approach end of the runway to be used. When approaching
>for landing, all turns must be made to the left unless a traffic pattern
>indicator indicates that turns should be made to the right. If the pilot
>will mentally enlarge the indicator for the runway to be used, the base and
>final approach legs of the traffic pattern to be flown immediately become
>apparent. Similar treatment of the indicator at the departure end of the
>runway will clearly indicate the direction of turn after takeoff.
>
>--------------------
>Richard Kaplan, CFII

>www.flyimc.com
>
This does not apply to IFR arrivals desiring to circle in instrument
conditions. The approach chart limitations/notations are the only
limitation. What are you teaching your students? You should read the
TERPS.

>>
I am simply giving an example of how FAA publications/documents/regulations
need to be interpreted in an overall context rather than in isolation.
<<

They all need to be interpted in overall context. As long as there isn't an
accident, your interpretation is probably fine (with the FAA). If there's an
accident, then the FAA can choose to bring the AIM and the "careless and
reckless" clause into play. It might not always pass, but it's always above
you.

Here's a better one. Flight into known icing is prohibited (for a certain
subset of aircraft). Known icing and forecast icing are identical (to the
FAA).

So, you get a briefing, and find that the freezing level is forecast to be
6000. Freezing level at your destination will be at the surface three hours
after your arrival (before which the freezing level is 6000). You file for and
get 4000. You take off into the soup, and find that the weather is moving
faster. The temperature at 4000 is plus one. You get no ice. The minimum IFR
altitude is 2000, the cloud tops are 6000. You have several outs should you
pick up ice.

You continue (it's one of the options) to your destination which is reporting
clear and 6, and is an hour away. The temperature at 4000 drops to zero and you
start picking up a little ice. You ask to descend, ATC says unable. You ask
to climb, they clear you to 8000. This is above the clouds, and your
destination is clear. You accept, it being only a 2000 foot climb.

By doing so you are explicitly flying into known icing conditions.
Nonetheless, this is one of the recommended options in the new FAA Icing video.
IT doesn't appear to me to be a bad option, and turning around might not be
any better. You could declare an emergency, but you decide the situation
doesn't really warrant it yet.

You climb. Something Bad Happens. Nonetheless you survive, and after you get
out of the hospital, you face the FAA.

Did you violate the FARs? I bet they are lighting the grill for your goose.

In your example (IFR circling and the AIM) the case is weaker. But the AIM
recommends certain procedures (like altitudes and such), and if failure to
adhere to those recommendations causes grief, I bet they magically become
regulatory.

Jose

--
(for Email, make the obvious changes in my address)

"Bill Zaleski" > wrote in message
...>

> wouldn't be called an STANDARD (PTS). if it wasn't a standard. Yup,
> it's binding. Call 'em up like you finally did last time.


I do appreciate your help regarding the prior issue. Your advice was quite
correct and was confirmed by my inquiry to multiple FAA sources, by my
cross-check with multiple FAA written documents, and by inquiry to my FTD
manufacturer.

In this case the situation is different: every FTD manufacturer in
existence without exception supports the use of an FTD for a complete IPC
today, several FAA documents and personnel do support the use of an FTD for
an IPC, and every FTD manufacturer I have spoken with so far initially was
puzzled by the new PTS but has ultimately come to the conclusion that an IPC
will indeed remain legal in an FTD.


--------------------
Richard Kaplan, CFII

www.flyimc.com

That is like saying that "Speed Limits are advisory, unless a cop is
around"....

Come to think of it, I guess they are!

Rich



Teacherjh wrote:
> Do you believe items in the
> AIM are advisory or binding?
> <<
>
> They are advisory until there is an accident. Then they were binding.
>
> I say this tongue in cheek, but it does seem to be the FAA way.
>
> Jose
>

"Rich" > wrote in message
...
> That is like saying that "Speed Limits are advisory, unless a cop is
> around"....
>
> Come to think of it, I guess they are!
>

In some states, speed limits _were_ advisory (in the 30's and so)...until
they realized what a treasure trove they could be.

Roy Smith > wrote in message >...
> I seem to remember there used to be wording to the effect that an
> ICC/IPC needed to include a "representative sample" of the PTS checkride
> tasks. I can't remember if that was in the PTS itself or part 61/91
> somewhere. Or maybe it's just a faulty memory circuit?

Right, but the PTS was more explicit in giving a table of required
items on the IPC (this has been that way for many years). The issue is
whether those items that the PTS requires for an IPC have been
regulatory. In short, the FAA, when putting out the PTS, chose the
"representative sample" for you. The FARs never say the CFII gets to
pick.

-Robert, CFI