"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