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/practica...-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