Changes in Instrument Proficiency Check Requirements

"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...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Was there a newer version of the IFR PTS which was issued in between with a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Was there a newer version of the IFR PTS which was issued in between with a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


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