Changes in Instrument Proficiency Check Requirements

"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

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)

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.

"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

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

"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

"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

"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

"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