Changes in Instrument Proficiency Check Requirements

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


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"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


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"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

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

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