Changes in Instrument Proficiency Check Requirements

Roy Smith wrote in message ...
In article m,
"Richard Kaplan" wrote:

"Robert M. Gary" wrote in message
om...

I"m not sure how far back you're going. My IFR PTS is pretty old but
still includes a table of things required for a PC. I think that a lot
of CFIIs just didn't know what an IPC was.

The difference is that the prior PTS versions did not state that all the IPC
items in the table are required for an IPC; thus a reasonable interpretation
has been that 61.57(d) givet a CFII the discretion to choose among those
items.

The newest PTS now explicitly states that all IPC items in the table must be
included in an IPC.

I seem to remember there used to be wording to the effect that an
ICC/IPC needed to include a "representative sample" of the PTS checkride
tasks. I can't remember if that was in the PTS itself or part 61/91
somewhere. Or maybe it's just a faulty memory circuit?

That being said, I'm about to give my first IPC in an plane with an
approach certified GPS. I spent some time re-reading the PTS to make
sure my plan is up to snuff, and here's what I came up with for the
flight portion:


Actually, if you read the current PTS, you will notice that in the
table of tasks to be done, there is a column for IPC. Today, the PTS
spells out the IPC. You can call AOPA and hear it for yourself. Of
course you can argue the PTS is not regulatory. One guy tried to argue
that the AIM wasn't regulatory too. The NASA admin law judge didn't
seem to buy that story either. Right or wrong doesn't make any
difference, its all what the judge is going to say when you plead to
keep your ticket.

-Robert

"Robert M. Gary" wrote in message
om...

Actually, if you read the current PTS, you will notice that in the
table of tasks to be done, there is a column for IPC. Today, the PTS
spells out the IPC. You can call AOPA and hear it for yourself. Of

There is nothing in the current PTS which states that the ENTIRE table has
to be conducted on every IPC; 61.57(d) allows a CFII the discretion to
select representative tasks from that list.


--------------------
Richard Kaplan, CFII

www.flyimc.com

There is nothing in the current PTS which states that the ENTIRE table has
to be conducted on every IPC; 61.57(d) allows a CFII the discretion to
select representative tasks from that list.

Page 2 of the current PTS states:

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 Rating Task Table heading states:

Required TASKS are indicated by either the TASK letter(s) that apply(s) or an
indication that all or none of the TASKS must be tested.

Note the word "required". These two statements, taken together, indicate to
me that the intent was to require all items on the table. (The FAA's Part 61
FAQ, though admittedly not regulatory, also supports this view.) One can
claim that there's some ambiguity, and that the list is not legally binding.
However, if this interpretation is wrong, the CFII jeopardizes not just
himself, but also the pilots to whom he provides the endorsement. Is this
something a conscientious CFII should do? In the absence of a formal FAA
interpretation, I feel obligated to make a good faith effort to comply by
including all the "required" items.

Barry

"Barry" wrote in message ...

himself, but also the pilots to whom he provides the endorsement. Is
this
something a conscientious CFII should do? In the absence of a formal FAA
interpretation, I feel obligated to make a good faith effort to comply by
including all the "required" items.

How about if I do an IPC in an airplane on a day when weather is below
circling minimums at the aiport where the IPC is conducted?

That seems like an excellent way to assess an instrument pilot's
capabilities, yet there is no way to conduct a circling approach.

Should the conscientious CFII not do the IPC and thus miss this opportunity?

Should the conscientious CFII require a return to conduct a circling
approach on another day to complete the IPC?

And how do we reconcile this with the FAA Inspector's Handbook clearly
approves of an IPC in a Level 1 FTD which cannot perform circling
approaches?



--------------------
Richard Kaplan, CFII

www.flyimc.com

How about if I do an IPC in an airplane on a day when weather is below
circling minimums at the aiport where the IPC is conducted?

That seems like an excellent way to assess an instrument pilot's
capabilities, yet there is no way to conduct a circling approach.

Should the conscientious CFII not do the IPC and thus miss this opportunity?

Should the conscientious CFII require a return to conduct a circling
approach on another day to complete the IPC?

I'd say this should be treated the same way one would treat a failure of the
glide slope transmitter - go to another airport where the requirement can be
met. If all requirements can't be met, don't sign off the IPC. I'm not
claiming this all makes sense, but it seems to be required.

And how do we reconcile this with the FAA Inspector's Handbook clearly
approves of an IPC in a Level 1 FTD which cannot perform circling
approaches?

I don't know. It sounds like whoever updated the PTS didn't talk to whoever's
in charge of the Handbook. Maybe there's some kind of waiver. The best way
to find out is probably to ask the FSDO that approved the FTD.

"Barry" wrote in message ...

I don't know. It sounds like whoever updated the PTS didn't talk to
whoever's
in charge of the Handbook. Maybe there's some kind of waiver. The best
way
to find out is probably to ask the FSDO that approved the FTD.

A FSDO inspector just does what the Handbook says he is authorized to do.
The Handbook is a national document; that is much more authoritative than
any one FSDO's opinion.

It seems very clear that an FTD can be approved today for a complete
instrument proficiency check. The newest PTS document states that an FTD
will remain approved for previously approved tasks. Thus an FTD approved
today for a full IPC will remain approved for a full IPC under the new PTS.


--------------------
Richard Kaplan, CFII

www.flyimc.com

On Mon, 07 Jun 2004 16:41:32 GMT, "Richard Kaplan"
wrote:



"Robert M. Gary" wrote in message
. com...

Actually, if you read the current PTS, you will notice that in the
table of tasks to be done, there is a column for IPC. Today, the PTS
spells out the IPC. You can call AOPA and hear it for yourself. Of

There is nothing in the current PTS which states that the ENTIRE table has
to be conducted on every IPC; 61.57(d) allows a CFII the discretion to
select representative tasks from that list.


--------------------
Richard Kaplan, CFII

www.flyimc.com




Once again, READ the info at the top of the current rating task table.
It states"AREA
OF
OPERATION
Required TASKS are indicated by either the TASK letter(s)
that apply(s) or an indication that all or none of the TASKS
must be tested.

What does the word "MUST" mean to you?

"Bill Zaleski" wrote in message
...


What does the word "MUST" mean to you?

Take a look at page 4 of the current PTS or page 6 of the October 2004 PTS:

"All TASKs in these practical test standards are required for the issuance
of an instrument rating in airplanes, helicopters, and powered lift.
However, when a particular element is not appropriate to the aircraft, its
equipment, or operational capability, that element may be omited."

Thus in the current PTS not all tasks are required.

Actually, this is yet another argument supporting an IPC in an FTD in the
October 2004 PTS. The confusion comes about with the new paragraph on page
16 stating that the table comprises the minimum standard. But then the
footnote in the Appendix reverses this again and clarifies that an FTD
previously approved for a complete IPC remains approved for a complete IPC.

So I conclude that an IPC in an FTD after October 2004 will be "not not not
unauthorized" and thus will be legal.



--------------------
Richard Kaplan, CFII

www.flyimc.com

On Tue, 08 Jun 2004 03:04:42 GMT, "Richard Kaplan"
wrote:


"Bill Zaleski" wrote in message
.. .


What does the word "MUST" mean to you?

Take a look at page 4 of the current PTS or page 6 of the October 2004 PTS:

"All TASKs in these practical test standards are required for the issuance
of an instrument rating in airplanes, helicopters, and powered lift.
However, when a particular element is not appropriate to the aircraft, its
equipment, or operational capability, that element may be omited."

Thus in the current PTS not all tasks are required.

Actually, this is yet another argument supporting an IPC in an FTD in the
October 2004 PTS. The confusion comes about with the new paragraph on page
16 stating that the table comprises the minimum standard. But then the
footnote in the Appendix reverses this again and clarifies that an FTD
previously approved for a complete IPC remains approved for a complete IPC.

So I conclude that an IPC in an FTD after October 2004 will be "not not not
unauthorized" and thus will be legal.



--------------------
Richard Kaplan, CFII

www.flyimc.com

"for the issuance
of an instrument rating"

Seems like they are not talking about an IPC here.
Your point?

(Robert M. Gary) wrote
One guy tried to argue that the AIM wasn't regulatory too.
The NASA admin law judge didn't seem to buy that story either.
Right or wrong doesn't make any difference, its all what the
judge is going to say when you plead to keep your ticket.

NASA law judge????? I trust that you meant to say "the NTSB
administrative law judge".....right?

Bob Moore