Changes in Instrument Proficiency Check Requirements

This is the text in the inspector's handbook authorizing use of an FTD for a
COMPLETE IPC -- it remains valid today.


B. For use under 14 CFR§ 61.57(d)(1)(ii). Regulatory authorization for pilot
use of a level 1 FTD to conduct all or part of an instrument competency
check, consisting of a representative number of tasks required for the
instrument rating practical test when given by an authorized instructor:
. Aviation Simulation Technology, Inc.: AST 201 and 300 Models
. ATC Flight Simulator Company: ATC 112H, 610, 710, 810, and 920 Models
. Frasca International, Inc.: 121, 122, 131, 132, 141, 142, 241, 242,
242T, and 342 Models
. Pacer Systems Corporation: MK II Models


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

www.flyimc.com

I have now spoken with most of the simulator/FTD manufacturers in the
industry. The consensus overall based upon multiple contact with various
FAA sources is that existing FTDs will remain legal for a full IPC. The
basis for this is that in the newest PTS there is a footnote to Appendix 1-1
indicating that FTDs which are now operating via a letter from the FAA
Administrator may continue to be used for their original acceptable use. In
other words, my FTD was originally approved for an IPC and therefore it will
remain approved for an IPC even with then new PTS goes into effect.

There are two relevant notes in that appendix:

NOTE: Users of the following chart are cautioned that use of the chart alone
is incomplete. The description and Objective of each TASK as listed in the
body of the practical test standard, including all NOTEs, must also be
incorporated for accurate simulation device use.

NOTE: 1. Level 1 FTDs that have been issued a letter authorizing their use by
the FAA Administrator, may continue to be used only for those TASKs originally
found acceptable.

It seems to me that these notes are intended to RESTRICT FTD use, by
preventing someone with a Level 1 FTD from doing something that wasn't
originally approved. I don't see how it would grandfather in all FTDs for any
original acceptable use.

Barry

"Barry" wrote in message ...

It seems to me that these notes are intended to RESTRICT FTD use, by
preventing someone with a Level 1 FTD from doing something that wasn't
originally approved. I don't see how it would grandfather in all FTDs for
any
original acceptable use.

Yes, but per the FAA Inspector's Handbook one of the original acceptable
uses is a complete IPC so now an FTD will remain "restricted" to this use.
So for example an IPC will remain possible in a Level 1 FTD but for the
purpose of an IFR checkride the FTD will not be usable for a circling
approach because a circling approach was not originally an explicitly
approved maneuver. This is the text from the Inspector's handbook:


B. For use under 14 CFR§ 61.57(d)(1)(ii). Regulatory authorization for pilot
use of a level 1 FTD to conduct all or part of an instrument competency
check, consisting of a representative number of tasks required for the
instrument rating practical test when given by an authorized instructor:
. Aviation Simulation Technology, Inc.: AST 201 and 300 Models
. ATC Flight Simulator Company: ATC 112H, 610, 710, 810, and 920 Models
. Frasca International, Inc.: 121, 122, 131, 132, 141, 142, 241, 242,
242T, and 342 Models
. Pacer Systems Corporation: MK II Models



--------------------
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

B. For use under 14 CFR§ 61.57(d)(1)(ii). Regulatory authorization for pilot
use of a level 1 FTD to conduct all or part of an instrument competency
check, consisting of a representative number of tasks required for the
instrument rating practical test when given by an authorized instructor:


Seems to me that the phrase "consisting of a representative number of tasks"
modifies "instrument competency check", and the correct English parsing of the
sentense would restrict the use only to those IPCs which consist of a
representative number of tasks. IPCs which do not would not be permitted.

It could (of course) be argued that since "all the tasks" is representative of
the required tasks, that an IPC which consists of all the tasks is also an IPC
which consists of a representative number of tasks.

Isn't language wonderful!

Jose
--
(for Email, make the obvious changes in my address)

"Teacherjh" wrote in message
...

They are advisory until there is an accident. Then they were binding.

OK, then let me ask a question which is now extremely appropriate to this
thread.

Suppose I am flying a real circling approach to minimums at an uncontrolled
field and the only way I can safely comply with the circling visibility and
runway distance requirements is by flying a non-standard pattern. Is it
OK to consider the AIM advisory only in this case?
--------------------
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?