Changes in Instrument Proficiency Check Requirements

The FAA has just released a revised version of the instrument rating
practical test standards to become effective October 1, 2004:



http://av-info.faa.gov/data/practica...-s-8081-4d.pdf



Included in the footnotes of this new PTS is a substantial change in the
requirements for an Instrument Proficiency Check.



Currently a CFII conducting an IPC is permitted to use his discretion in
asking a pilot to demonstrate a reasonable selection of items from the PTS.
This seems reasonable in order to adjust the IPC to pilot
strengths/weaknesses which are perceived by either the pilot or the CFII, as
well as to adjust the IPC to items particularly important given a particular
pilot's airplane, avionics, and missions. In other words, the IPC can be
both a learning experience and a proficiency check.



The PTS now itemizes specific tasks which must be accomplished on an IPC.
Among these tasks, a circling approach is now required. I see this as
having several significant effects on the flight training industry, although
as a principal and instructor in a simulator-based flight school I am
interested in input from others not quite as directly affected:



(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. In rigidly
defining the tasks to be included in an IPC, the FAA has removed the CFII's
discretion and turned the IPC into just another hurdle to overcome.



(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. Thus schools
or individuals who very recently bought an Advanced ATD will not be able to
utilize such a device for the intended purpose, nor does there appear to be
a grandfather clause in the PTS.



(3) There exist a number of flight schools (including my own --- full
disclosure) which offer advanced simulator-based training in either
full-motion or non-motion Flight Training Devices or Simulators. These
devices cost anywhere from $100,000 to over $1,000,000 and are typically
approved to conduct a full Instrument Proficiency Check. With the new IFR
PTS, these devices will no longer be legal to conduct a full Instrument
Proficiency Check because many (most?) do not have a wide wraparound visual
display. Adding such a visual display would cost tens of thousands of
dollars and might still not be feasible at any price in the case of the more
expensive devices with enclosed cockpits. One workaround would be to use
these devices to log IFR Currency instead of an IPC, but that would not work
if a pilot is more than 6 months out of currency. Another workaround would
be to conduct a circling approach in an airplane, yet weather or maintenance
issues might make that impractical in some situations. Imagine traveling
hundreds of miles for specialized recurrent training in a sophisticated
training device but being unable to be signed off for an IPC due to a
technical change in FAA rules. Or imagine investing a 6-digit or 7-digit
sum in a training device, only to have the FAA quickly change the rules and
make the device suddenly illegal for its originally approved purpose.



(4) Is it desirable for the FAA to require IFR pilots to practice circling
approaches at every IPC? High visibility circling approaches are far less
critical a skill to maintain than flying a partial panel non-precision
approach. Low visibility circling approaches are risky enough that many
corporate and airline flight departments do not permit such 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?



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

Richard Kaplan, CFII, MCFI

Flight Level Aviation, Inc.



www.flyimc.com

This is typical FAA bull-puckie empire building, and by incompetents at that.
The original concept was an instrument competency check; simply do it until it
all fits.

Now, they want to progress towards an ATP check ride it seems. Where is AOPA
when we need them?

Richard Kaplan wrote:

The FAA has just released a revised version of the instrument rating
practical test standards to become effective October 1, 2004:

http://av-info.faa.gov/data/practica...-s-8081-4d.pdf

Included in the footnotes of this new PTS is a substantial change in the
requirements for an Instrument Proficiency Check.

Currently a CFII conducting an IPC is permitted to use his discretion in
asking a pilot to demonstrate a reasonable selection of items from the PTS.
This seems reasonable in order to adjust the IPC to pilot
strengths/weaknesses which are perceived by either the pilot or the CFII, as
well as to adjust the IPC to items particularly important given a particular
pilot's airplane, avionics, and missions. In other words, the IPC can be
both a learning experience and a proficiency check.

The PTS now itemizes specific tasks which must be accomplished on an IPC.
Among these tasks, a circling approach is now required. I see this as
having several significant effects on the flight training industry, although
as a principal and instructor in a simulator-based flight school I am
interested in input from others not quite as directly affected:

(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. In rigidly
defining the tasks to be included in an IPC, the FAA has removed the CFII's
discretion and turned the IPC into just another hurdle to overcome.

(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. Thus schools
or individuals who very recently bought an Advanced ATD will not be able to
utilize such a device for the intended purpose, nor does there appear to be
a grandfather clause in the PTS.

(3) There exist a number of flight schools (including my own --- full
disclosure) which offer advanced simulator-based training in either
full-motion or non-motion Flight Training Devices or Simulators. These
devices cost anywhere from $100,000 to over $1,000,000 and are typically
approved to conduct a full Instrument Proficiency Check. With the new IFR
PTS, these devices will no longer be legal to conduct a full Instrument
Proficiency Check because many (most?) do not have a wide wraparound visual
display. Adding such a visual display would cost tens of thousands of
dollars and might still not be feasible at any price in the case of the more
expensive devices with enclosed cockpits. One workaround would be to use
these devices to log IFR Currency instead of an IPC, but that would not work
if a pilot is more than 6 months out of currency. Another workaround would
be to conduct a circling approach in an airplane, yet weather or maintenance
issues might make that impractical in some situations. Imagine traveling
hundreds of miles for specialized recurrent training in a sophisticated
training device but being unable to be signed off for an IPC due to a
technical change in FAA rules. Or imagine investing a 6-digit or 7-digit
sum in a training device, only to have the FAA quickly change the rules and
make the device suddenly illegal for its originally approved purpose.

(4) Is it desirable for the FAA to require IFR pilots to practice circling
approaches at every IPC? High visibility circling approaches are far less
critical a skill to maintain than flying a partial panel non-precision
approach. Low visibility circling approaches are risky enough that many
corporate and airline flight departments do not permit such 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?

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

Richard Kaplan, CFII, MCFI

Flight Level Aviation, Inc.



www.flyimc.com

"Currently a CFII conducting an IPC is permitted to use his discretion
in
asking a pilot to demonstrate a reasonable selection of items from the
PTS".


This is not true. Since change 2 of the current instrument PTS came
out, there has been NO discretion as to the content of an IPC. The
rating task table, on page 15 of the current PTS specifically states
which tasks in each area of operation must be accomplished. Nothing
has changed in this requirement.

Perhaps you might re-evaluate the way you are performing your IPC's






On Thu, 27 May 2004 00:43:17 GMT, "Richard Kaplan"
wrote:




The FAA has just released a revised version of the instrument rating
practical test standards to become effective October 1, 2004:



http://av-info.faa.gov/data/practica...-s-8081-4d.pdf



Included in the footnotes of this new PTS is a substantial change in the
requirements for an Instrument Proficiency Check.



Currently a CFII conducting an IPC is permitted to use his discretion in
asking a pilot to demonstrate a reasonable selection of items from the PTS.
This seems reasonable in order to adjust the IPC to pilot
strengths/weaknesses which are perceived by either the pilot or the CFII, as
well as to adjust the IPC to items particularly important given a particular
pilot's airplane, avionics, and missions. In other words, the IPC can be
both a learning experience and a proficiency check.



The PTS now itemizes specific tasks which must be accomplished on an IPC.
Among these tasks, a circling approach is now required. I see this as
having several significant effects on the flight training industry, although
as a principal and instructor in a simulator-based flight school I am
interested in input from others not quite as directly affected:



(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. In rigidly
defining the tasks to be included in an IPC, the FAA has removed the CFII's
discretion and turned the IPC into just another hurdle to overcome.



(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. Thus schools
or individuals who very recently bought an Advanced ATD will not be able to
utilize such a device for the intended purpose, nor does there appear to be
a grandfather clause in the PTS.



(3) There exist a number of flight schools (including my own --- full
disclosure) which offer advanced simulator-based training in either
full-motion or non-motion Flight Training Devices or Simulators. These
devices cost anywhere from $100,000 to over $1,000,000 and are typically
approved to conduct a full Instrument Proficiency Check. With the new IFR
PTS, these devices will no longer be legal to conduct a full Instrument
Proficiency Check because many (most?) do not have a wide wraparound visual
display. Adding such a visual display would cost tens of thousands of
dollars and might still not be feasible at any price in the case of the more
expensive devices with enclosed cockpits. One workaround would be to use
these devices to log IFR Currency instead of an IPC, but that would not work
if a pilot is more than 6 months out of currency. Another workaround would
be to conduct a circling approach in an airplane, yet weather or maintenance
issues might make that impractical in some situations. Imagine traveling
hundreds of miles for specialized recurrent training in a sophisticated
training device but being unable to be signed off for an IPC due to a
technical change in FAA rules. Or imagine investing a 6-digit or 7-digit
sum in a training device, only to have the FAA quickly change the rules and
make the device suddenly illegal for its originally approved purpose.



(4) Is it desirable for the FAA to require IFR pilots to practice circling
approaches at every IPC? High visibility circling approaches are far less
critical a skill to maintain than flying a partial panel non-precision
approach. Low visibility circling approaches are risky enough that many
corporate and airline flight departments do not permit such 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?



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

Richard Kaplan, CFII, MCFI

Flight Level Aviation, Inc.



www.flyimc.com

"Bill Zaleski" wrote in message
...

This is not true. Since change 2 of the current instrument PTS came
out, there has been NO discretion as to the content of an IPC. The

You are correct that the current PTS lists items which are required on an
IPC; however, those items are few enough and important enough that it is
unlikely any CFII would want to conduct an IPC without those items. It is
also clear that the CFII has the discretion to add additional items as
appropriate, and indeed most IPCs likely do include such additional items.

The newest PTS to take effect in October requires more tasks, enough tasks
in fact that in a typical 60-90 minute IPC flight it is probably not
practical to include much beyond the specifically required items.

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

www.flyimc.com

(4) Is it desirable for the FAA to require IFR pilots to practice circling
approaches at every IPC?


I think so. I suspect (but do not know as a fact) that the changes are coming
about because of a realization that circling approaches are not as benign as
they were first thought to be, and pilots should be proficient in them.
Perhaps too few pilots have any experience at all with them in training, and
then in real life are unprepared for the transition to visual while circling in
low visibilty at low altitude. The first time I did a circling approach (in an
IPC, at my request) it was an eye opener.

I'm much less concerned with the profits of businesses that have invested in
devices that are more expensive than airplanes and now complan that they need
to use a real airplane. There's plenty a sim can do (and some things done
better in a sim), but there's no beating an airplane.

I'm actually a bit more bothered by the "if it's in the airplane, you have to
demonstrate it, but if it's not in the airplane, you don't" mentality, though I
don't really have much to say for the alternative either and have no answer.

Jose



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

"Teacherjh" wrote in message
...


Perhaps too few pilots have any experience at all with them in training,
and
then in real life are unprepared for the transition to visual while
circling in
low visibilty at low altitude. The first time I did a circling approach
(in an
IPC, at my request) it was an eye opener.

I agree with this completely, but then the same argument applies to flying
in actual IMC and especially to flying in night-time actual IMC. Why not
require an IPC be conducted at night or in IMC? Indeed, it is not even
required to EVER fly in IMC to get an IFR rating. It is not even required
to ever fly in IMC to get a CFII certificate.


I'm much less concerned with the profits of businesses that have invested
in
devices that are more expensive than airplanes and now complan that they
need
to use a real airplane. There's plenty a sim can do (and some things done
better in a sim), but there's no beating an airplane.

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?

It sounds altruistic to say that it the profits of businesses are not
relevant, but actually the issue at hand is whether it is reasonable to
change the rules in the middle of the game, especially on such short notice.
How about if the FAA declared that in the interest of safety all airplane
owners need to install a Mode S transponder and inertia seatbelts by October
1? You say you agree there are some things done better in a simulator --
well, how likely do you think it is that new/innovative simulators will be
developed/installed if the owner cannot have reasonable confidence in the
legal uses of that simulator for a reasonably long enough period of time to
obtain a return on his investment?


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

www.flyimc.com

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.

You are correct that the current PTS lists items which are required on an
IPC; however, those items are few enough and important enough that it is
unlikely any CFII would want to conduct an IPC without those items. It is
also clear that the CFII has the discretion to add additional items as
appropriate, and indeed most IPCs likely do include such additional items.

The newest PTS to take effect in October requires more tasks, enough tasks
in fact that in a typical 60-90 minute IPC flight it is probably not
practical to include much beyond the specifically required items.

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.

Barry

"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

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


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