Changes in Instrument Proficiency Check Requirements

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