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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 |
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