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Changes in Instrument Proficiency Check Requirements



 
 
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  #1  
Old May 27th 04, 06:03 AM
Richard Kaplan
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"Barry" wrote in message
...

The current PTS is FAA-S-8081-4C with changes 1 and 2. Change 2 added the
Rating Task Table and was issued 3/11/99. I couldn't find it online so I
posted it on alt.binaries.pictures.aviation.


Thank you... much appreciated.

In reviewing the original version 4C as well as changes 1 and 2, I think it
could reasonably be said that the "IPC task list" is the list of items from
which FAR 61.57 allows the instructor to select a "representative" number of
tasks. I believe that is how/why an IPC can be conducted today in an FTD or
advanced ATD without a circling approach; there is no explicit statement
that all of the IPC tasks must be included in an IPC, so I would conclude a
CFII has the discretion to select a representative number of the tasks from
the IPC task list.

The new "gotcha" item which grabs my attention in the new version 4D PTS is
the following on page 16 -- note in particular the last sentence which I
have quoted:

Instrument Proficiency Check. 14 CFR part 61.57(d) sets forth the
requirements for an instrument proficiency check. The person giving that
check shall use the standards and procedures contained in ths PTS when
administering the check. A representative number of TASKs, as determined by
the examiner/instructor, must be selected to assure the competence of the
applicant to operate in the IFR environment. As a minimum, the applicant
must demonstrate the ability to perform the TASKs as listed in the above
chart.


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

www.flyimc.com



  #2  
Old May 27th 04, 06:47 AM
Barry
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In reviewing the original version 4C as well as changes 1 and 2, I think it
could reasonably be said that the "IPC task list" is the list of items from
which FAR 61.57 allows the instructor to select a "representative" number of
tasks. I believe that is how/why an IPC can be conducted today in an FTD or
advanced ATD without a circling approach; there is no explicit statement
that all of the IPC tasks must be included in an IPC, so I would conclude a
CFII has the discretion to select a representative number of the tasks from
the IPC task list.

The new "gotcha" item which grabs my attention in the new version 4D PTS is
the following on page 16 -- note in particular the last sentence which I
have quoted:

Instrument Proficiency Check. 14 CFR part 61.57(d) sets forth the
requirements for an instrument proficiency check. The person giving that
check shall use the standards and procedures contained in ths PTS when
administering the check. A representative number of TASKs, as determined by
the examiner/instructor, must be selected to assure the competence of the
applicant to operate in the IFR environment. As a minimum, the applicant
must demonstrate the ability to perform the TASKs as listed in the above
chart.


The old PTS doesn't include that wording, but on page 3 it says:

"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 FAA's Part 61 FAQ (http://www.faa.gov/avr/afs/afs800/docs/pt61FAQ.doc)
says :

----------------------
QUESTION: Request guidance on the meaning/intent of the wording ". . . a
representative number of tasks. . ."

ANSWER: Ref. § 61.57(d): First of all, neither the regulation nor the preamble
of the regulation covers what you're asking. The answer is to be found in the
Instrument Rating Practical Test Standards, FAA-S-8081-4C on page 15 of the
Introduction (effective with change 2 as of 03/11/99). The right hand column
of the Rating Task Table indicates the required Tasks for the Areas of
Operation.

Historically, the wording ". . .a representative number of tasks . . ."
requires an objective decision to be made by the CFII/examiner that is
dependent on the applicant's ability. If it becomes obvious during the conduct
of the instrument proficiency check that a pilot who has not flown instruments
in over a year or more is extremely weak, then the check may need to be more
extensive than the required list. The CFII/examiner needs to be able to say at
the conclusion of the check that yes this pilot can operate safely in the
national airspace system.
--------------------

These both indicate to me that the FAA intends for the IPC to require all of
the listed items. However, it's not clear that this is legally binding on a
CFII. Page 1 of the current PTS says:

"The Flight Standards Service of the Federal Aviation Administration (FAA) has
developed this practical test standards book to be used by FAA inspectors and
designated pilot examiners when conducting instrument rating—airplane,
helicopter, and powered lift practical tests, and instrument proficiency
checks for all aircraft."

There's no mention of instructors, so one could argue that it's mandatory for
examiners but not plain old CFIIs. I have been treating it as mandatory.

I suppose you could ask your local FSDO (who I assume approved your FTD) for
their interpretation, but you might not like the answer you get.

Barry





  #3  
Old May 27th 04, 06:47 AM
Richard Kaplan
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"Barry" wrote in message
...

There's no mention of instructors, so one could argue that it's mandatory

for
examiners but not plain old CFIIs. I have been treating it as mandatory.


Interesting.. the latest version of the PTS seems even more permissive in
that regard:

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

FAA inspectors and designated pilot examiners shall conduct practical tests
in compliance with these standards. Flight instructors and applicants
should find these standards helpful during training and when preparing for
practical tests.

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


This preamble seems to imply that the PTS is just a helpful reference,
presumably a reference from which to draw "representative tasks" per 61.57.



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

www.flyimc.com


  #4  
Old May 27th 04, 12:33 PM
Richard Kaplan
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Posts: n/a
Default

"Barry" wrote in message
...

These both indicate to me that the FAA intends for the IPC to require all

of
the listed items. However, it's not clear that this is legally binding on

a
CFII. Page 1 of the current PTS says:


If all the listed items were legally binding on a CFII, then a huge number
of IPCs issued by FlightSafety, Simcom, and RTC since 1999 would be invalid
because landing out of an approach is required, yet only Level C and Level D
simulators qualify to log landings according to the chart at the end of the
1999 PTC.


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

www.flyimc.com


 




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