Changes in Instrument Proficiency Check Requirements

"Robert M. Gary" wrote in message
om...

I"m not sure how far back you're going. My IFR PTS is pretty old but
still includes a table of things required for a PC. I think that a lot
of CFIIs just didn't know what an IPC was.

The difference is that the prior PTS versions did not state that all the IPC
items in the table are required for an IPC; thus a reasonable interpretation
has been that 61.57(d) givet a CFII the discretion to choose among those
items.

The newest PTS now explicitly states that all IPC items in the table must be
included in an IPC.



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

www.flyimc.com

In article m,
"Richard Kaplan" wrote:

"Robert M. Gary" wrote in message
om...

I"m not sure how far back you're going. My IFR PTS is pretty old but
still includes a table of things required for a PC. I think that a lot
of CFIIs just didn't know what an IPC was.

The difference is that the prior PTS versions did not state that all the IPC
items in the table are required for an IPC; thus a reasonable interpretation
has been that 61.57(d) givet a CFII the discretion to choose among those
items.

The newest PTS now explicitly states that all IPC items in the table must be
included in an IPC.

I seem to remember there used to be wording to the effect that an
ICC/IPC needed to include a "representative sample" of the PTS checkride
tasks. I can't remember if that was in the PTS itself or part 61/91
somewhere. Or maybe it's just a faulty memory circuit?

That being said, I'm about to give my first IPC in an plane with an
approach certified GPS. I spent some time re-reading the PTS to make
sure my plan is up to snuff, and here's what I came up with for the
flight portion:

------------
Two flight legs, each with full route clearance on ground, flight to
another airport, at least one approach, and full stop landing. One
leg done with NAV radio only, another with GPS.

VOR leg will include airway intercept and tracking, partial panel VOR
approach, p/p missed, and p/p hold. Partial panel unusual attitudes.
Full panel ILS to a full stop.

GPS leg will include programming flight plan, constant airspeed and
rate climbs and descents, in-flight reroute, GPS approach, full
procedure, circle-to-land to a full stop.
------------

The rest of the PTS material will be covered in the oral.

The bizarre thing is that, AFAICT, the PTS lets me have the guy do a
VOR, LOC, and ILS, and never touch the GPS once. Given that all our club
planes are now equipped with approach-certified GPS, I just can't see
doing that. The hard question is where to draw the line.

If I require a GPS approach at all, the PTS would be perfectly happy to
have us punch in Direct Destination and get vectors to the approach.
But that only exercises a miniscule portion of what you really need to
know to fly IFR with the box. I think the selection of GPS tasks listed
above is a reasonable compromise, but it still leaves a lot untouched.
I guess at some point you need to trust the checkee's PIC judgement to
practice on his own and not attempt things in IMC that are beyond his
abilities.

Roy Smith wrote:

In article m,
"Richard Kaplan" wrote:


"Robert M. Gary" wrote in message
.com...

I"m not sure how far back you're going. My IFR PTS is pretty old but
still includes a table of things required for a PC. I think that a lot
of CFIIs just didn't know what an IPC was.

The difference is that the prior PTS versions did not state that all the IPC
items in the table are required for an IPC; thus a reasonable interpretation
has been that 61.57(d) givet a CFII the discretion to choose among those
items.

The newest PTS now explicitly states that all IPC items in the table must be
included in an IPC.


I seem to remember there used to be wording to the effect that an
ICC/IPC needed to include a "representative sample" of the PTS checkride
tasks. I can't remember if that was in the PTS itself or part 61/91
somewhere. Or maybe it's just a faulty memory circuit?

That being said, I'm about to give my first IPC in an plane with an
approach certified GPS. I spent some time re-reading the PTS to make
sure my plan is up to snuff, and here's what I came up with for the
flight portion:

------------
Two flight legs, each with full route clearance on ground, flight to
another airport, at least one approach, and full stop landing. One
leg done with NAV radio only, another with GPS.

VOR leg will include airway intercept and tracking, partial panel VOR
approach, p/p missed, and p/p hold. Partial panel unusual attitudes.
Full panel ILS to a full stop.

GPS leg will include programming flight plan, constant airspeed and
rate climbs and descents, in-flight reroute, GPS approach, full
procedure, circle-to-land to a full stop.
------------

The rest of the PTS material will be covered in the oral.

The bizarre thing is that, AFAICT, the PTS lets me have the guy do a
VOR, LOC, and ILS, and never touch the GPS once. Given that all our club
planes are now equipped with approach-certified GPS, I just can't see
doing that. The hard question is where to draw the line.

If I require a GPS approach at all, the PTS would be perfectly happy to
have us punch in Direct Destination and get vectors to the approach.
But that only exercises a miniscule portion of what you really need to
know to fly IFR with the box. I think the selection of GPS tasks listed
above is a reasonable compromise, but it still leaves a lot untouched.
I guess at some point you need to trust the checkee's PIC judgement to
practice on his own and not attempt things in IMC that are beyond his
abilities.

Based on my flight yesterday, depending on which GPS you have, I'd want
to see the approach with the IAF being the fix in the middle of the "T",
and I'd want to see the MAP flown as well rather than a full stop
landing. The reason being that, at least with the King 89B radio, there
are a couple of things that come into play in these two circumstances.
If you fly to one of the fixes at the ends of the "T", you don't fly the
PT for reversal an thus can fly the approach in leg mode. This is very
straightforward. However, to fly a course reversal you must enter OBS
mode prior to arriving at the IAF. If you don't, it gets very
confusing. Same with flying the missed. The 89B stops autosequencing
at the MAP and you have to manually select the fix that defines the
hold. These are both easy to overlook in the heat of battle. :-)


Matt

"Roy Smith" wrote in message
...

I seem to remember there used to be wording to the effect that an
ICC/IPC needed to include a "representative sample" of the PTS checkride
tasks. I can't remember if that was in the PTS itself or part 61/91

That wording is in 61.57(d). If the PTS is advisory and not binding, then
the CFII's discretion will not have been significantly hampered.

On Mon, 07 Jun 2004 02:30:39 GMT, "Richard Kaplan"
wrote:




"Roy Smith" wrote in message
...

I seem to remember there used to be wording to the effect that an
ICC/IPC needed to include a "representative sample" of the PTS checkride
tasks. I can't remember if that was in the PTS itself or part 61/91

That wording is in 61.57(d). If the PTS is advisory and not binding, then
the CFII's discretion will not have been significantly hampered.


The current FAR 61,57(d) was last revised in 1997. The change 2 of
the current PTS became effective in March 1999. AFS 640, the branch
of the FAA that sets training policy, told me during the last examiner
recertification seminar that the PTS is binding, and the task table
provided within sets the minimum areas of operation required to
complete an IPC. The term "representative tasks" are not at the
descretion of the CFI, but are the tasks already set out and dictated
by the task table. Nothing has changed with the upcomming change of
the task table except that the tasks have been reduced, not increased.

Don't take my word for it, call Oak City if you like, but don't hide
your head in the sand and say it isn't so out of wishful thinking. To
say that a Practical test STANDARD is not binding is laughable. Read
the top of the current task table. It specifically states which tasks
are required and MUST be tested during an IPC. You just never read it
before.

"Bill Zaleski" wrote in message
...

the current PTS became effective in March 1999. AFS 640, the branch
of the FAA that sets training policy, told me during the last examiner
recertification seminar that the PTS is binding, and the task table

Bill,

The question of whether the PTS is legally binding upon a CFII is a bit more
complex than this, as is often the case for areas where law and
administrative regulations overlap.


Your answer is sort of like saying you called a specific division of the IRS
for a ruling on a complex taxation and that gave you a definitive answer.
Actually, getting a definitive answer on federal tax regulations is quite
complex and often has gray areas until a court reaches a final decision.
Sometimes courts even give different answers in different districts around
the country.

It is very clear that the Advanced ATD concept was introduced after the 1999
PTS and that the Advanced ATD was intended for completing a full IPC. Yet
if the PTS is considered to be legally binding, the Advanced ATD cannot be
used for an IPC because a literal interpretation of the PTS requires landing
out of an approach for an IPC, yet no Advanced ATD and no FTD is approved
for landings. Thus if the PTS is legally binding then a huge percentage of
piston IPCs done at virtually every major simulator center in the past 5
years are invalid. And if the PTS is legally binding then the whole concept
of approving the Advanced ATD is inconsistent within the FAA's regulatory
framework.

I think the best answer is that there are some unclear or gray areas here
which need to be resolved.

Saying the PTS is obviously legally binding rather than advisory is like
saying the AIM is obviously legally binding. Do you believe items in the
AIM are advisory or binding?



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

www.flyimc.com

Do you believe items in the
AIM are advisory or binding?


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

I say this tongue in cheek, but it does seem to be the FAA way.

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

That is like saying that "Speed Limits are advisory, unless a cop is
around"....

Come to think of it, I guess they are!

Rich



Teacherjh wrote:
Do you believe items in the
AIM are advisory or binding?


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

I say this tongue in cheek, but it does seem to be the FAA way.

Jose

On Mon, 07 Jun 2004 11:48:39 GMT, "Richard Kaplan"
wrote:

"Bill Zaleski" wrote in message
.. .

the current PTS became effective in March 1999. AFS 640, the branch
of the FAA that sets training policy, told me during the last examiner
recertification seminar that the PTS is binding, and the task table

Bill,

The question of whether the PTS is legally binding upon a CFII is a bit more
complex than this, as is often the case for areas where law and
administrative regulations overlap.


Your answer is sort of like saying you called a specific division of the IRS
for a ruling on a complex taxation and that gave you a definitive answer.
Actually, getting a definitive answer on federal tax regulations is quite
complex and often has gray areas until a court reaches a final decision.
Sometimes courts even give different answers in different districts around
the country.

It is very clear that the Advanced ATD concept was introduced after the 1999
PTS and that the Advanced ATD was intended for completing a full IPC. Yet
if the PTS is considered to be legally binding, the Advanced ATD cannot be
used for an IPC because a literal interpretation of the PTS requires landing
out of an approach for an IPC, yet no Advanced ATD and no FTD is approved
for landings. Thus if the PTS is legally binding then a huge percentage of
piston IPCs done at virtually every major simulator center in the past 5
years are invalid. And if the PTS is legally binding then the whole concept
of approving the Advanced ATD is inconsistent within the FAA's regulatory
framework.

I think the best answer is that there are some unclear or gray areas here
which need to be resolved.

Saying the PTS is obviously legally binding rather than advisory is like
saying the AIM is obviously legally binding. Do you believe items in the
AIM are advisory or binding?



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

www.flyimc.com


So, in effect, you are saying that those who wrote the PTS are not in
a position to provide accurate information on it's use, validity, or
legality. Again, laughable. Who do you plan to go to for any
meaningful guidance? You've already said that the FSDO's don't know
how to handle queries on this issue. I recall giving you information
on the use of the FTD without an instructor present for currency that
you were steadfast against until the simulator branch confirmed to you
what you didn't want to hear. Time to use common sense here. It
wouldn't be called an STANDARD (PTS). if it wasn't a standard. Yup,
it's binding. Call 'em up like you finally did last time.