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

"Barry" wrote in message ...

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.

Yes, but per the FAA Inspector's Handbook one of the original acceptable
uses is a complete IPC so now an FTD will remain "restricted" to this use.
So for example an IPC will remain possible in a Level 1 FTD but for the
purpose of an IFR checkride the FTD will not be usable for a circling
approach because a circling approach was not originally an explicitly
approved maneuver. This is the text from the Inspector's handbook:


B. For use under 14 CFR§ 61.57(d)(1)(ii). Regulatory authorization for pilot
use of a level 1 FTD to conduct all or part of an instrument competency
check, consisting of a representative number of tasks required for the
instrument rating practical test when given by an authorized instructor:
. Aviation Simulation Technology, Inc.: AST 201 and 300 Models
. ATC Flight Simulator Company: ATC 112H, 610, 710, 810, and 920 Models
. Frasca International, Inc.: 121, 122, 131, 132, 141, 142, 241, 242,
242T, and 342 Models
. Pacer Systems Corporation: MK II Models



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

www.flyimc.com

B. For use under 14 CFR§ 61.57(d)(1)(ii). Regulatory authorization for pilot
use of a level 1 FTD to conduct all or part of an instrument competency
check, consisting of a representative number of tasks required for the
instrument rating practical test when given by an authorized instructor:


Seems to me that the phrase "consisting of a representative number of tasks"
modifies "instrument competency check", and the correct English parsing of the
sentense would restrict the use only to those IPCs which consist of a
representative number of tasks. IPCs which do not would not be permitted.

It could (of course) be argued that since "all the tasks" is representative of
the required tasks, that an IPC which consists of all the tasks is also an IPC
which consists of a representative number of tasks.

Isn't language wonderful!

Jose
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