Changes in Instrument Proficiency Check Requirements

"Teacherjh" wrote in message
...

Apples and oranges. The sim thing has to do with currency checks only.
Mode S
affects flying itself. You are just complaining that your profit center
got
weaker.

The underlying concept is far more significant and widespread than just my
particular business model -- it affects everyone involved in any area of
aviation.

Actually, my particular business model would be minimally affected even if
there were a definitive ruling that the PTS is binding upon a CFII; most of
my students are within 6 months of currency so using my FTD to log IFR
Currency would serve the same purpose as an IPC, and I also try to fly in an
airplane with my students whenever possible in addition to the FTD.

The much bigger issue though is the question of the the FAA arbitrarily and
on relatively short notice changing some standard or rule in the name of
safety. What if they all of a sudden required all A&P mechanics to have a
repair station license and prohibited indepdendent A&Ps? What if they
prohibited Part 61/91 training and required all instruction to be in a Part
141/142 environment? What if they decided as of next year your airplane had
to be modified to meet today's certification requirements instead of the
requirements as of the day your airplane received its type certificate? You
could make an argument in the name of "safety" for all of these situations.


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

www.flyimc.com

"Richard Kaplan" wrote
(1) By granting discretion to a CFII, an IPC can currently serve not only
as a proficiency check but also as an opportunity for instruction or for a
pilot to try a new skill relevant to his IFR operations.

True. On the other hand, it can also allow a CFII to sign off an ICC
that consists of a single full-panel vectors-to-final ILS approach.
I've seen it done. There is a very real reason why the discretion
CFII's have on an IPC has been reduced - too many CFII's were abusing
it, and signing off people who did not meet even the very minimal PTS
standards. In fact, I would argue that those CFII's were always far
more numerous than those who made the IPC a true advanced training
experience. This is always the problem with rules - removing the
discretion assures some minimum standard for those doing it wrong, at
the expense of making things worse for those genuinely trying to do it
right. Once you accept that having rules is a good thing (I don't),
it's a bit late to argue that a new rule change removes too much of
your discretion.

(2) Recently the FAA granted approval to a new class of inexpensive
training device called an Advanced ATD - An Advanced ATD is a PC
computer-based trainer approved among other purposes to conduct an entire
Instrument Proficiency Check, and an Advanced ATD is much less expensive
than more traditional full-scale Flight Training Devices or Simulators. An
Advanced ATD will no longer be able to function to conduct an entire IPC
because no Advanced ATD is approved for circling approaches.

Yeah, that's rough. Some aviation businesses/individuals made
investments in equipment whose capability was reduced due to FAA fiat.
However, once you accept that it's legitimate for the FAA to change
the rules, such as by issuing emergency AD's, (and again I don't) it's
a little too late to make the argument that people who made
investments assuming the old rules would apply are now hurt
financially. Think of all the people who bought T-34's, complied with
the first series of AD's, and now have had the value of their
investment dramatically reduced - all because of an accident that
occurred to a T-34 that DID NOT have the AD's complied with and was
probably being operated outside the design envelope in any case.

(4) Is it desirable for the FAA to require IFR pilots to practice circling
approaches at every IPC?

I think this is really the crux of the issue, and the only valid point
you have made. Is recurrent training on circling approaches a
safety-critical issue? I think it's worth exploring in detail.

High visibility circling approaches are far less
critical a skill to maintain than flying a partial panel non-precision
approach.

I agree completely, but the partial panel non-precision approach is
also required.

Low visibility circling approaches are risky enough that many
corporate and airline flight departments do not permit such approaches.

I concur with your observation but not with your reasoning. The
elimination of low visibility circling approaches dates to the time
when training in the airplane was superseded by training in the
simulator. The simulators of the time simply didn't have adequate
visuals to realistically simulate circling approaches. Nobody really
wanted to keep training in the airplanes for financial reasons, and
circling approaches were not considered important for the kinds of
destinations the airlines served.

Those corporate flight departments that have a need to serve airports
where circle to land is often required train for them and do them;
those that don't have a need don't bother.

Circling approaches are inherently more difficult to do, and provide a
reduced margin of error, in heavier and faster airplanes with poor
outside visibility. They are not all that difficult to do in the
light piston airplanes we fly, and in fact lots of corporate flight
departments that operate piston singles and twins train for and allow
circling approaches.

By
requiring circling approaches at each IPC, will we be encouraging a circling
approach as a "normal" IFR procedure alongside straight-in ILS approaches?

At my home field, a circling approach is a normal IFR procedure - in
fact the only IFR procedure available. Such airports are non-existent
for the airlines, rare for major corporate flight departments, but
quite common for GA use. Further, while GPS may eliminate this out in
the boonies, it will never do so in major metropolitan areas where the
position of the final approach course is all about minimizing impact
on the major Class B fields.

Therefore, I forsee the necessity for circling approaches extending
into the forseeable future, and thus think that recurrent training in
them is important. It is certainly a part of my recurrent training
cycle, under maximally adverse conditions (single engine and partial
panel). I do not consider it unreasonable to include the circling
approach as an IPC requirements.

Michael

What if ....

Then I would have a separate opinion on each of these proposals. Some I might
favor, some I might not. However the thrust of the original post is that it
impacts the business of simulator IPCs. I don't have much sympathy for that.

Jose

--
(for Email, make the obvious changes in my address)

"Michael" wrote in message
om...

experience. This is always the problem with rules - removing the
discretion assures some minimum standard for those doing it wrong, at
the expense of making things worse for those genuinely trying to do it
right. Once you accept that having rules is a good thing (I don't),
it's a bit late to argue that a new rule change removes too much of
your discretion.

I do not think there is any profession that has been improved by removing
discretion or judgment.

Come to think of it, maybe that is why this new PTS hit such a nerve with
me -- it seems as if the FAA is starting to micro-manage CFIs just like
managed care tries to micro-manage my judgment as a physician. Neither is
likely to improve the quality of the underlying service.

CFIs who will sign off an IPC today based on only a vectored ILS will still
do so after October 1 and would still do so even if 61.57(d) were made more
restrictive; limiting CFI judgment only hurts those CFIs who are trying to
do it right to the best of their ability and judgment.

While we are at it though, why not require specific tasks for a BFR as well
as an IPC?


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

www.flyimc.com

"Michael" wrote in message
om...

Therefore, I forsee the necessity for circling approaches extending
into the forseeable future, and thus think that recurrent training in
them is important. It is certainly a part of my recurrent training

How helpful do you think practicing a circling approach on a CAVU day is in
preparing you to fly a circling approach on a low visibility day?

Circling in CAVU weather is basically a matter of flying a tight pattern at
a lower than usual pattern altitude. There is somewhat of a learning curve
needed especially in a hilly or mountainous area, but this is not
particularly challenging in my opinion for it to take precedence over any
number of other items not mandated in the new PTS.

On the other hand, a circling approach in low visibility is indeed a
challenge even in a piston airplane. One of the reasons it is a challenge
is that it is so difficult to train for this effectively either in the
airplane or in a piston FTD/simulator. I do not think the new PTS solves
this problem.



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

www.flyimc.com

"Richard Kaplan" wrote
I do not think there is any profession that has been improved by removing
discretion or judgment.

I don't disagree. However, it's a mistake to call the average CFII a
professional. He is at best an apprentice.

Come to think of it, maybe that is why this new PTS hit such a nerve with
me -- it seems as if the FAA is starting to micro-manage CFIs just like
managed care tries to micro-manage my judgment as a physician. Neither is
likely to improve the quality of the underlying service.

I don't think this is the same thing at all - after all, the goal of
managed care is reduced cost. Quality is irrelevant. The goal here
is to improve quality, and the need is real. The solution, like most
FAA solutions, is incompetent. Remember when the decision was made to
have all initial CFI rides done with the FAA?

CFIs who will sign off an IPC today based on only a vectored ILS will still
do so after October 1 and would still do so even if 61.57(d) were made more
restrictive

That's the one area where I do not concur. I think that setting out
specific rules will stop that in most cases. It won't stop the CFII
willing to lie to sign off his buddy (you would be amazed how many
BFR's are done in a bar rather than an airplane, though I know of no
ICC's being done that way - yet) but it will stop the CFII who doesn't
know any better.

While we are at it though, why not require specific tasks for a BFR as well
as an IPC?

It would not surprise me in the least if this were to happen.

Michael

"Richard Kaplan" wrote
How helpful do you think practicing a circling approach on a CAVU day is in
preparing you to fly a circling approach on a low visibility day?

Better than nothing, but far from optimal. On the other hand, you can
get about a 90% simulation on an overcast night with a little haze
and/or mist. Even a clear night gets you a good simulation if you
pick your airport carefully (meaning in a poorly lit area).

Circling in CAVU weather is basically a matter of flying a tight pattern at
a lower than usual pattern altitude. There is somewhat of a learning curve
needed especially in a hilly or mountainous area, but this is not
particularly challenging in my opinion for it to take precedence over any
number of other items not mandated in the new PTS.

I have two issues with this argument. First, there is the transition
issue. There's a pretty big difference between circling in a
Skyhawk-class airplane and a Bonanza-class airplane, and much of that
difference can be taught in CAVU. Practically all of it can be taught
at night.

Second, I can't think of anything more important than circling (even
in CAVU) that is not already required.

On the other hand, a circling approach in low visibility is indeed a
challenge even in a piston airplane. One of the reasons it is a challenge
is that it is so difficult to train for this effectively either in the
airplane or in a piston FTD/simulator. I do not think the new PTS solves
this problem.

The FAA doesn't ever solve problems. At best, by taking action it
might raise awareness that the problem exists without making it
substantially worse. The new PTS has, in fact, raised awareness -
people are discussing this, and that's positive. The question is, has
the FAA made the problem substantially worse. I'm not sure about
that. I doubt that the people getting recurrent sim training really
NEED an IPC from a regulatory standpoint anyway, so I doubt much
damage is being done.

Michael

"Richard Kaplan" wrote in message ws.com...
The FAA has just released a revised version of the instrument rating
practical test standards to become effective October 1, 2004:



http://av-info.faa.gov/data/practica...-s-8081-4d.pdf



Included in the footnotes of this new PTS is a substantial change in the
requirements for an Instrument Proficiency Check.



Currently a CFII conducting an IPC is permitted to use his discretion in
asking a pilot to demonstrate a reasonable selection of items from the PTS.
This seems reasonable in order to adjust the IPC to pilot
strengths/weaknesses which are perceived by either the pilot

My PTS that is almost 4 years old had this. I think this has always
been there, I think people just haven't noticed. You need to look at
the table that talks about what items have to be done for an airplane
instrument if you already have a rotocraft instrument. There is
another table called PC that is for IPC. It spells out the IPC pretty
easily.

-Robert, CFI

(Michael) wrote in message . com...
"Richard Kaplan" wrote
(1) By granting discretion to a CFII, an IPC can currently serve not only
as a proficiency check but also as an opportunity for instruction or for a
pilot to try a new skill relevant to his IFR operations.

True. On the other hand, it can also allow a CFII to sign off an ICC
that consists of a single full-panel vectors-to-final ILS approach.
I've seen it done. There is a very real reason why the discretion
CFII's have on an IPC has been reduced - too many CFII's were abusing
it, and signing off people who did not meet even the very minimal PTS
standards.


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.

-Robert, CFI

"Richard Kaplan" wrote in message ws.com...
The FAA has just released a revised version of the instrument rating
practical test standards to become effective October 1, 2004:



http://av-info.faa.gov/data/practica...-s-8081-4d.pdf



Included in the footnotes of this new PTS is a substantial change in the
requirements for an Instrument Proficiency Check.


Hey, it looks like they greatly reduced the items required for an IPC.
The old IFR PTS included a lot more items on the proficiency check!
This will make IPCs go much faster.

Our local DE claims the FAA is working on a PTS standard for BFRs
right now. It will be from the private/commercial PTS. That will mean
that a commercial rated pilot will have a higher standard BFR than a
private.
-Robert