Changes in Instrument Proficiency Check Requirements

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)

Roy Smith wrote in message ...
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:


Actually, if you read the current PTS, you will notice that in the
table of tasks to be done, there is a column for IPC. Today, the PTS
spells out the IPC. You can call AOPA and hear it for yourself. Of
course you can argue the PTS is not regulatory. One guy tried to argue
that the AIM wasn't regulatory too. The NASA admin law judge didn't
seem to buy that story either. Right or wrong doesn't make any
difference, its all what the judge is going to say when you plead to
keep your ticket.

-Robert

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

Actually, if you read the current PTS, you will notice that in the
table of tasks to be done, there is a column for IPC. Today, the PTS
spells out the IPC. You can call AOPA and hear it for yourself. Of

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.


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

www.flyimc.com

"Bill Zaleski" wrote in message
...


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

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.


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

www.flyimc.com

(Robert M. Gary) wrote
One guy tried to argue that the AIM wasn't regulatory too.
The NASA admin law judge didn't seem to buy that story either.
Right or wrong doesn't make any difference, its all what the
judge is going to say when you plead to keep your ticket.

NASA law judge????? I trust that you meant to say "the NTSB
administrative law judge".....right?

Bob Moore

It appears that there is a written basis to support an IPC containing a
representative number of items from the PTS rather than the complete list.

The inspector's handbook 8700.1 allows approval of a Level 1 FTD (clearly
not approved for circling approaches or for landing out of an instrumetn
approach) to be used for a COMPLETE IPC. This order remains valid today
with the current PTS:


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

www.flyimc.com
"Bill Zaleski" wrote in message
...
Robert:

I mentioned this same thing when the thread was new, however my
comments fell on deaf ears. There has even been an article on Avweb
stating how the "new requirements" will impact the process. The
process has been in place since 1999 when the task pable came into
existance. Yes, the IPC is actually being relaxed as of October, not
expanded, as the original poster stated. Just shows you how alert
some of the CFII's are. There has not been any descretion in the IPC
process for a long time. As it stands now, an IPC is an instrument
practical test in it's entirety except for X-C flight planning, WX
information, timed turns, and steep turns. The dreaded circling
approach is nothing new in the requirement. The IPC is an open book
test, but nobody is reading the book.


On 4 Jun 2004 21:42:28 -0700, (Robert M. Gary) wrote:

(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