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Fri, May 28, 2004

Change In The Air

FAA Revises IFR Practical Test -- Many Sims Out

by Richard Kaplan, CFII, MCFI, Flight Level Aviation

The FAA has just released a revised version of the instrument rating practical test standards to become effective October 1, 2004:

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 or the CFII, as well as to adjust the IPC to items particularly important given a particular pilot's airplane, avionics, and missions. In other words, the IPC can be both a learning experience and a proficiency check.

The PTS now itemizes specific tasks which must be accomplished on an IPC. Among these tasks, a circling approach is now required. I see this as having several significant effects on the flight training industry, although as a principal and instructor in a simulator-based flight school I am interested in input from others not quite as directly affected:

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. In rigidly defining the tasks to be included in an IPC, the FAA has removed the CFII's discretion and turned the IPC into just another hurdle to overcome.

Recently the FAA granted approval to a new class of inexpensive training device called an Advanced AD - An Advanced AD is a PC computer-based trainer approved among other purposes to conduct an entire Instrument Proficiency Check, and an Advanced AD is much less expensive than more traditional full-scale Flight Training Devices or Simulators.  An Advanced AD will no longer be able to function to conduct an entire IPC because no Advanced AD is approved for circling approaches. Thus schools or individuals who very recently bought an Advanced AD will not be able to utilize such a device for the intended purpose, nor does there appear to be a grandfather clause in the PTS.

There exist a number of flight schools (including my own -- full disclosure) which offer advanced simulator-based training in either full-motion or non-motion Flight Training Devices or Simulators. These devices cost anywhere from $100,000 to over $1,000,000 and are typically approved to conduct a full Instrument Proficiency Check. With the new IFR PTS, these devices will no longer be legal to conduct a full Instrument Proficiency Check because many (most?) do not have a wide wraparound visual display.  Adding such a visual display would cost tens of thousands of dollars and might still not be feasible at any price in the case of the more expensive devices with enclosed cockpits. One work around would be to use these devices to log IFR Currency instead of an IPC, but that would not work if a pilot is more than 6 months out of currency.

Another work around would be to conduct a circling approach in an airplane, yet weather or maintenance issues might make that impractical in some situations. Imagine traveling hundreds of miles for specialized recurrent training in a sophisticated training device but being unable to be signed off for an IPC due to a technical change in FAA rules. Or imagine investing a 6-digit or 7-digit sum in a training device, only to have the FAA quickly change the rules and make the device suddenly illegal for its originally approved purpose.

Is it desirable for the FAA to require IFR pilots to practice circling approaches at every IPC?  High visibility circling approaches are far less critical a skill to maintain than flying a partial panel non-precision approach. Low visibility circling approaches are risky enough that many corporate and airline flight departments do not permit such approaches. By requiring circling approaches at each IPC, will we be encouraging a circling approach as a "normal" IFR procedure alongside straight-in CLS approaches?

FMI: http://av-info.faa.gov/data/practicalteststandard/faa-s-8081-4d.pdf, www.flyimc.com

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