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?
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