In April, 2004, the FAA updated and revised the Practical Test Standards (“PTS”) for the Instrument Rating. The new standards went into effect October 1, 2004. Of particular interest to instrument flight instructors (“CFII’s”) and pilots holding instrument ratings is a substantial change in the requirements for administering an Instrument Proficiency Check (“IPC”).
Prior to October 1, 2004, a CFII had discretion regarding what PTS tasks he or she could require for an instrument rated pilot to demonstrate instrument proficiency. That discretion allowed a CFII to be flexible in order to accommodate/address a pilot's strengths/weaknesses, as well as the pilot’s aircraft, instrumentation and intended missions. That is, the CFII was allowed to decide what tasks the pilot needed to accomplish in order to show the CFII that the pilot could competently operate an aircraft solely with reference to the instruments.
Although this discretion presented the opportunity for a CFII to conduct an IPC with minimal demonstration of ability by the pilot, most CFII’s required pilots to demonstrate sufficient skills and competence to show that they could safely fly in instrument meteorological conditions (“IMC”). After all, no responsible CFII wanted to be the last IPC sign-off in a pilot’s logbook if the pilot was later in an accident or incident: Too many questions to answer and potential liability for the CFII.
However, the revised PTS no longer give the CFII discretion in how an IPC is to be conducted or the tasks to be performed. The current PTS now require completion of specific tasks including holds, unusual attitudes, intercepting nav-aids and dme-arcs, precision, non-precision and circling approaches, partial- panel and review of instruments and aircraft equipment.
Unfortunately, the removal of the CFII’s discretion seems to convert what used to be a learning experience tailored to a pilot and his or her needs into what is more closely akin to an actual check-ride. Under the prior PTS, a student and instructor could discuss and determine the appropriate and/or necessary tasks to ensure that the pilot could demonstrate the necessary competency to pass an IPC. This allowed a pilot to use the IPC as a learning tool by agreeing with the instructor to review or practice specific tasks on which the pilot may have felt he or she needed additional practice.
Under the revised PTS, all of the designated tasks must now be satisfactorily completed. Although a pilot and instructor can still tailor the IPC to focus on tasks needing additional work, the remainder of the designated tasks will still need to be completed. This will increase the time required for an IPC and may deter pilots from spending the time and money for additional practice of specific tasks.
Another concern is the requirement that an IPC candidate must now perform a circling approach. Unfortunately, this eliminates the opportunity for an IPC candidate to fully complete an IPC using a computer-based trainer such as an Advanced AD. Although an Advanced AD will still qualify for completion of a majority of the IPC requirements, if it does not have a wide, wrap-around display, a circling approach will be impossible and this portion of the IPC will need to either be demonstrated in an aircraft or in a simulator that is equipped for such an approach.
This new requirement also has the potential to increase the cost of an IPC for a pilot. If the pilot does not have access to an appropriate computer based trainer, he or she will need to perform a circling approach in an aircraft.
The revised PTS are here and are the standards for conducting an IPC. Pilots should keep in mind that an IPC sign-off received after October 1, 2004 that does not comply with the revised PTS will not be valid and may leave the pilot operating without instrument currency. Both pilots and their instructors should review the revised PTS to fully understand what tasks are required for an IPC.
As always, fly safe and fly smart.
About the Author
Greg is an aviation attorney, author and holds a commercial pilot certificate with instrument rating. His handles aviation litigation, including insurance matters and creditor’s rights, FAA certificate actions and aviation related transactional matters. He can be reached via e-mail at greigel@aerolegalservices.com or check out his website at www.aerolegalservices.com.
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