Clarification of IPC Requirements

FAA published several updates to IFR currency requirments in June 2018. One of the changes, to 14 CFR Part 61.57(d), removed the reference to the Instrument Rating ACS, which includes both guidance and a task table in appendix A that specifies the areas of operation that must be completed to accomplish an instrument proficiency check.

The change to the language of 14 CFR Part 61.57(d), however, implied that the task table no longer applied, and I wrote the FAA to ask for clarification. Here is the response that I received on October 17, 2018:

Question 1.

Does the table in the IFR ACS (p. A-12) still apply? In other words, must an IPC candidate demonstrate all of the tasks specified in that table, or does the CFII administering the IPC have discretion (as when conducting a flight review) to select specific tasks from the areas codified in 61.57(d)?

Answer: Yes. The tasks identified on page A-12 of the Instrument ACS, for the successful completion of an Instrument Proficiency Check (IPC), is still applicable. Just as 61.65(c) describes the areas of operation that a pilot must show proficiency in for the instrument rating practical test, the Airman Certification Standards (ACS) provides the tasks, details, and level of proficiency required for successful completion of that practical test. This includes what tasks must be accomplished for the successful completion of a IPC, and the associated proficiency standards applicable to the areas of operation identified in 61.57(d).

Question 2.

Do the limitations on the use of ATDs and FTDs noted in the IFR ACS still apply? For example, most ATDs are not approved for circle-to-land approaches. But if a CFII chooses not to include c-t-l tasks during an IPC, can the instructor the IFR pilot receiving and IPC, complete the IPC in an FTD that is otherwise approved for instrument training and proficiency, especially given the changes to § 67.57(c) that will become effective in November?

Answer: Yes, those limitations still apply. The FAA letter of authorization (LOA) provided for each model ATD, references part 61.57(d) and the ACS/PTS requirements when accomplishing an IPC in an AATD. A flight instructor could complete the IPC in a qualified FTD that is approved for instrument training and proficiency. The revised 61.57 (d) rule that becomes effective November 27, 2018, allows for any combination of aircraft, FFS, FTD, and/or ATD to accomplish the instrument experience requirements.

Question 3.

Does the FAA plan to update its guidance for conducting IPCs in the IFR ACS, AC 61-98D, and IPC Guidance (v.1.1 March 2010)?

Answer: The guidance for the appropriate and successful conduct of a IPC, as described in AC 61-98D and the IPC Guidance, remains valid. It is possible that updates to this guidance may be provided, as input from the field and industry comes forward. We continue to promote scenario based training to proficiency, to otherwise improve safety during IFR flight operations and reduce the accident rate.

Sincerely,

Marcel Bernard
Aviation Safety Inspector
Aviation Training Device (ATD) National Program Manager

My original email to the FAA, which provided additional background, appears below.

14 CFR Part 61.57(d) governing IPCs was revised effective July 27, 2018. The text of the regulation now reads:

(d) Instrument proficiency check. (1) Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check. The instrument proficiency check must consist of at least the following areas of operation:

(i) Air traffic control clearances and procedures;

(ii) Flight by reference to instruments;

(iii) Navigation systems;

(iv) Instrument approach procedures;

(v) Emergency operations; and

(vi) Postflight procedures.

When the new regulations were published in the Federal Register, the discussion of the changes to § 61.57(d) included the following text:

In § 61.57(d), the FAA is removing the reference to the PTS. The FAA recognizes that it was inappropriate for § 61.57(d) to state that the areas of operation and instrument tasks were required in the instrument rating PTS. The PTS and ACS do not contain regulatory requirements. Therefore, rather than referencing the instrument rating ACS in § 61.57(d), the FAA is codifying in § 61.57(d) the areas of operation for an IPC. The FAA finds that this revision is not a substantive change because the areas of operation and instrument tasks required for an IPC remain unchanged. Thus, an IPC is still driven by the standards for the instrument rating practical test.

I am among the instructors who are confused by the above statement. As you know the current Instrument-Airplane ACS includes a table (p. A-12) that outlines the specific Tasks required to accomplish an IPC. Those Tasks include a circle-to-land approach, recoveries from unusual attitudes, and other “flight activities” that are also described, for example, in the checklist in AC 61-98D Appendix J.

The background text from the Federal Register notes that “…an IPC is still driven by the standards for the instrument rating practical test” (emphasis added). I take that to mean that pilots must meet the ACS standards for maintaining altitude, heading, speed, tracking courses, etc. while performing various tasks.

I note that the background text in the Federal Register says that “the areas of operation and instrument tasks required for an IPC remain unchanged.”

But the language of the revised language and the background text in the Federal Register support the idea that § 61.57(d) now codifies the areas of operation for an IPC. However, the list in the updated regulation does not specifically include a circle-to-land approach, recoveries from unusual attitudes, and other details listed in the ACS table and AC 61-98D. This disagreement raises two important questions:

1)     Does the table in the IFR ACS (p. A-12) still apply? In other words, must an IPC candidate demonstrate all of the tasks specified in that table, or does the CFII administering the IPC have discretion (as when conducting a flight review) to select specific tasks from the areas codified in 67.57(d)?

2)     Do the limitations on the use of ATDs and FTDs noted in the IFR ACS still apply? For example, most ATDs are not approved for circle-to-land approaches. But if a CFII chooses not to include c-t-l tasks during an IPC, can the instructor the IFR pilot receiving and IPC, complete the IPC in an FTD that is otherwise approved for instrument training and proficiency, especially given the changes to § 67.57(c) that will become effective in November?

Finally, to clarify the above questions, does the FAA plan to update its guidance for conducting IPCs in the IFR ACS, AC 61-98D, and IPC Guidance (v.1.1 March 2010)?