Changes to the wording of 14 CFR Part 61.57(d) in July 2018 caused confusion among some flight instructors about which tasks are now required when administering an instrument proficiency check (IPC). I earlier wrote about a question that I posed to FAA and the agency’s response in Clarification of IPC Requirements.
As that post notes, the FAA still requires an IPC to include the tasks listed in Appendix A of the Instrument Rating-Airplane ACS.
FAA released an editorial update to AC 61-98D Currency Requirements and Guidance for the Flight Review and Instrument Proficiency Check, but Appendix J of that document still referenced the old language of 14 CFR Part 61.57(d), so I wrote FAA again to point out the error and ask for clarification.
Here’s part of the response that I received via email:
Background. As stated in the preamble discussion addressing the revised regulatory text language in § 61.57(d), “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.” For instance, just as § 61.65(c) describes the areas of operation that a pilot must meet to complete the instrument rating practical test successfully, the ACS provides the required tasks, details, and level of proficiency for successful completion of that practical test. The Instrument Rating ACS also include the tasks that a pilot must accomplish for the successful completion of an IPC, as well as providing the associated proficiency standards applicable to the areas of operation identified in §61.57(d). Bear in mind that § 61.43(a)(3), Practical tests: General procedures, require examiners to conduct evaluations under approved standards. It states, “(a) Completion of the practical test for a certificate or rating consists of—3) Demonstrating proficiency and competency within the approved standards.” Applicable ACS/PTS documents provide FAA approved standards. In this same manner, the FAA provides the standards by which an authorized instructor must conduct an IPC. Therefore, the FAA still requires the use of applicable ACS/PTS to provide the tasks and standards for an IPC. The tasks required for an IPC are still driven by the approved standards for the instrument rating practical test.
Response. In review of your feedback, our office determined that your observation is correct. The FAA did not update the regulatory reference to § 61.57(d) in AC 61-98D, Appendix J, which can cause confusion. To correct this inaccuracy, we will:
- Revise AC 61-98D by correcting its reference to § 61.57(d) containing obsolete regulatory text and replace it with the current regulatory text in § 61.57(d);
- Provide additional information explaining the basis for the requirement to use the approved standards provided by ACS/PTS, as applicable, in the conduct of an IPC; and
- Submit an editorial revision correcting this matter at the time of the next approved revision period for AC 61-98D.
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