Another Update on IPCs

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:

1. 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);
2. 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
3. Submit an editorial revision correcting this matter at the time of the next approved revision period for AC 61-98D.

Draft Advisory Circulars: Flight Reviews, FIRCs, etc.

The FAA has published several draft ACs of interested to general aviation pilots and flight instructors. The documents are available for review and comment at the FAA website, here.

•  AC 61-98C, Currency Requirements and Guidance for the Flight Review and Instrument Proficiency Check. This advisory circular (AC) provides information for certificated pilots and flight instructors to use in complying with the flight review required by Title 14 of the Code of Federal Regulations (14 CFR) part 61, § 61.56 and the recent flight experience requirements of § 61.57. This AC is particularly directed to General Aviation (GA) pilots holding sport or higher grades of pilot certificates who wish to maintain currency and to certificated flight instructors (CFI) who give flight instruction to support such activities. This AC does not apply to training programs or proficiency checks conducted pursuant to 14 CFR part 121 or 135, nor to curriculums approved pursuant to 14 CFR part 142.
• AC 61-83H: Nationally Scheduled, FAA-Approved, Industry-Conducted Flight Instructor Refresher Course. This advisory circular (AC) provides information and standards for the preparation and approval of training course outlines (TCO) for Federal Aviation Administration (FAA)-approved, industry conducted flight instructor refresher courses (FIRC) in accordance with Title 14 of the Code of Federal Regulations (14 CFR) part 61, § 61.197(a)(2)(iii).

Two additional ACs, although directed primarily at air carriers, are nevertheless of interest to all pilots and instructors:

• AC 120-UPRT, Upset Prevention and Recovery Training. AC 120-UPRT provides guidance to air carriers for the implementation of the new requirements in the Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers (part 121 subpart N&O) final rule (provisions §§ 121.419, 121.423, and 121.427) to provide pilots with ground and flight training on upset. The AC also provides guidance for some of the flight instructor training requirements contained in §§ 121.412 and 121.414.
• AC 120-109A, Stall Prevention and Recovery Training. The revision of AC 120-109 provides guidance to air carriers for the implementation of the new requirements in the Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers (part 121 subpart N&O) final rule (provisions §§ 121.419, 121.423, and 121.427) to provide pilots with ground and flight training on stall prevention and recovery.