AIM Updates 28 February 2019

FAA has published changes to the AIM effective 28 February 2019. You can download the PDF that lists the changes and includes all of the updated text. The updates of most interest to general aviation pilots focus on the following sections.

1−2−1. General

1−2−2. Required Navigation Performance (RNP)

5−2−9. Instrument Departure Procedures (DP) − Obstacle Departure Procedures (ODP), Standard Instrument Departures (SID), and Diverse Vector Areas (DVA)

5−4−1. Standard Terminal Arrival (STAR) Procedures

5−4−5. Instrument Approach Procedure (IAP) Charts

There was not enough adequate information concerning Performance−Based Navigation (PBN) and Advanced Required Navigational Performance (A−RNP) available to flight crews and operators in the AIM. This expansion in the description and advantages of these navigation specifications (NavSpecs) will provide better guidance as to what A−RNP is, how it will be applied, and its applicability in the PBN NAS. Additional information is being added to better clarify NavSpecs, RNP, and PBN understanding in AIM Chapter 1. Associated paragraph changes are necessary to ensure harmonization between all the paragraphs in the AIM.

5−1−8. Flight Plan (FAA Form 7233−1) − Domestic IFR Flights

This change updates pilot guidance to incorporate air traffic control (ATC) procedures for GNSS−equipped aircraft operating on area navigation (RNAV) air traffic service (ATS) routes and on random point−to−point and random impromptu routes in airspace in which ATC procedures are applied, excluding oceanic airspace. This change also incorporates the use of the term GNSS in place of RNAV for space−based positioning and navigation systems.

Area Navigation, RNAV, RNP, and A-RNP

AIM 1−2−1 includes new explanations of RNAV and performance-based navigation (PBN). Before reviewing the new information in this section of the AIM, it’s important to remember that AIM 1−1−17. Global Positioning System (GPS) notes that:

(5) Aircraft navigating by IFR−approved GPS are considered to be performance−based navigation (PBN) aircraft and have special equipment suffixes.

The specific capabilities of the GNSS (GPS) in your panel are described in the AFM Supplement and operating handbooks for the equipment (as updated when new system software is installed). You can find more information about RNAV and RNP specs in AC 90-105 and at RNP Procedures and Typical Part 91 Pilots here at BruceAir.

With that in mind, it’s important to understand that if your airplane is equipped with, say, a Garmin GNS530W/GNS530W or GTN 750/650 (with an appropriate AFM supplement), you can fly RNAV SIDs and STARs based on RNP-1 criteria. And you can also fly en route segments that require RNP-2 accuracy. No special authorization is required at these RNP levels.

For more information about RNP levels, see “Required Navigation Performance” in the Instrument Procedures Handbook (2-34).

IPH-RNP Levels

Figure 9-41 in the Instrument Flying Handbook is also helpful.

IFH-Fig9-41

Update to AIM 1−2−1. General

Here’s the new language in AIM 1-2-1, the introduction to PBN. Note that RAIM, used to validate the accuracy and reliablity of non-WAAS GPS for use under IFR, qualifies as “onboard performance monitoring and alerting capability” for purposes of PBN and basic RNP. WAAS, which incorporates its own performance and accuracy checking system, also provides onboard performance monitoring and alerting capability.

a. Introduction to PBN. As air travel has evolved, methods of navigation have improved to give operators more flexibility. PBN exists under the umbrella of area navigation (RNAV). The term RNAV in this context, as in procedure titles, just means “area navigation,” regardless of the equipment capability of the aircraft…Many operators have upgraded their systems to obtain the benefits of PBN. Within PBN there are two main categories of navigation methods or specifications: area navigation (RNAV) and required navigation performance (RNP). In this context, the term RNAV x means a specific navigation specification with a specified lateral accuracy value. For an aircraft to meet the requirements of PBN, a specified RNAV or RNP accuracy must be met 95 percent of the flight time. RNP is a PBN system that includes onboard performance monitoring and alerting capability (for example, Receiver Autonomous Integrity Monitoring (RAIM)). PBN also introduces the concept of navigation specifications (NavSpecs) which are a set of aircraft and aircrew requirements needed to support a navigation application within a defined airspace concept. For both RNP and RNAV NavSpecs, the numerical designation refers to the lateral navigation accuracy in nautical miles which is expected to be achieved at least 95 percent of the flight time by the population of aircraft operating within the airspace, route, or procedure. This information is detailed in International Civil Aviation Organization’s (ICAO) Doc 9613, Performance−based Navigation (PBN) Manual and the latest FAA AC 90−105, Approval Guidance for RNP Operations and Barometric Vertical Navigation in the U.S. National Airspace System and in Remote and Oceanic Airspace.

Required Navigation Performance (RNP)

Here’s the new language in AIM 1−2−2.

a. General. While both RNAV navigation specifications (NavSpecs) and RNP NavSpecs contain specific performance requirements, RNP is RNAV with the added requirement for onboard performance monitoring and alerting (OBPMA). RNP is also a statement of navigation performance necessary for operation within a defined airspace. A critical component of RNP is the ability of the aircraft navigation system to monitor its achieved navigation performance, and to identify for the pilot whether the operational requirement is, or is not, being met during an operation. OBPMA capability therefore allows a lessened reliance on air traffic control intervention and/or procedural separation to achieve the overall safety of the operation. RNP capability of the aircraft is a major component in determining the separation criteria to ensure that the overall containment of the operation is met. The RNP capability of an aircraft will vary depending upon the aircraft equipment and the navigation infrastructure. For example, an aircraft may be eligible for RNP 1, but may not be capable of RNP 1 operations due to limited NAVAID coverage or avionics failure. The Aircraft Flight Manual (AFM) or avionics documents for your aircraft should specifically state the aircraft’s RNP eligibilities. Contact the manufacturer of the avionics or the aircraft if this information is missing or incomplete. NavSpecs should be considered different from one another, not “better” or “worse” based on the described lateral navigation accuracy. It is this concept that requires each NavSpec eligbility to be listed separately in the avionics documents or AFM. For example, RNP 1 is different from RNAV 1, and an RNP 1 eligibility does NOT mean automatic RNP 2 or RNAV 1 eligibility. As a safeguard, the FAA requires that aircraft navigation databases hold only those procedures that the aircraft maintains eligibility for. If you look for a specific instrument procedure in your aircraft’s navigation database and cannot find it, it’s likely that procedure contains PBN elements your aircraft is ineligible for or cannot compute and fly. Further, optional capabilities such as Radius−to−fix (RF) turns or scalability should be described in the AFM or avionics documents. Use the capabilities of your avionics suite to verify the appropriate waypoint and track data after loading the procedure from your database.

RNP Approach (RNP APCH) and RNP AR APCH

The new language in this section of the AIM intends to address confusion about RNP and approaches. Unfortunately, because FAA continues to use RNAV in procedure titles, many pilots remain puzzled about the differences between the terms RNAV, RNP APCH, and RNP AR APCH. As this part of the revised AIM 1−2−2 notes:

In the U.S., RNP APCH procedures are titled RNAV (GPS) and offer several lines of minima to accommodate varying levels of aircraft equipage: either lateral navigation (LNAV), LNAV/vertical navigation (LNAV/VNAV), Localizer Performance with Vertical Guidance (LPV), and Localizer Performance (LP).

A helpful guide from FAA, Required Navigation Performance (RNP) Approaches (APCH), succinctly explains the different lines of minimums and provides helpful links to ACs, the AIM, and other sources.

Here’s the detailed language in the updated AIM:

(1) RNP Approach (RNP APCH). In the U.S., RNP APCH procedures are titled RNAV (GPS) and offer several lines of minima to accommodate varying levels of aircraft equipage: either lateral navigation (LNAV), LNAV/vertical navigation (LNAV/VNAV), Localizer Performance with Vertical Guidance (LPV), and Localizer Performance (LP). GPS with or without Space−Based Augmentation System (SBAS) (for example, WAAS) can provide the lateral information to support LNAV minima. LNAV/VNAV incorporates LNAV lateral with vertical path guidance for systems and operators capable of either barometric or SBAS vertical. Pilots are required to use SBAS to fly to the LPV or LP minima. RF turn capability is optional in RNP APCH eligibility. This means that your aircraft may be eligible for RNP APCH operations, but you may not fly an RF turn unless RF turns are also specifically listed as a feature of your avionics suite. GBAS Landing System (GLS) procedures are also constructed using RNP APCH NavSpecs and provide precision approach capability. RNP APCH has a lateral accuracy value of 1 in the terminal and missed approach segments and essentially scales to RNP 0.3 (or 40 meters with SBAS) in the final approach. (See Paragraph 5−4−18, RNP AR Instrument Approach Procedures.)

(2) RNP Authorization Required Approach (RNP AR APCH). In the U.S., RNP AR APCH procedures are titled RNAV (RNP). These approaches have stringent equipage and pilot training standards and require special FAA authorization to fly. Scalability and RF turn capabilities are mandatory in RNP AR APCH eligibility. RNP AR APCH vertical navigation performance is based upon barometric VNAV or SBAS. RNP AR is intended to provide specific benefits at specific locations. It is not intended for every operator or aircraft. RNP AR capability requires specific aircraft performance, design, operational processes, training, and specific procedure design criteria to achieve the required target level of safety. RNP AR APCH has lateral accuracy values that can range below 1 in the terminal and missed approach segments and essentially scale to RNP 0.3 or lower in the final approach. Before conducting these procedures, operators should refer to the latest AC 90−101, Approval Guidance for RNP Procedures with AR. (See paragraph 5−4−18.)

Advanced RNP (A−RNP)

If you’re keeping up so far, the new language in AIM 1−2−2 provides more details about Advanced RNP (A-RNP), not to be confused with RNP (AR). Some features of A-RNP, such as the ability to fly some RF legs, are available if you have the current system software installed in a Garmin GTN navigator. For more information, see Garmin GTN Avionics and RF Legs here at BruceAir.

(4) Advanced RNP (A−RNP). Advanced RNP is a NavSpec with a minimum set of mandatory functions enabled in the aircraft’s avionics suite. In the U.S., these minimum functions include capability to calculate and perform RF turns, scalable RNP, and parallel offset flight path generation. Higher continuity (such as dual systems) may be required for certain oceanic and remote continental airspace. Other “advanced” options for use in the en route environment (such as fixed radius transitions and Time of Arrival Control) are optional in the U.S. Typically, an aircraft eligible for A−RNP will also be eligible for operations comprising: RNP APCH, RNP/RNAV 1, RNP/RNAV 2, RNP 4, and RNP/RNAV 10. A−RNP allows for scalable RNP lateral navigation values (either 1.0 or 0.3) in the terminal environment. Use of these reduced lateral accuracies will normally require use of the aircraft’s autopilot and/or flight director. See the latest AC 90−105 for more information on A−RNP, including NavSpec bundling options, eligibility determinations, and operations approvals.

NOTE−
A−RNP eligible aircraft are NOT automatically eligible for RNP AR APCH or RNP AR DP operations, as RNP AR eligibility requires a separate determination process and special FAA authorization.

(5) RNP 1. RNP 1 requires a lateral accuracy value of 1 for arrival and departure in the terminal area, and the initial and intermediate approach phase when used on conventional procedures with PBN segments (for example, an ILS with a PBN feeder, IAF, or missed approach). RF turn capability is optional in RNP 1 eligibility. This means that your aircraft may be eligible for RNP 1 operations, but you may not fly an RF turn unless RF turns are also specifically listed as a feature of your avionics suite.

(6) RNP 2. RNP 2 will apply to both domestic and oceanic/remote operations with a lateral accuracy value of 2.

PBN Requirement Boxes

AIM 1−2−2 now includes language about equipment requirement boxes on procedures that include PBN elements. For more information, see New Equipment Required Notes and An ILS that Requires GPS here at BruceAir.

(c) Depiction of PBN Requirements. In the U.S., PBN requirements like Lateral Accuracy Values or NavSpecs applicable to a procedure will be depicted on affected charts and procedures. In the U.S., a specific procedure’s Performance−Based Navigation (PBN) requirements will be prominently displayed in separate, standardized notes boxes. For procedures with PBN elements, the “PBN box” will contain the procedure’s NavSpec(s); and, if required: specific sensors or infrastructure needed for the navigation solution, any additional or advanced functional requirements, the minimum RNP value, and any amplifying remarks. Items listed in this PBN box are REQUIRED to fly the procedure’s PBN elements. For example, an ILS with an RNAV missed approach would require a specific capability to fly the missed approach portion of the procedure. That required capability will be listed in the PBN box. The separate Equipment Requirements box will list ground−based equipment and/or airport specific requirements. On procedures with both PBN elements and ground−based equipment requirements, the PBN requirements box will be listed first.

Flying and Flying Direct with GNSS (GPS)

AIM 5−1−8 now provides more details for pilots flying under IFR with GNSS about filing direct routes or requesting direct clearances from ATC. The new text focuses on direct routes that include legs that exceed navaid service volumes and provides more details about filing direct routes.

In particular, if you plan a direct flight you should:

  • File and fly point-to-point using published waypoint names (airports, navaids, intersections, and RNAV waypoints) to define the route of flight.
  • Include at least one named waypoint within each ARTCC through which the flight will pass.

4. Increasing use of self−contained airborne navigational systems which do not rely on the VOR/VORTAC/TACAN system has resulted in pilot requests for direct routes that exceed NAVAID service volume limits. With the exception of GNSS−equipped aircraft, these direct route requests will be approved only in a radar environment, with approval based on pilot responsibility for navigation on the authorized direct route. Radar flight following will be provided by ATC for ATC purposes. For GNSS−equipped aircraft, ATC may approve a direct route that exceeds ground based NAVAID service volume limits; however, in a non−radar environment, the routing must be “point−to−point,” defined as navigation from a published point to a published point, and navigational assistance will not be available. (See subparagraph 5−1−8d below.)

5. At times, ATC will initiate a direct route in a radar environment that exceeds NAVAID service volume limits. In such cases ATC will provide radar monitoring and navigational assistance as necessary. For GNSS−equipped aircraft, if the route is point−to−point, radar monitoring and navigational assistance is not required. (See subparagraph 5−1−8d below.)

d. Area Navigation (RNAV)/Global Navigation Satellite System (GNSS) 1. Except for GNSS−equipped aircraft, random impromptu routes can only be approved in a radar environment. A random impromptu route is a direct course initiated by ATC or requested by the pilot during flight. Aircraft are cleared from their present position to a NAVAID, waypoint, fix, or airport. Factors that will be considered by ATC in approving random impromptu routes include the capability to provide radar monitoring and compatibility with traffic volume and flow. ATC will radar monitor each flight; however, navigation on the random impromptu route is the responsibility of the pilot. GNSS−equipped aircraft are allowed to operate in a non−radar environment when the aircraft is cleared via, or is reported to be established on, a point−to−point route. The points must be published NAVAIDs, waypoints, fixes, or airports recallable from the aircraft’s database. The distance between the points cannot exceed 500 miles and navigational assistance will not be provided…

(f) File a minimum of one route description waypoint for each ARTCC through whose area the random route will be flown.

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Loading Procedures from Databases

Most IFR pilots who use GNSS (GPS) are aware that they must load instrument approach procedures (IAPs) by name from the unit’s database. But there’s some confusion in IFR land about flying instrument departure procedures, arrivals, and other routes.

For more information about database currency, see Database Currency for IFR Operations here at BruceAir.

AIM 1−1−17. Global Positioning System (GPS), 2. IFR Use of GPS, includes the following paragraph about IAPs:

(3) All approach procedures to be flown must be retrievable from the current airborne navigation database supplied by the equipment manufacturer or other FAA−approved source. The system must be able to retrieve the procedure by name from the aircraft navigation database, not just as a manually entered series of waypoints. Manual entry of waypoints using latitude/longitude or place/bearing is not permitted for approach procedures. (p. 1−1−20)

That language specifically address IAPs, but it doesn’t mention DPs, STARs, or airways.

If you use an IFR-approved GNSS (see AIM 1−1−17. Global Positioning System (GPS), 2. IFR Use of GPS for the details), you should check the Aircraft Flight Manual Supplement or the AFM (if you fly an aircraft with an IFR-approved GNSS installed as original equipment) for the limitations associated with the unit(s) in your aircraft.

For example, the AFM supplement (a required document for a unit installed under an STC) for the Garmin GNS 530W includes the following language:

2.5 Flight Planning

Whenever possible, RNP and RNAV routes including Standard Instrument Departures (SIDs), and Standard Terminal Arrival (STAR), routes should be loaded into the flight plan from the database in their entirety, rather than loading route waypoints from the database into the flight plan individually. Selecting and inserting individual named fixes from the database is permitted, provided all fixes along the published route to be flown are inserted. Manual entry of waypoints using latitude/longitude or place/bearing is prohibited. (Garmin document 190-00357-03_F)

Similar language appears in the AFM supplements for the GNS 430, GTN 750, and GTN 650 units. For example:

2.4 Flight Planning

Whenever possible, RNP and RNAV routes including Standard Instrument Departures (SIDs), Standard Terminal Arrival (STAR), and enroute RNAV “Q” and RNAV “T” routes should be loaded into the flight plan from the database in their entirety, rather than loading route waypoints from the database into the flight plan individually. Selecting and inserting individual named fixes from the database is permitted, provided all fixes along the published route to be flown are inserted. Manual entry of waypoints using latitude/longitude or place/bearing is prohibited. (AFMS, Garmin GTN GPS/SBAS System, 190-01007-A2 Rev. 8)

You should take care, however, when entering a departure procedure as a series of fixes rather than by name from the database. A DP is more than a series of points defined by LAT/LON. A DP typically contains several types of legs, and you must ensure that you understand how each leg works and how the GNSS in your aircraft handles different leg types and interfaces with your autopilot.

You can find more information about leg types in Avoiding Confusion when Flying GPS Legs here at BruceAir. See also Chapter 6 of the Instrument Procedures Handbook.

VOR Status–Another Update

FAA provided another update on its plans to reduce the VOR network at the October 2018 meeting of the Aeronautical Charting Meeting. The latest Very High Frequency Omnidirectional Range (VOR) Minimum Operational Network (MON) Program update (PDF) includes the following key details:

  • 311 VORs (about 30 percent) will be shut down by 2025
  • 585 VORs will remain operational
  • Most of the VORs to be deactivated are in the East (133) and Central (163) regions; in the West, only 15 navaids are on the list to be turned off.
  • As of September 2018, 34 VORs, VOR/DME, and VORTACs have been shut down.
  • At the end of 2018, 34 of the 74 Phase 1 VORs have been shut down.
  • FAA plans to enhance the service volume of remaining VORs from 40 nm to 70 nm beginning at 5000 AGL. The enhanced VORs will be classified as VOR Low (VL) and VOR High (VH).  Documents such as the AIM will be updated as the enhancement program gets underway. The illustration below shows the coverage that the enhanced VORs will provide at or above 5000 AGL.

VOR-MON-70NM.jpg

As I’ve noted in several previous posts (e.g., here), the VOR MON program is designed to provide backup to GNSS (GPS). Specifically, within the contiguous United States the MON program will support conventional navigation in the event of a GPS outage by ensuring that pilots can:

  • Tune and identify a VOR at an altitude of 5,000 feet above site level and higher
  • Conduct VOR navigation through a GPS outage area
  • Navigate to a MON airport within 100 nautical miles to fly an Instrument
    Landing System (ILS), Localizer (LOC) or VOR instrument approach without
    GPS, DME, Automatic Direction Finder (ADF), or radar
  • Navigate along VOR Airways, especially in mountainous terrain, where
    Minimum En-route Altitudes (MEAs) make direct-to navigation impracticable

MON airports (i.e., those with conventional instrument procedures as described above) will be identified on en route charts, FAA Chart Supplements, and included in the National Airspace System Resource (NASR) Subscriber File data set for developers of electronic charts, apps, and so forth.

The FAA’s detailed policy for the transition was outlined in the Federal Register, here. More information about the program to reduce the VOR neworks is available at AOPA, here.

Here’s the list of next round of VORs scheduled to be shut down. I have provided links to the navaids at SkyVector.com so that you can see each location on a sectional chart. Note that in each case, several nearby VORs will remain in service:

BUU (BURBUN) Burlington, WI – Nov. 8, 2018
RUT (RUTLAND) Rutland, VT  – Nov. 8 2018
VNN (MT VERNON) Vernon, IL – Nov. 8, 2018
TVT (TIVERTON) Tiverton, OH  – Nov. 8, 2018
CSX (CARDINAL) St. Louis, MO – Jan. 3, 2019
ISQ (SCHOOLCRAFT CO) Manistique, MI – Jan. 3, 2019
MTO (MATTOON) Mattoon, IL – Jan. 3, 2019
ORD (CHICAGO O’HARE) Chicago, IL – Jan. 3, 2019
RID (RICHMOND) Richmond, IN – Jan. 3, 2019
FRM (FAIRMOUNT) Fairmont, MN – Feb. 28, 2019
GNP (GLENPOOL) Tulsa, OK – Feb. 28, 2019
LSE (LA CROSSE) La Crosse WI – Feb. 28, 2019
MTW (MANITOWOC) Manitowoc, WI – Feb. 28, 2019
GTH (GUTHERIE) Guthrie, TX – Apr. 25, 2019
HUB (HOBBY) Hobby, TX – Apr. 25
CZQ (CLOVIS) Clovis, in Fresno, CA – Apr. 25, 2019

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.

An IFR Flight: KBFI-KUAO

Here’s video from a recent IFR flight in the Bonanza from Boeing Field (KBFI) in Seattle, WA to Aurora, OR (KUAO) just south of Portland, OR.

I was in visual meterological conditions (VMC) for almost all of the trip, but the destination was shrouded in low fog when I departed Seattle. I arrived just as the mist was clearing.

I flew the NRVNA ONE departure procedure from KBFI and flew via the preferred low-altitude IFR route to the Portland area (OLM V165 UBG). At KUAO, I flew the RNAV RWY 35 approach, which provides LPV minimums for WAAS-capable aircraft like my A36, which is equipped with a Garmin GTN 750 navigator and G500 PFD/MFD. (To experiment with these avionics, you can download the free Garmin simulators for Windows.)

I also use the free Beechcraft Performance app for iOS to confirm takeoff and landing data and other important details.

Throughout this 20-minute video, I tried to verbalize my intentions, procedures, checklists to help you understand how I try to conduct a flight.

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.

IFR ACS-IPC Task Table.jpg

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)?

NBAA Proposal to Simplify FAA IAP Charts

Many instrument approach procedure charts are cluttered with notes and multiple lines of minimums to accommodate a range of possible lighting failures, remote altimeter settings, and other factors.

NBAA has submitted a recommendation document (PDF) to the Aeronautical Charting Meeting. The ACM will consider the proposal to simply FAA IAP charts at its October 2018 meeting.

To comment on the proposal, see the contact information in the recommendation document.

The proposal begins by noting that:

U.S. Government (FAA) instrument approach charts (IAPs) have become increasingly complex and difficult for pilots to use and interpret. This complexity results from TERPS and PBN requirements, multiple lines of minima, voluminous chart notes, just to name a few. As a result, pilots find it difficult to extract necessary information to fly the approach. Several FAA initiatives are currently underway or proposed to simplify the FAA IAP charts. Currently underway is the deployment of the PBN and Equipment Requirements Box. In addition, at the 1801 ACF meeting, there was discussion about the removal of the airport sketch on the FAA’s IAP chart. NBAA believes that these changes are long overdue. We believe it is necessary to look at Chart Notes, the Minima depiction, and adjustments to these minima resulting from inoperative components or remote altimeter setting source (RASS).

NBAA offers four suggestions:

  1. Removal of the Airport Sketch from the IAP chart and replace it with a stand-alone Airport Diagram chart for every airport entry in the TPP. This proposal not only reduces chart clutter and returns valuable “white space” to the chart, it will also provide for a larger airport diagram assisting pilots with ground surface operations and reduces the risks associated with runway incursions and excursions. Removal of the Airport Sketch has been discussed at a prior ACF; however, it is incorporated into this recommendation as a prerequisite for IAP modernization.
  2. Eliminate Military Minimums. Concerning military minimums, the ceiling is easily derived from other information already present on the chart and a parenthetical Statute Mile (SM) visibility for RVR would be provided.
  3. Eliminate RASS chart note and incorporate the RASS as a separate line of minima applicable to the altimeter source.
  4. Incorporate the effects of inoperative components into the lines of minima for each approach category. The purpose of this proposed change is to furnish the pilot with a Minima Table providing minimums for all situations. Today, the pilot must refer to the Inoperative Components Table of the TPP to determine corrections to the published visibility and to the MDA or DA with the failure of the approach lighting system, runway touchdown zone or centerline lights, or RVR systems.

The following illustration shows how proposal (3) would consolidate and clarify notes related to remote altimeter settings.

NBAA-IAP-RASS-Notes-01
NBAA asserts that:

The advantages of these changes are clear. The benefit of this proposed change is to furnish the pilot with a Minima Table providing minimums for all situations without the need for pilot computations or references to other pages within the TPP. The increased use of EFB products makes referencing ancillary pages difficult and time consuming.

NBAA proposes two options, side-by-side and stacked, to present minimums when all components of the approach lights are working, and when some are inoperative.

NBAA-IAP-minima options-01