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.

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)?

Simulating Partial-Panel with a G500/G600

I schedule an annual instrument proficiency check before the Pacific Northwest skies turn gray as fall arrives. The tasks that you must accomplish to complete an IPC are outlined in the practical test standards for the instrument rating and in an appendix to Instrument Proficiency Check (IPC) Guidance, published by FAA.

Instrument Proficiency Check. 14 CFR part 61, section 61.57(d), sets forth the requirements for an instrument proficiency check. The person giving that check shall use the standards and procedures contained in this PTS when administering the check. A representative number of Tasks, as determined by the examiner/instructor, must be selected to assure the competence of the applicant to operate in the IFR environment. As a minimum, the applicant must demonstrate the ability to perform the Tasks as listed in the [chart below]. The person giving the check should develop a scenario that incorporates as many required tasks as practical to assess the pilot’s ADM and risk management skills during the IPC. See Appendix 2 for IPC AATD Credit Table. (FAA-S-8081-4E with Changes 1, 2, 3, 4, & 5)

image

As you can see, the required items include VII–Emergency Operations, Task D: Approach with Loss of Primary Flight Instrument Indicators. The notes for that task in the PTS specify that the pilot, “Demonstrat[e] a non-precision instrument approach without the use of the primary flight instrument using the objectives of the non-precision approach Task (Area of Operation VI, Task A).”

In an airplane with conventional instruments (the so-called steam gauges), the instructor covers the attitude indicator with a suction cup, business card, or sticky note.

Like many pilots, however, I’ve updated my instrument panel. It now features a Garmin G500 electronic display that replaces six traditional primary flight instruments (airspeed indicator, attitude indicator, altimeter, vertical speed indicator, heading indicator, and turn coordinator). I have a backup attitude indicator, ASI and altimeter in the self-contained Mid-Continent SAM.

FullPanel-01

Now, avionics manufacturers and the FAA have advised against pulling circuit breakers to simulate failures of electronic displays and the behind-the-scenes gizmos that drive them (e.g., attitude-heading reference systems). Plastering expensive displays—especially touch-screens–with sticky notes isn’t a good idea. So, how to simulate the failure of the PFD (the left side of the G500)—or, indeed the entire GDU 620, the two-panel display that shows the flight instruments and a map?

For more information about using CBs to simulate failures, see Garmin’s G1000 Guide for Designated Pilot Examiners and Certified Flight Instructors. That document notes in part:

Cessna does not recommend pulling circuit breakers as a means of simulating failures on the Garmin G1000. Pulling circuit breakers—or using them as switches—has the potential to weaken the circuit breaker to a point at which it may not perform its intended function. Using circuit breakers as switches is also discouraged in Advisory Circulars 120-80, 23-17B, and 43.13-1B. Additionally, a circuit breaker may be powering other equipment (such as avionics cooling fans) that could affect the safe operation of other equipment.

For the map side, it’s easy—select a page that shows, say, A/FD information or one of the AUX pages. They’re useless as references during an approach.

After much deep thought, I came up with the following solution for the PFD side: A piece of cardboard taped above the display. Here’s the item lying in wait in the holder that I use for my iPad.

Cover_1957

And here it is in place, covering most of the PFD.

Covered_1963

Inelegant to be sure. I’ll trim it to size next time. But it’s simple, non-destructive, cheap, and easy to put in place and remove. In a aircraft used primarily for training, I’d consider a strip of Velcro above the PFD.

If you wanted to “fail” just the attitude indicator and leave the ASI, altimeter, VSI, HI, CDI, bearing pointers, and other information visible, you could trim the cardboard so that it covers only the AI portion of the PFD.

Today, however, I wanted to simulate a complete failure of the GDU 620 to see how well I could fly an approach using the SAM and the navigation information on the GTN750 and the chart on my iPad. Per the PTS, I was flying a non-precision approach, so I didn’t need a glideslope indicator.

To set up descents on each segment of the approach, I applied the Pitch+Power+Configuration=Performance equation, knowing that at a specified power setting and pitch in a given configuration (flaps and landing gear positions), I would descend at approximately 600 fpm at a stable airspeed. Tracking the courses was a bit more difficult than when using the HSI, but this was a simulated emergency, so I used all available sources, including the depiction of my airplane on the GTN750 moving map and the approach chart displayed (via ForeFlight) on my iPad. By making small, coordinated turns based on the SAM, I never wandered more than about a dot off the centerline of any segment of the approach. The graphical information made meeting altitude restrictions easier. And the trend vectors that show how your current track relates to the required course were also a big help in making smooth, small heading changes.

I plan to use this high-tech failure simulator in the future when I practice flying instrument procedures (in VMC, of course) to maintain my proficiency. Note that this device would also work well in ATDs and FTDs that feature glass cockpits.

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.