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FAA Instrument Proficiency Requirements 2004
As part of an ongoing effort to improve regulatory compliance, clarity, and safety, the Federal Aviation Administration (FAA) occasionally finds it necessary to implement changes to existing policies and guidance. While such changes are typically very effective in achieving their desired safety goals, clarity (and with it compliance) may not always fare as well. This recently became evident when the FAA published the new Instrument Rating Practical Test Standards (PTS), FAA-S-8081-4D. Effective October 1, 2004, version "Delta" has raised questions concerning the requirement to conduct circling approaches as
part of the instrument proficiency check (IPC).

Specifically, this latest version of the PTS includes a new paragraph (page 16, following the Rating Task Table) that states in relevant part, "The person giving the check shall use the standards and procedures contained in this PTS when administering the check." Some viewed this language as mandating tasks that were voluntary under the current PTS, version "Charlie." While this (current) version lacks the explicit text cited above, the FAA always intended for the table to be used in the conduct of IPCs. Of course "intent" lacks the precision to which we aspire, so the latest version "Delta" was modified to
clarify existing Flight Standards policy. In short, the FAA always expected instructors to conform to the task table when conducting IPCs, and version "Delta" now makes that clear.

This brings us to the main point of contention. Similar to its predecessor (issued in 1999), version "Delta" of the Instrument PTS contains a task table that includes a column for the IPC. While some of these tasks vary between versions "Delta" and "Charlie," both specify circling approaches under Area of Operation VI. However, because some flight training institutions consider circling approaches to be a new requirement, they are concerned they may no longer exclusively use FAA-approved Flight Training Devices (FTDs) to conduct IPCs.

Again, the PTS change poses no additional burdens on flight schools, instructors, or pilots. The FAA never envisioned, nor has the FAA ever approved, the use of FTDs and other similar devices for a complete instrument proficiency check. Flight Training Devices need not contain a visual system, and those that do lack the visual cues necessary to replicate a circle-to-land procedure (circling approach). As a result, it is inappropriate to credit a complete IPC in such a device absent supplemental flights in an actual aircraft. As a practical matter, it is difficult to imagine that any ground-based training aid, short of a full level-qualified flight simulator approved for circling approaches, could substitute for instruction received during actual flight operations. That is not to say FTDs have no place in the pantheon of instrument flight instruction, or for that matter IPCs. In fact, many of these devices serve as excellent procedure trainers, and are a proven means of evaluating certain piloting skills. However, as with all such
resources, it is important they be used in a manner consistent with their design and limitations.

And finally, for those who say circling approaches are too dangerous and shouldn't be emphasized, consider these facts. Currently there are over 1,100 instrument approach procedures with only circle-to-land minima. Combine this with literally thousands of other approaches with published circling minima, and it's clear that an instrument pilot needs to possess such skills to be a complete aviator. Moreover, the skills needed to transition from instrument to visual flight while maintaining precise aircraft control are critical...At least as critical as those required to execute a hold or recover from an unusual flight attitude. Again, circling approaches provide for the maintenance of these skills. Also, it should be noted that most accidents involving circling approaches were attributed to poor piloting technique and failure to maintain the requisite visibility and cloud clearances for a given procedure. This fact alone provides a clear and compelling incentive to make circling approaches a part of any instrument training and proficiency regimen, thus the FAA's rationale for their inclusion as part of a comprehensive IPC.

All Available Information
Any time you visit an airport it is a good idea to talk with the locals. Locals have a great deal of safety information related to operations from their home field. Using locals as a cockpit resource is a good stress remover. More than one I have picked a local brain as to local checkpoints and airport specific IFR procedures. For example, Santa Monica has an unpublished but standard IFR departure procedure that will be a complete surprise to a pilot who has not been briefed.

IFR Proficiency
Proficiency in IFR and currency in IFR are two different animals. You must fly in weather to become comfortable in weather. Scan, regardless of pattern must let you interpret and anticipate pressure requirements. Anticipation is planning ahead for what, when, and how to proceed both in long-range plans and near term plans.

Simulation is no adequate substitute for actual conditions. The likely absence of turbulence, changing visibilities, illusions and a low visibility landing are not possible. Visual peeks are bound to occur when compass-heading checks are made. The absence of actual conditions inhibits low time certified IFR pilots from maintaining currency.

Proficiency is demonstrated best by economy of time and effort that results in safe flight. The proficient pilot does not let the weather briefing extend to areas not within range for consideration. The Chart selections are based upon most likely route considerations. However, a very useful advanced instrument lesson can be learned by a student if the instructor should suddenly require a change of route to an unplanned arrival at an unplanned airport. Ability to make this adjustment in flight in IFR is a sign of proficiency.

Second major area of incompetence lies in the transition from IFR to landing the aircraft in low visibility to a full stop. Training approaches all too often end with the published missed. In my own program, admittedly under the hood, out of last eleven approaches ten have been full stop-taxi backs. The one non-landing was a GCA approach at a military facility. I stress landings because most real-life IFR approaches end in landings.

Proficiency is further demonstrated by the pilot's ability to preset all radios and navaids into the radios in the order of expected use. Paperwork should be highlighted on the charts and a contingency sheet should be available should a chart suddenly disappear under the seat. It happens…plan for it.

IFR Proficiency Factors
--Scan skills
--Flight planning
--Cockpit organization

IFR Proficiency2
1. Iced windshield problem. Fly slightly right of center so as to see lights out side window.
2. Confidence derives from proficiency, which derives for knowledge and experience. The mother of all these is practice.
3. You're not a good instrument pilot until you scan is as natural as breathing.
4. The infrequent flyer has no business in heavy weather.
5. Proficient pilots always have an 'out', an option, and a Plan-B.
6. Always play the "What If…" game with fuel, weather, and equipment..
7. Watch refueling, check fuel, and know the fuel system

When putting into practice the maneuvers that we have been taught, we find that the access we have to the skill involved is tied to our ability to access and recall the thought processes involved. Skill is a retention and recall problem based upon mental anticipation and application.

Our ability to use our mentally powered physical skills is biased by the effects of stress factors and physical well being. If we are fearful of our ability to perform, we are much more unlikely to be able to perform. Confidence is an essential element in the art of flying. Any lack of confidence can only be acquired by guided practice either instructional or self-taught.

--Legal currency includes six approaches, holding and tracking.
--Real currency is the learning and practice done in the past six months.
--Training exercise is to plan IFR flight with airspace, FARs, chart and plates, emergency, and negotiating.
--IFR accidents occur in conditions beyond capability of aircraft and/or pilot.
--Accidents occurring in IFR conditions are most often fatal accidents.
--If you can't use the equipment, you are wasting one more safety option.
--Know your aircraft performance and the limitations so as to evaluate your options.
-- Ability to preset all radios and navaids into the radios in the order of expected use.
--Paperwork should be highlighted on the charts
--Have pilot delineate personal minimums of weather, equipment and fuel.
--What to do when you get behind a situation?
--Detection of ATC procedural errors.
--Knowledge of minimums and equipment tolerances.

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