Was I current or wasn't I? IFR/IPC check

R

Rouge1

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Posting anon as to not draw attention to myself for a possible reg violation...

So a few months ago my IFR currency was running out so I found a CFII and had him do an IPC check. This particular CFII was a young guy- one of many from our local flight school working towards an aviation degree and trying to build hours. We spent some ground time, did a few approaches and holds, then he signed my logbook and put one of the pre-printed stickers in the back that they use here saying I'd completed an IPC check and put his signature on it. So as far as I was concerned, I was current for the next 6mo.

Then recently I got some instruction from someone more experienced for an unrelated thing. He looked at the IPC check in my logbook and said it was "an illegal IPC check" and the previous instructor "didn't know how to do one". I looked up the requirements and sure enough he was right- I'd only done 1 precision and 1 non-precision approach where the requirements say you need 2.

So, in the meantime I've filed IFR, accepted IFR clearances, and flown in IMC. Now, I know as long as I don't point it out to the FAA nobody is going to care but what if someone had looked? I had a CFII signed log entry saying I'd completed an IPC check.... but really the requirements were not met. So who's at fault there? Did I bust currency requirements because it wasn't a valid check or does it still count even though it wasn't done right because it was signed off?

Next time I'll look closer, I just assumed anyone who had their CFII would know this stuff better than a weekend warrior private pilot like me and didn't question it.
 
I wouldn't worry about it. Tell instructor 2 that he's not a cop for the FAA and mind his own business?
 
So you saved some money on the IPC,the Cfi evidently thought you were proficient. It if really bothers you reach out to the FAA,they’re there to help.
 
I wouldn't worry about it. Tell instructor 2 that he's not a cop for the FAA and mind his own business?
Uh, no, don't tell him that. Thank him for the enlightenment. Then ask him (for me) where you went wrong:

61.57(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.

(2) The instrument proficiency check must be—

(i) In an aircraft that is appropriate to the aircraft category;

(ii) For other than a glider, in a full flight simulator or flight training device that is representative of the aircraft category; or

(iii) For a glider, in a single-engine airplane or a glider.

(3) The instrument proficiency check must be given by—

(i) An examiner;

(ii) A person authorized by the U.S. Armed Forces to conduct instrument flight tests, provided the person being tested is a member of the U.S. Armed Forces;

(iii) A company check pilot who is authorized to conduct instrument flight tests under part 121, 125, or 135 of this chapter or subpart K of part 91 of this chapter, and provided that both the check pilot and the pilot being tested are employees of that operator or fractional ownership program manager, as applicable;

(iv) An authorized instructor; or

(v) A person approved by the Administrator to conduct instrument practical tests.​
https://www.ecfr.gov/cgi-bin/text-i...fc165ec93&mc=true&node=se14.2.61_157&rgn=div8
 
Posting anon as to not draw attention to myself for a possible reg violation...

So a few months ago my IFR currency was running out so I found a CFII and had him do an IPC check. This particular CFII was a young guy- one of many from our local flight school working towards an aviation degree and trying to build hours. We spent some ground time, did a few approaches and holds, then he signed my logbook and put one of the pre-printed stickers in the back that they use here saying I'd completed an IPC check and put his signature on it. So as far as I was concerned, I was current for the next 6mo.

Then recently I got some instruction from someone more experienced for an unrelated thing. He looked at the IPC check in my logbook and said it was "an illegal IPC check" and the previous instructor "didn't know how to do one". I looked up the requirements and sure enough he was right- I'd only done 1 precision and 1 non-precision approach where the requirements say you need 2.

So, in the meantime I've filed IFR, accepted IFR clearances, and flown in IMC. Now, I know as long as I don't point it out to the FAA nobody is going to care but what if someone had looked? I had a CFII signed log entry saying I'd completed an IPC check.... but really the requirements were not met. So who's at fault there? Did I bust currency requirements because it wasn't a valid check or does it still count even though it wasn't done right because it was signed off?

Next time I'll look closer, I just assumed anyone who had their CFII would know this stuff better than a weekend warrior private pilot like me and didn't question it.
Your last sentence covers it. As PIC, it is up to you to know the requirements to act as PIC flying IFR.

Don't ask, don't tell
 
...I looked up the requirements and sure enough he was right- I'd only done 1 precision and 1 non-precision approach where the requirements say you need 2....
Not doubting you but could you quote the requirement or post the reg#?
 
Refer to AC 61-98D Flight Review and IPC

5.3 IPC Skill Portion. The maneuvers and procedures selected for the IPC must include those listed in the Rating Task Table in FAA-S-ACS-8 or FAA-S-8081-4, as applicable. The flight instructor conducting the IPC has the discretion to require any other maneuver(s) necessary to determine that the pilot can safely operate under IFR in a broad range of conditions


The ACS has a table of required procedures for an IPC

III B Holding Procedures
IV B Recovery from Unusual Attitudes
V A Intercepting and Tracking Navigation Systems and Arcs
VI All
A Nonprecision Approach
B Precision Approach
C Missed Approach
D Circling Approach
E Landing from an Instrument Approach
VII D Approach with Loss of Primary Flight Instruments (non-precision approach)
VIII Postflight

You can combine some of these, e.g. perform a circling approach from a Nonprecision approach, and land from precision approach, but at a minimum you would need two non-precision approaches (one with failed instruments) and one precision.
 
Refer to AC 61-98D Flight Review and IPC

5.3 IPC Skill Portion. The maneuvers and procedures selected for the IPC must include those listed in the Rating Task Table in FAA-S-ACS-8 or FAA-S-8081-4, as applicable. The flight instructor conducting the IPC has the discretion to require any other maneuver(s) necessary to determine that the pilot can safely operate under IFR in a broad range of conditions


The ACS has a table of required procedures for an IPC

III B Holding Procedures
IV B Recovery from Unusual Attitudes
V A Intercepting and Tracking Navigation Systems and Arcs
VI All
A Nonprecision Approach
B Precision Approach
C Missed Approach
D Circling Approach
E Landing from an Instrument Approach
VII D Approach with Loss of Primary Flight Instruments (non-precision approach)
VIII Postflight

You can combine some of these, e.g. perform a circling approach from a Nonprecision approach, and land from precision approach, but at a minimum you would need two non-precision approaches (one with failed instruments) and one precision.

You are required to do a nonprecision approach with failed instruments, but are you required to do a separate one without failed instruments?
 
Hint: Who's more current on the regs, the young one or the old "experienced" one?

Good point. The regulation used to require adherence to practical test standards:

61.57(d) March 21, 2017:
Instrument proficiency check. Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check. The instrument proficiency check must consist of the areas of operation and instrument tasks required in the instrument rating practical test standards.​

That wording has been removed:

61.57(d) July 27, 2018:
(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.​

FAA Order 8900.2C requires DPE's to adhere to the PTS or ACS while giving practical tests. I can't find any current regulation which requires a CFII to adhere to the PTS or ACS while giving an IPC.

It would seem the second instructor is the pot calling the kettle black, basing his opinion on an obsolete regulation.
 
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The reg says you need the IPC. You had it. As far as I can tell, you were legal.

If the IPC was lacking, that’s on the CFI
 
The reg says you need the IPC. You had it. As far as I can tell, you were legal.

If the IPC was lacking, that’s on the CFI

This is what I was really unclear on. Am I current because I got an IPC check and that's the end of it or am I not current because the IPC check I got didn't meet all requirements? If I'm legal, it works for me and I'll just make sure I get a better one next time.
 
You’ve seen the error of your ways. Move on and sin no more.

If you haven’t already, get a proper IPC before filing again.
 
I can't find any current regulation which requires a CFII to adhere to the PTS or ACS while giving an IPC.
The Final ruling has this legalese doublespeak about that:

"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."​

My take on it is that 61.57(d) sets a requirement the same way 61.65(c) does for the initial instrument test. The ACS is the standard that must be met for each and it can be updated without usual regulatory protocols. The ACS says this about IPCs:

"Instructors and evaluators conducting an IPC must ensure the pilot meets the standards established in this ACS."
Area VI, Task A, Nonprecision Approach has a note referring to Appendix 7 "...for related considerations." There, "The applicant must accomplish at least two nonprecision approaches..."

So, is a rated instrument pilot getting an IPC an "applicant"? Can the second NP approach be a rejected "related consideration" (I would hope so)? Any competent CFII ought to be able to judge whether two NP approaches are really necessary in certain cases.
 
Ok, took this student a while to catch up, but here's what I see:

What you have to do isn't vague. In paragraph 5.3, the AC states that you must use the task list in the ACS. That is found on page A-12 and the relevant sections say that you have to do all of part 6 (approaches) and section D of part 7 (assuming single engine, add B and C for multi). As it happens, part 6 requires NPA, PA, circling, missed and landing, while part 7-D is approach with failed instruments.

What is vague - does the approach for part 7-D count for an approach in part 6? I see nothing that prohibits it from covering both and the suggested guideline for the instructor in AC seems to hint that a separate approach isn't necessary. If you've flown it with failed instruments, then you've flown an approach, right?

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_61-98D.pdf
https://www.faa.gov/training_testing/testing/acs/media/instrument_rating_acs.pdf

I think the OP was legal, but that's just SISOTI (Some IFR Student on the Internet).
 
It's pretty clear to me that attempting to give or receive an IPC based on this horrific list of overlapping regulatory and non-regulatory written guidance is difficult.

The AC 61-98D is 49 pages of FAA blather that does not even get to the subject of the evaluation until page 21!

As you might guess, I'm not a fan of the ACS and the way the FAA has decided to integrate accident prevention and other important topics into the evaluation standards.

I can see how a CFII could get it wrong after digging through the maze of documentation and comparing tables and lists on separate pages in different ACs.

Why not simply make a single document with a one page list of maneuvers and subject areas required to complete the IPC?

I agree with Rod Machado that current system is over complicated and difficult to administer...
 
It's pretty clear to me that attempting to give or receive an IPC based on this horrific list of overlapping regulatory and non-regulatory written guidance is difficult.

The AC 61-98D is 49 pages of FAA blather that does not even get to the subject of the evaluation until page 21!

As you might guess, I'm not a fan of the ACS and the way the FAA has decided to integrate accident prevention and other important topics into the evaluation standards.

I can see how a CFII could get it wrong after digging through the maze of documentation and comparing tables and lists on separate pages in different ACs.

Why not simply make a single document with a one page list of maneuvers and subject areas required to complete the IPC?

m is over complicated and difficult to administer...I agree with Rod Machado that current syste
Does this one page work? It's the IPC page from the current Instrument ACS. Prior PTS going back maybe 10 years also had the table. I haven't had too much trouble following it as either the CFII or the trainee.

upload_2019-2-24_9-2-20.png
 
Does this one page work? It's the IPC page from the current Instrument ACS. Prior PTS going back maybe 10 years also had the table. I haven't had too much trouble following it as either the CFII or the trainee.

Nope.

There is no listing of maneuvers. They could have easily just listed the elements of the IPC on all that blank space. Parts 3,4 and 5 only have one task per.

I'm sure instructors have all created their own laminated card with a list of tasks required for the eval. How else do you keep track of the tasks and their related standards in the cockpit?

Oh yeah, that's how it worked with the PTS! :cool:
 
Nope.

There is no listing of maneuvers. They could have easily just listed the elements of the IPC on all that blank space. Parts 3,4 and 5 only have one task per.

I'm sure instructors have all created their own laminated card with a list of tasks required for the eval. How else do you keep track of the tasks and their related standards in the cockpit?

Oh yeah, that's how it worked with the PTS! :cool:
To each his own degree of needed detail. It seems just as easy as anything else in the ACS or PTS.

And yes, I do have my own checkoff sheet for the IPC. Also for FRs, transition training, regular lessons...
 
To each his own degree of needed detail. It seems just as easy as anything else in the ACS or PTS.
Does the OP need two non precision approaches or not? He's not an "applicant" and Appendix 7, which is where the standard is listed, is for "related considerations". That doesn't sound controlling to me, but is it?
 
Does the OP need two non precision approaches or not? He's not an "applicant" and Appendix 7, which is where the standard is listed, is for "related considerations". That doesn't sound controlling to me, but is it?
There was an argument about being controlling when the PTS first included the PC table. It was resolved with a regulatory amendment. Some have questioned whether this past years regulatory amendment reopened the issue, despite the mandatory "must" language.

If you accept them as mandatory, it's a minimum of three approaches. If you don't, I guess you don't really have to do even one.

I don't have a problem with "applicant" in a paragraph about IPCs meaning "applicant for an IPC."
 
I don't have a problem with "applicant" in a paragraph about IPCs meaning "applicant for an IPC."
What about "related considerations" though? The whole requirement, if it IS a requirement, for two NP approaches is in an appendix for "related considerations". If it was meant to be mandatory, why not place it in the body of the ACS? Also, applicants fill out forms. There's no form filing for an IPC nor a denial of an application like with a flight test.
 
What about "related considerations" though? The whole requirement, if it IS a requirement, for two NP approaches is in an appendix for "related considerations". If it was meant to be mandatory, why not place it in the body of the ACS? Also, applicants fill out forms. There's no form filing for an IPC nor a denial of an application like with a flight test.
I guess if you insist of parsing paragraphs to that degree, you sure can. I don't.

I don't have your problem with "related considerations" containing expanded explanations. Nor with someone applying for something being an "applicant" without filling out a form - my first job was a delivery boy for a local business and I don't recall filling out anything to "apply" for the job. OTOH, if you want to be a purist and insist on a formal application, you can use IACRA for IPCs and flight reviews.
 
I guess if you insist of parsing paragraphs to that degree, you sure can. I don't.

I don't have your problem with "related considerations" containing expanded explanations.
The problem is the FAA, not me. What they demand of an instrument rating applicant differs from their demands of an IPC. It's easy to plan to always do what they demand of an initial applicant, but life throws curve balls at you. You might have a time crunch or an equipment failure that makes doing all those things impossible without considerable cost and inconvenience. Some pilots could plainly be proficient, perhaps the OP was one, after shooting a partial panel NDB approach. Maybe the CFII "considered" it was not necessary to do a second, appendix 7 NPA, because the table requirements were met. If the FAA would write their requirements clearly there wouldn't be any question. Nobody is disputing that the ACS applies to proficiency checks that I know of. Just trying to figure out what the heck the minimum tasks for one really are compared to an initial applicant.
 
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Nobody is disputing that the ACS applies to proficiency checks that I know of.
No need to beat our disagreement on clarity to death. We can each read it as we want.

But just as an FYI, folks have indeed disputed that the ACS is mandatory for IPCs. Not taking sides, just explaining for the three people who might care.

When the FAA first added the PC table, a number of folks argued it wasn't mandatory. The regulation called for a sample number of tasks. There was even a case about it. A flight school did entire IPCs in a device, so no circle to land. The FAA went after them for issuing improper IPCs. It was a civil penalty action, so no appeal to the NTSB. Perhaps the most interesting part of the case is that, the FAA lost the case within the FAA's own administrative process. The FAA said the FAA could not impose a requirement to abide by the PTS without a regulation saying so.

Anyway, while that case was going on, the FAA amended the rule to specifically incorporate the PTS - "The instrument proficiency check must consist of the areas of operation and instrument tasks required in the instrument rating practical test standards." 61.57(d) before the recent amendments. The FAA dropped that language in the current version, choosing instead to call for the accomplishment of a number of "areas of operation" without mentioning either the PTS or ACS. The FAA has said there was no intent to change the requirement to use the PC table, but I've heard a number of people argue the "legal" effect is to remove the compulsory nature of the PC table.

Personally I don't care. It's simple enough for me to follow the PTS/ACS requirement.
 
If you accept them as mandatory, it's a minimum of three approaches.

What about this?
https://www.faa.gov/pilots/training/media/IPC_Guidance.pdf

"The PTS task chart requires one precision approach and one non-precision approach."

Can CFI-2 really fault CFI-1 for following the FAA's own guidance on IPCs in a document called IPC Guidance?

If you don't, I guess you don't really have to do even one.

I would say you have to do at least one to comply with 61.57(d)(1)(4).
 
I'm just hung up on how you do an IPC in a glider.

"Okay, after this missed approach we'll do two turns in a hold, followed by..."

Uh, no, don't tell him that. Thank him for the enlightenment. Then ask him (for me) where you went wrong:

61.57(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.

(2) The instrument proficiency check must be—

(i) In an aircraft that is appropriate to the aircraft category;

(ii) For other than a glider, in a full flight simulator or flight training device that is representative of the aircraft category; or

(iii) For a glider, in a single-engine airplane or a glider.

(3) The instrument proficiency check must be given by—

(i) An examiner;

(ii) A person authorized by the U.S. Armed Forces to conduct instrument flight tests, provided the person being tested is a member of the U.S. Armed Forces;

(iii) A company check pilot who is authorized to conduct instrument flight tests under part 121, 125, or 135 of this chapter or subpart K of part 91 of this chapter, and provided that both the check pilot and the pilot being tested are employees of that operator or fractional ownership program manager, as applicable;

(iv) An authorized instructor; or

(v) A person approved by the Administrator to conduct instrument practical tests.​
https://www.ecfr.gov/cgi-bin/text-i...fc165ec93&mc=true&node=se14.2.61_157&rgn=div8
 
What about this?
https://www.faa.gov/pilots/training/media/IPC_Guidance.pdf

"The PTS task chart requires one precision approach and one non-precision approach."

Can CFI-2 really fault CFI-1 for following the FAA's own guidance on IPCs in a document called IPC Guidance?


I would say you have to do at least one to comply with 61.57(d)(1)(4).
Agreed under the current version of the rule.

I would never argue the FAA is consistent :D Just saying that if you treat the ACS as mandatory, it calls for three approaches. I've heard of many CFIIs who have only done two and wouldn't fault anyone for doing that.
 
What about "related considerations" though? The whole requirement, if it IS a requirement, for two NP approaches is in an appendix for "related considerations". If it was meant to be mandatory, why not place it in the body of the ACS? Also, applicants fill out forms. There's no form filing for an IPC nor a denial of an application like with a flight test.

Believe it or not, in AC 61-98, there is an expectation to fill out and submit an 87-10! Lots of wishy washy language here, though:

"1.10.2
Flight Review and IPC. When a pilot satisfactorily completes a flight review or IPC, the applicant should provide, and the evaluating flight instructor should submit, a completed FAA Form 8710-1 to the Airmen Certification Branch (AFB-720). The FAA does not require FAA Form 8710-1 for a pilot’s flight review or IPC; however, the FAA strongly encourages all applicants and flight instructors to follow this recommendation. When submitted, AFB-720 will add the application to the pilot’s FAA record. Pilots should ensure that their data is current, because up-to-date records benefit everyone. For example, a pilot’s total flight time and aeronautical experience determines insurance premiums. If a pilot loses his or her logbook, an FAA record is on file and available. Nevertheless, submitting FAA Form 8710-1 for a flight review or IPC is optional."
 
Believe it or not, in AC 61-98, there is an expectation to fill out and submit an 87-10! Lots of wishy washy language here, though:

"1.10.2
Flight Review and IPC. When a pilot satisfactorily completes a flight review or IPC, the applicant should provide, and the evaluating flight instructor should submit, a completed FAA Form 8710-1 to the Airmen Certification Branch (AFB-720). The FAA does not require FAA Form 8710-1 for a pilot’s flight review or IPC; however, the FAA strongly encourages all applicants and flight instructors to follow this recommendation. When submitted, AFB-720 will add the application to the pilot’s FAA record. Pilots should ensure that their data is current, because up-to-date records benefit everyone. For example, a pilot’s total flight time and aeronautical experience determines insurance premiums. If a pilot loses his or her logbook, an FAA record is on file and available. Nevertheless, submitting FAA Form 8710-1 for a flight review or IPC is optional."
Right, but it's after the fact. Some application. Wonder how they'd feel if you only applied after you passed a flight test.
 
Agreed under the current version of the rule.

I would never argue the FAA is consistent :D Just saying that if you treat the ACS as mandatory, it calls for three approaches. I've heard of many CFIIs who have only done two and wouldn't fault anyone for doing that.

I didn't read a requirement to do three approaches in the ACS. There are three requirements for certain. However, if you've done a NPA with failed instruments, then you've also flown an NPA, so the one maneuver can count for two requirements. I read two approaches minimum and the OP was legal.

I also believe the AC makes the IPC section of the ACS regulatory.

Also, if the VP is such a VIP, then the PC should be kept on the QT. If it leaks to the VC then he could be MIA and we could all wind up on KP.
 
I didn't read a requirement to do three approaches in the ACS.
It isin the description if the nonprecision task. Quoted below.

An AC can't make something "regulatory." An AC us itself "nonregulatory."



Task A. Nonprecision Approach

The evaluator will select nonprecision approaches representative of the type that the applicant is likely to use. The choices must use at least two different types of navigational aids.

Examples of acceptable non precision approaches include: VOR, VOR/DME, LOC procedures on an ILS, LDA, RNAV (RNP) or RNAV (GPS) to LNAV, LNAV/VNAV or LPV line of minima as long as the LPV DA is greater than 300 feet HAT. The equipment must be installed and the database must be current and qualified to fly GPS-based approaches.

The applicant must accomplish at least two nonprecision approaches in simulated or actual weather conditions.

• One must include a procedure turn or, in the case of a GPS-based approach, a Terminal Arrival Area (TAA) procedure.

• At least one must be flown without the use of autopilot and without the assistance of radar vectors. The yaw damper and flight director are not considered parts of the autopilot for purposes of this Task.

• One is expected to be flown with reference to backup or partial panel instrumentation or navigation display, depending on the aircraft’s instrument avionics configuration, representing the failure mode(s) most realistic for the equipment used.

The evaluator has discretion to have the applicant perform a landing or a missed approach at the completion of each non precision approach.
 
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