Circling Approaches and Their Conduct During Instrument Proficiency Checks

by Michael W. Brown, Reprinted with permission from FAA Aviation News

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), FAAS- 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 previous PTS, version 'Charlie.' While version 'Charlie' lacked 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 the FAA aspires, so 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.

Since the publication of the new PTS, some instructors have expressed concern that clarification of established policy impinges upon the discretion afforded flight instructors under 14 Code of Federal Regulations section 61.57(d). However, section 61.57(d) outlines the requirements for an IPC, stating in relevant part that pilots must pass ''an instrument proficiency check consisting of a representative number of tasks required by the instrument rating practical test.' Those tasks are outlined in the rating task table of the PTS, thus section 61.57(d) provides a clear regulatory basis for this requirement. Although instructor discretion is not mentioned anywhere within this section, instructors do have considerable latitude in the conduct of an IPC. The difficulty comes from the fact that many within the flight training community have come to view the PTS as a flight-training guide, which was never its intent.

As its name implies, the PTS merely outlines the standards to which an applicant must perform. There are an infinite number of approaches (no pun intended) available to instructors in testing or preparing their applicant. A quality flight instructor will find innovative techniques for integrating the necessary items into a comprehensive IPC.

This brings us to the main point of contention mentioned earlier. 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 FAA policy ever allowed for, 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.

For more information regarding the areas of operation for which a FTD or simulator may be used, one need only check Appendix 1-2 of the PTS. Notice that no flight simulation device, short of a full level-qualified simulator, is approved for circling procedures. This too has not changed, further emphasizing the benefit to both training institutions and students alike of familiarization with the equipment (and its limitations) to be used in their recurrent training program.

Some instructors have also expressed concern that requiring their clients to conduct circling approaches as part of an IPC may deprive them of an opportunity to complete an IPC in instrument meteorological conditions that preclude a circling procedure. This situation is analogous to any other flight-testing situation that does not allow for a complete evaluation of the applicant. The task that cannot be completed must still be tested, and that sometimes requires an additional flight. This is no different than if an applicant undertook a flight in IMC, only to find the requisite instrument landing system (ILS) was out of service. Again, the fact that the applicant managed the flight with great proficiency does not absolve him or her from the obligation to complete this required item.

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 regiment, thus the FAA's rationale for their inclusion as part of a comprehensive IPC.

Michael W. Brown is an Aviation Safety Analyst in Flight Standards Service's General Aviation and Commercial Division.