The FAA should permit pilots who must take an instrument proficiency check before acting as pilot in command under instrument flight rules to use aviation training devices to meet their regulatory obligation, AOPA said in a filing proposing major reforms for the IPC.

AOPA also proposed eliminating the recordkeeping requirement for logging 30-day VOR checks for IFR navigation.

Bringing ATDs online for use in IPCs would require dropping the requirement to land from an instrument approach—a mandatory item on an instrument-rating practical test that is not required by regulation on an IPC. AOPA has pointed out that the relevant instrument flight skill to be reviewed on an IPC is not the landing, but “is the pilot’s transition from flight solely by instruments to visual flight.”

A related reform to make ATD use possible would be scrapping the circle-to-land procedure from IPCs, an improvement that would reduce training costs, add efficiency, and conform to the industry’s goal of encouraging stabilized approaches as circling procedures are phased out of use.

AOPA first proposed ATD-related IPC reforms in 2018 and is again emphasizing their importance as a participant in the Airman Certification System Working Group, said Rune Duke, AOPA senior director of government affairs for airspace, air traffic, and aviation security.

“We are continuing to work with our industry partners to advocate that the FAA implement these changes, as they would improve safety, reduce cost, and promote the use of ATDs,” he said.

Currently, regulations require an IFR pilot who has failed to meet the instrument experience requirements of FAR 61.57(c) for more than six calendar months to “reestablish instrument currency only by completing an instrument proficiency check.” In most cases, the check must be completed “in an aircraft that is appropriate to the aircraft category.”

Removing the circle-to-land and landing-from-an-approach tasks “would allow the IPC to be completed entirely from an ATD—saving pilots considerable time and money while maintaining, and possibly, improving both the safety and proficiency of the pilot. We believe this request is in line with the FAA’s strategy to transition away from circling procedures and their goal of encouraging the use of ATDs,” AOPA said in its submission.

In addition to tasks considered unnecessary for proficiency, AOPA has noted that some recordkeeping requirements also serve no useful purpose. In November 2019, AOPA submitted comments supporting a petition for rulemaking from a GA pilot to eliminate the logging of the 30-day operational check of a VOR for IFR operations mandated by FAR 91.171.

AOPA noted that the logging requirement “is an unnecessary burden on pilots and serves no practical safety purpose.”