The FAA’s Office of the Chief Counsel recently issued a Memorandum responding to a letter regarding demonstration of circling approaches during Part 135 competency checks and instrument proficiency checks. The letter’s inquiry specifically focused on the conduct of such checks by an operator that is not authorized to conduct IFR circle-to-land approaches.
The Memorandum initially noted that an instrument proficiency check under FAR 135.297need only include the standard instrument approaches involving navigational facilities which the pilot is to be authorized to use in operations for the Part 135 operator. It further observed that FAR 135.297(b) “requires that a pilot qualifying to use an instrument approach procedure must perform ‘one straight-in approach, one circling approach, and one missed approach’ for each procedure demonstrated.”
However, the Memorandum then noted that FAA policy does not require pilots for Part 135 operators to demonstrate a circling approach if the Part 135 operator is not authorized to conduct such maneuvers in IFR conditions. As a result, the Memorandum concluded that since the Part 135 operator referenced in the letter was not authorized to conduct circling instrument approaches in IFR conditions, “it follows that its pilots are not required to demonstrate a circling approach to satisfy the requirements of § 135.297.”
Nice to see the FAA taking a position that makes sense. After all, why should a pilot have to prove proficiency in a maneuver the pilot is not legally authorized to perform when carrying out his or her duties? Of course, that’s not to say that a pilot shouldn’t be proficient in such maneuvers anyway, at least from a safety perspective.