FAA recently updated its guidance for instructors and DPEs about the types of approaches that must be accomplished during the so-called long IFR cross-country described in 14 CFR Part 61.65(d)(2)(ii)(C).
That rule requires:
Instrument flight training on cross country flight procedures, including one cross country flight in an airplane with an authorized instructor, that is performed under instrument flight rules, when a flight plan has been filed with an air traffic control facility, and that involves –
(A) A flight of 250 nautical miles along airways or by directed routing from an air traffic control facility;
(B) An instrument approach at each airport; and
(C) Three different kinds of approaches with the use of navigation systems.
Paragraph (C) has caused confusion. For example, some DPEs have said that flying an ILS and then a LOC approach on that “long IFR xc” doesn’t meet the requirement for three different approaches, because both of those procedures are based on a localizer.
The new guidance, described in NOTC2305 (excerpt below) and in a more formal legal memorandum (PDF) dated February 28,2022, distinguishes between types of approaches and types of navigation systems. The notice explains that “the requirements for an instrument rating may be met by performing three different approaches, regardless of the source of navigation.”
The Federal Aviation Administration (FAA) recently reviewed two legal interpretation and determined they were overly restrictive. The Glaser (2008) and Pratte (2012) legal interpretations focused on the requirements of an instrument rating under § 61.65. Specifically, the requirement to use three different kinds of approaches with the use of navigation systems to meet the requirements of § 61.65(d)(2)(ii)(C). These interpretations inaccurately concluded that an applicant for an instrument rating must use three different kinds of navigation systems to meet these requirements.
On February 28, 2022, the FAA rescinded both the Glaser and Pratte legal interpretations, stating the regulation’s plain language requires three different types of approaches, not three different navigation systems. Certificated flight instructors (CFI) and designated pilot examiners (DPEs) should be aware that the requirements for an instrument rating may be met by performing three different approaches, regardless of the source of navigation.
A further update to Order 8900.1 in September 2022 added that:
B. Clarification of Different Kinds of Approaches. Section 61.65(d) contains the aeronautical experience requirements for a person applying for an Instrument—Airplane rating.
Section 61.65(d)(2)(ii)(C) states, in relevant part, that an applicant must complete 40 hours of actual or simulated instrument time that includes at least one cross-country flight that is performed under instrument flight rules (IFR) and involves “three different kinds of approaches with the use of navigation systems.” The FAA previously issued legal interpretations indicating that the three different kinds of approaches must utilize three different kinds of navigation systems. The FAA has since rescinded the legal interpretations. To fulfill the regulatory requirements, an applicant only needs to conduct three different kinds of approaches regardless of the navigation system utilized. Different approaches can be defined by the various lines of minima found on an approach plate. For example, localizer (LOC) minima are one kind of approach operation and instrument landing system (ILS) minima are another kind of approach operation. The same could be true of Area Navigation (RNAV) GPS-titled approach plates, a localizer performance with vertical guidance (LPV) approach is one kind of approach operation and a Localizer Performance (LP) to a circling MDA is another kind of approach operation.
Subparagraph 5-433A3) above discusses the types of approaches. This paragraph also applies to § 61.65(e)(2) and (f)(2). NOTE: Precision approach radar (PAR) and airport surveillance radar (ASR) approaches can be used to meet the requirements of § 61.65(d)(2), (e)(2), and (f)(2).
It’s important to understand, however, that this policy change affects only the specific regulation cited above. That rule describes one of the requirements that an IFR applicant must meet during training, specifically while completing the “long IFR xc,” a flight of at least 250 nm with approaches flown at three different airports.
The new guidance does not change types of approaches flown during a practical test. The requirements for flying precision and non-precision approaches are in the ACS for the instrument rating, and are based in part on the equipment installed in the aircraft used for the practical test.
To clarify the requirements for the long IFR cross-country and the instrument rating practical test, I suggest that FAA publish guidance like the following:
During the cross-country flight required by § 61.65(d)(2)(ii)(C), you must fly three approaches at three airports along the route. The approaches must include:
- One approach to a DA flown with approved vertical guidance (i.e., an ILS glideslope or a glidepath provided on an RNAV (GPS) approach with LPV or LNAV/VNAV minimums).
- Two approaches with lateral guidance to an MDA, such as LOC-only, LOC BC, VOR, or RNAV (GPS) procedures. If you are flying an aircraft with avionics capable of displaying advisory vertical guidance while flying non-precision approaches, typically annunciated as +V (e.g., LNAV+V, LP+V, or VOR LNAV+V), you may display and use the advisory vertical guidance as allowed in the AFM and supplements for the avionics installed in the aircraft.
- A PAR approach may be substituted for an ILS or RNAV (GPS) approach with approved vertical guidance, and an ASR approach may be substituted for one of the non-precision approaches.
We need to be careful, however, about using the terms precision approach and non-precision approach.
As I noted in a blog post about the forthcoming AC 90-119, FAA plans to adopt the new(ish) ICAO definitions for procedures that include 2D (lateral navigation) and 3D (lateral and vertical navigation).
In the past, precision approach applied only to procedures based on ground facilities that provide a glideslope or other approved vertical guidance to a DA–viz., an ILS or PAR. That obsolete definition required the creation of a new term, APV (approaches with vertical guidance), for RNAV procedures that offer approved vertical guidance to LPV or LNAV/VNAV decision altitude minimums.
Today, ICAO has updated its definition of precision approach by describing procedures that include approved vertical guidance to a DA, so-called 3D navigation. ICAO also describes so-called 2D approaches to MDAs.
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