“Long IFR XC”: FAA Changes Guidance

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On February 28, 2022, the FAA rescinded both the Glaser and Pratte legal interpretations, stating the regulation’s plain language requires three different types of approaches, not three different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.

Webinar: Briefing IFR Procedures

On February 9, I presented a webinar about Briefing IFR Procedures. The event was hosted by the American Bonanza Society (I’m an instructor for the Beechcraft Pilot Proficiency Program at ABS).

You can watch the recording of the webinar on the ABS website, here (ABS membership is not required).

For more information about how I annotate electronic charts, see Annotating IFR Charts and Stylus for iPad and ForeFlight ScratchPads and Annotations.

FAA Completes ATC Phone Number Plan

The February 25, 2019 issue of FAAST Blast includes the following item about FAA’s plan to publish ATC telephone numbers in the Chart Supplement. You can read more details and see examples at earlier entries here at BruceAir:

Leidos FSS has posted ARTCC clearance/cancelation phone numbers on its website, here.

FAA Completes Clearance Relay Initiative

Flight Service will complete the Clearance Relay initiative on June 20 when it publishes the remaining phone numbers for pilots to obtain IFR clearances at public- and private-use airports, from either the overlying Air Route Traffic Control Center (ARTCC) Flight Data Units, or an approach control facility. As part of modernization efforts to streamline service delivery and increase efficiency, pilots now call directly to obtain or cancel an IFR clearance, reducing the risk of potential errors.

Last year, Flight Service formalized a process already in place by publishing phone numbers for 30 approach controls covering 667 public use airports, providing pilots direct contact with the controlling facility. Last fall, another 26 approach control facilities covering 226 public-use and 3,000 private-use airports had numbers published in the Chart Supplement, US and subscriber files.

Leidos Flight Service will provide pilots with the name of the facility to contact or the correct phone number to obtain or cancel an IFR clearance. Pilots may continue to request clearances via radio from air traffic control or Flight Service.

You can find the phone numbers for clearance delivery in the remarks section of the entry for each airport in the Chart Supplement, US. This initiative does not affect pilots requesting clearances from Flight Service over Remote Communications Outlets (RCO), Ground Communication Outlets (GCO), or from locations in Alaska. For more information, visit https://go.usa.gov/x5wsR.

New Equipment Required Notes

FAA has published a charting notice (PDF) that describes how equipment requirements will be noted on terminal procedure charts. This change is based on a long discussion at the Aeronautical Charting Forum (see 13-02-312: Equipment Requirement Notes on Instrument Approach Procedure).

For procedures with PBN elements, the PBN box will contain the procedure’s navigation specification(s); and, if required: specific sensors or infrastructure needed for the navigation solution; any additional or advanced functional requirements; the minimum Required Navigation Performance (RNP) value and any amplifying remarks. Items listed in this PBN box are REQUIRED. The separate Equipment Requirements Box will list ground-based equipment requirements. On procedures with both PBN elements and ground-based equipment requirements, the PBN requirements box will be listed first.

The publication of the new notes will continue incrementally until all charts have been amended to comply with the new standard.

A sample of the new notes boxes is below.

PBN Requirements Notes

Here’s an example of the requirements box on the recently updated chart for the ILS RWY 28R approach at Billings, MT (KBIL):


New Edition of the Instrument Procedures Handbook

The FAA has published a new edition of the Instrument Procedures Handbook (FAA-H-8083-16). You can download the free PDF from the FAA website, here.


This is first major update to the IPH since 2007. As the preface notes:

It is designed as a technical reference for all pilots who operate under instrument flight rules (IFR) in the National Airspace System (NAS). It expands and updates information contained in the FAA-H-8083-15B, Instrument Flying Handbook, and introduces advanced information for IFR operations. Instrument flight instructors, instrument pilots, and instrument students will also find this handbook a valuable resource since it is used as a reference for the Airline Transport Pilot and Instrument Knowledge Tests and for the Practical Test Standards. It also provides detailed coverage of instrument charts and procedures including IFR takeoff, departure, en route, arrival, approach, and landing. Safety information covering relevant subjects such as runway incursion, land and hold short operations, controlled flight into terrain, and human factors issues also are included.