New IFR Currency Rules and Other Changes to 14 CFR Part 61

On June 27, 2018, FAA published an extensive revision to sections of 14 CFR Part 61 governing IFR currency with the use of aviation training devices, the role of technically advanced aircraft (TAA) in training for certain certificates and ratings, and many other important changes. You can download the PDF of the final rule here.

This rule is result of an NPRM published in May 2016, which you read about at BruceAir here.

Some of the new regulations should become effective July 28, 2018. Others will be effective later; the details of the effective dates are in the final rule and provided later this article.

The new regulations of primary interest to general aviation pilots:

  • Allow instrument-rated pilots to maintain IFR currency using an ATD, FTD, or FSS without having an instructor present. The IFR currency rules also now make no distinction between tasks performed in an ATD, FTD, or FSS and an aircraft.
  • Change some provisions related to the completion of an instrument proficiency check (IPC).
  • Allow the use of technically advanced aircraft in lieu of or in combination with complex aircraft to acquire 10 hours of flight time formerly required in a complex aircraft for commercial pilot applicants.

SUMMARY: This rulemaking relieves burdens on pilots seeking to obtain aeronautical experience, training, and certification by increasing the allowed use of aviation training devices. Use of these training devices has proven to be an effective, safe, and affordable means of obtaining pilot experience. This rulemaking also addresses changing technologies by accommodating the use of technically advanced airplanes as an alternative to the use of older complex single engine airplanes for the commercial pilot training and testing requirements. Additionally, this rulemaking broadens the opportunities for military instructor pilots or pilot examiners to obtain civilian ratings based on military experience, expands opportunities for logging pilot time, and removes a burden from sport pilot instructors by permitting them to serve as safety pilots. Finally, this rulemaking includes changes to some of the provisions established in an August 2009 final rule. These actions are necessary to bring the regulations in line with current needs and activities of the general aviation training community and pilots.

The following is an analysis of the new rules that are of interest primiarly to pilots operating under 14 CFR Parts 61 and 91. To understand all of the new regulations and how they affect certain commercial operators and flight training programs, you should review the entire text of the final rule.

CFI No Longer Required when using FFS, FTD, or ATD to Maintain IFR Currency

The FAA is amending § 61.51(g) by revising paragraph (g)(4) and adding a new paragraph (g)(5) to allow a pilot to accomplish instrument recency experience when using a FFS, FTD, or ATD without an instructor present, provided a logbook or training record is maintained to specify the approved training device, time, and the content as appropriate.

To learn more about the definitions of FSS, FTD, and ATD, see the final rule and AC 61-136.

A pilot will still be required to have an instructor present when using time in a FFS, FTD, or ATD to acquire instrument aeronautical experience for a pilot certificate or rating.

And the new rule does not changes the provisions of § 61.51 that require an instrument proficiency check if a pilot does not maintain IFR currency.

Here’s the revised language:

§ 61.51 (g) (5) A person may use time in a full flight simulator, flight training device, or aviation training device for satisfying instrument recency experience requirements provided a logbook or training record is maintained to specify the training device, time, and the content.

(h) Logging training time. (1) A person may log training time when that person receives training from an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device.

The new language for § 61.57 Recent flight experience: Pilot in command is:

(c) (2) Use of a full flight simulator, flight training device, or aviation training device for maintaining instrument experience. A pilot may accomplish the requirements in paragraph (c)(1) of this section in a full flight simulator, flight training device, or aviation training device provided the device represents the category of aircraft for the instrument rating privileges to be maintained and the pilot performs the tasks and iterations in simulated instrument conditions. A person may complete the instrument experience in any combination of an aircraft, full flight simulator, flight training device, or aviation training device.

The FAA’s analysis of the comments on the proposal notes that:

…[B]ecause instrument recency experience is not training, the FAA no longer believes it is necessary to have an instructor present when instrument recency experience is accomplished in an FSTD or ATD. The FAA is therefore removing the requirement for an authorized instructor to be present when a pilot accomplishes his or her instrument recency experience in an FFS, FTD, or ATD…

As with instrument recency experience accomplished in an aircraft, § 61.57(c) requires the pilot to log the required tasks in his or her logbook and § 61.51(b) requires certain information to be logged, including the type and identification of the FSTD or ATD. Additionally, § 61.51(g)(5) requires the pilot to maintain a logbook or training record that specifies the training device, time, and content. The FAA therefore emphasizes the importance of clearly documenting in one’s logbook the type and identification of the FFS, FTD, or ATD used to maintain recency and a detailed record of the specific tasks completed.

The FAA discussion points out that pilots have long been able to maintain IFR currency in aircraft by flying with a safety pilot, and the FAA addressed several comments about the efficacy of using ATDs and FTDs to maintain instrument currency.

Because instructor supervision is not required when a pilot satisfies the instrument
recency experience in an aircraft, similarly, it should not be required when a pilot satisfies the same instrument recency experience in a FFS, FTD, or ATD. A pilot must perform and log the required tasks regardless of whether the tasks are accomplished in an aircraft, FFS, FTD, or ATD. As several commenters noted, pilots who satisfy the instrument recency experience in an FFS, FTD, or ATD should be trusted in the same fashion as those pilots who satisfy the requirements in an aircraft. While there is a potential for falsification in both scenarios, the FAA finds that the current penalties for falsifying pilot logbooks and records, which include suspension or revocation of one’s airman certificate, are a sufficient deterrent to falsifying the logging requirements…

Furthermore, the FAA is not requiring the FFS, FTD, or ATD to produce a flight track and log pilot activities as proof of performing the required tasks for maintaining instrument recency; nor is the FAA imposing more stringent recordkeeping requirements on the flight schools who own such FFS, FTD, or ATDs or on the pilots who use the FFS, FTD, or ATD to maintain instrument recency…

The FAA finds that satisfying instrument recency experience requirements in an FFS, FTD or ATD is as beneficial as satisfying the requirements in an aircraft regardless of whether an instructor is present. FFSs, FTDs, and ATDs are specifically designed to allow a person to replicate and execute instrument tasks just as they would in an aircraft…

Section 61.57(c) requires a pilot to perform and log minimum tasks to maintain instrument recency; § 61.57(c) does not impose training or proficiency requirements. An instrument-rated pilot has already demonstrated his or her proficiency during a practical test with an examiner. The purpose of the instrument recency experience requirement is to ensure the pilot maintains his or her instrument proficiency by performing and logging the required instrument experience. Therefore, the FAA expects pilots accomplishing the instrument recency experience to already be at an acceptable level of proficiency. The FAA recommends, however, that a pilot seek additional training if he or she is uncomfortable with his or her performance of the required tasks under § 61.57(c)…

FAA believes that new § 61.51(g)(5) will likely increase the public’s use of FFSs, FTDs or ATDs and notes that the majority of comments supported this conclusion…

As a general matter, the FAA notes that ATDs allow programming and practice of many instrument situations, scenarios, and procedures. The current capabilities of ATDs, FTDs, and FFSs allow an instrument rated pilot to program and successfully practice simulated low visibility weather conditions, multiple approaches in a shorter period of time, emergency procedures, equipment failures, and other various flight scenarios that cannot necessarily be accomplished in an aircraft safely. Allowing the use of ATDs, FTDs and FFSs without the requirement (and therefore the cost) of having an instructor present can result in more pilots being better prepared. This benefit could include executing flight scenarios they may not normally experience when accomplishing instrument recency in an aircraft, or in locations where they do not normally fly, or when practicing emergency procedures that are likely too dangerous to accomplish in an aircraft. This includes the unique capability of practicing identical instrument approach procedures to an airport the pilot may not have otherwise flown to before.

Instrument Recency Experience Requirements

The new rules will simplify § 61.57(c) which describes how pilots can use ATDs, FTDs, and FSS alone or in combination with flight time in an aircraft to maintain IFR currency.

The FAA is aligning the requirements for accomplishing instrument experience in an ATD with the requirements for accomplishing instrument experience in an FSTD or aircraft. Prior to this final rule, a person accomplishing instrument recency experience in an aircraft, FFS, FTD, or a combination, was required to, within the preceding 6 months, have performed: (1) Six instrument approaches; (2) holding procedures and tasks; and (3) intercepting and tracking courses through the use of navigational electronic systems. Persons accomplishing instrument recency experience exclusively in an ATD, however, were required to have performed, within the preceding 2 months, the same tasks and maneuvers listed above plus “two unusual attitude recoveries while in a descending Vne airspeed condition and two unusual attitude recoveries while in an ascending, stall speed condition” and a minimum of three hours of instrument recency experience. This final rule amends § 61.57(c) to allow pilots to accomplish instrument experience in ATDs by performing the same tasks required for FSTDs and aircraft, and at the same 6-month interval allowed for FSTDs and aircraft.

In support of the change, the FAA notes that:

FAA believes that the current design and technology of ATDs has advanced and provides a greater opportunity for the advancement of instrument skills and improved proficiency, as well as a wider range of experiences and scenarios, which justifies their increased use in § 61.57(c)(2)…

While the FAA stated in the NPRM that a pilot would be permitted to complete instrument recency experience in any combination of aircraft, FFS, FTD, or ATD, the proposed rule would not have expressly allowed this. The FAA is therefore adding language to proposed § 61.57(c)(2) to expressly state that a person may complete the instrument recency experience in any combination of aircraft, FFS, FTD, or ATD…

FAA disagrees with [comments] requiring a pilot to accomplish the instrument recency experience in an aircraft. The FAA has allowed the instrument recency tasks to be accomplished in an FFS, FTD, or ATD since 2009. The FAA did not propose to change the allowance of an ATD to satisfy instrument recency experience. Rather, given the technological advancements that have occurred in ATDs since 2009, the FAA proposed to align ATD use to the 6-month task completion interval and the required tasks consistent with FSTDs and aircraft…

FAA finds that an ATD adequately replicates an aircraft for purposes of maintaining instrument recency. Section 61.57(c) does not require a pilot to experience variables and additional stressors that one may experience in an aircraft to maintain instrument recency. The FAA recognizes the importance of familiarity with these conditions and events; however, they are more attributable to training. An instrument-rated pilot maintaining instrument recency under § 61.57(c) has already accomplished the required instrument training and has already demonstrated his or her proficiency during a practical test with an examiner.

Furthermore, the FAA disagrees with the comment that requiring more flight time in an aircraft will result in fewer accidents. The FAA finds that allowing a pilot to accomplish instrument recency requirements in an ATD or FSTD encourages more pilots to remain instrument current and provides the necessary experience to enable safe operation of an aircraft in instrument meteorological conditions (IMC)…

FAA believes that training in FSTDs and ATDs in combination with training in an aircraft reinforces the necessary pilot skill to rely solely on the flight instruments to successfully operate an aircraft in IMC. This mitigates any reliance on postural senses, sounds, or feelings that can otherwise lead to loss of control. The FAA further described that training devices do not require motion to be approved and that training devices cannot completely train the pilot to ignore certain erroneous sensory perceptions, but pilots develop this skill during the flight portion of their instrument training. Consistent with the final rule, “Aviation Training Device Credit for Pilot Certification,” the FAA believes that instrument experience accomplished in ATDs is an effective procedural review and reinforces the necessary skills to properly interpret the aircraft’s flight instruments, allowing successful operation of an aircraft in IMC.

Change to IPC Requirements

The final rule also revises § 61.57(d) to remove the reference to the practical test standards (or ACS) for the tasks required to complete an IPC.

In § 61.57(d), the FAA is removing the reference to the PTS. The FAA recognizes that it was inappropriate for § 61.57(d) to state that the areas of operation and instrument tasks were required in the instrument rating PTS. The PTS and ACS do not contain regulatory requirements. Therefore, rather than referencing the instrument rating ACS in § 61.57(d), the FAA is codifying in § 61.57(d) the areas of operation for an IPC.

The new § 61.57(d) reads:

Instrument proficiency check. (1) Except as provided in paragraph (e) of this section, a person who has failed to meet the instrument experience requirements of paragraph (c) of this section for more than six calendar months may reestablish instrument currency only by completing an instrument proficiency check. The instrument proficiency check must consist of at least the following areas of operation:

(i) Air traffic control clearances and procedures;

(ii) Flight by reference to instruments;

(iii) Navigation systems;

(iv) Instrument approach procedures;

(v) Emergency operations; and

(vi) Postflight procedures.

Note that the new rule doesn’t specifically mention circle-to-land approaches, approaches to a landing, etc. According to the IFR ACS, these tasks must be accomplished in an airplane if you use an ATD or FTD for other parts of an IPC.

But the new list is more general. The new language in § 61.57(d) implies you could use an ATD or FTD to complete all of an IPC since you wouldn’t specifically be required to complete tasks that typically are not approved in those devices.

The change to § 61.57(d) seems to require updating at least the LOAs for ATDs and FTDs, AC 61-98D, and Instrument Proficiency Check (IPC) Guidance.

Completion of Commercial Pilot Training and Testing in Technically Advanced Airplanes

The new rules, effective August 28, 2018, will complement the recent changes in FAA policy that no longer require the use of complex aircraft for certain practical tests (more on this topic at BruceAir here).

The final rule substantially changes the definition of TAA in the NPRM.

§ 61.129 Aeronautical experience.

(ii) 10 hours of training in a complex airplane, a turbine-powered airplane, or a
technically advanced airplane (TAA) that meets the requirements of paragraph (j) of this section, or any combination thereof. The airplane must be appropriate to land or sea for the rating sought;…

(j) Technically advanced airplane. Unless otherwise authorized by the Administrator, a technically advanced airplane must be equipped with an electronically advanced avionics system that includes the following installed components:
(1) An electronic Primary Flight Display (PFD) that includes, at a minimum, an airspeed indicator, turn coordinator, attitude indicator, heading indicator, altimeter, and vertical speed indicator;
(2) An electronic Multifunction Display (MFD) that includes, at a minimum, a moving
map using Global Positioning System (GPS) navigation with the aircraft position displayed;
(3) A two axis autopilot integrated with the navigation and heading guidance system; and
(4) The display elements described in paragraphs (j)(1) and (2) of this section must be
continuously visible.

The discussion of the new rule expands on the reasoning behind and comments on the NPRM.

Prior to this final rule, a pilot seeking a commercial pilot certificate with an airplane single-engine class rating was required to complete 10 hours of training in either a complex or turbine-powered airplane. In the NPRM, the FAA proposed to add a definition of technically advanced airplane (TAA) to § 61.1 and amend the training requirements to allow a pilot seeking a commercial pilot certificate with an airplane single-engine class rating to complete the 10 hours of training in a TAA instead of a complex or turbine-powered airplane. In addition to these regulatory changes, the FAA proposed to revise the practical test standards for commercial pilot applicants and flight instructor applicants seeking an airplane category single engine class rating to allow the use of a TAA on the practical tests.

Several comments on the NPRM highlighted problems with the FAA’s original defintion of TAA. In response, the FAA notes that:

The FAA recognizes that the proposed definition would have been too prescriptive. …FAA has revised the proposed language in response to industry’s concerns to make it more flexible and accommodating of new technologies. Furthermore, the FAA recognizes that the definition of TAA would have inappropriately embedded requirements, which may have inhibited future technologies from falling under the definition of a TAA. The FAA is therefore revising the definition of TAA in § 61.1 to contain a more general description of a TAA. TAA is now defined as an airplane equipped with an electronically advanced avionics system. The FAA is relocating the requirements regarding what a TAA must contain to § 61.129 by adding new paragraph (j). The FAA is also adding language to § 61.129(j) to allow the FAA to authorize the use of an airplane that may not otherwise meet the requirements of a TAA. This additional language is intended to provide flexibility by allowing the FAA to accommodate future technologies that do not necessarily meet the confines of the regulatory requirements for a TAA in § 61.129(j).

The discussion of the final rule includes a detailed response to comments about the use of such terms as PFD and MFD and the description of the autopilot required in a TAA. The basic requirements are described in the FAA discussion:

FAA is retaining the terms “Primary Flight Display,” “Multifunction Display,” and “advanced” in the TAA requirements. The FAA disagrees that the terms PFD and MFD will cause confusion. These terms are currently used and described in several FAA publications that are recognized by the aviation industry…

PFD is defined as “a display that provides increased situational awareness to the pilot by replacing the traditional six instruments used for instrument flight with an easy-to-scan display that provides the horizon, airspeed, altitude, vertical speed, trend, trim, and rate of turn among other key relevant indications.” MFD is defined as a “small screen (CRT or LCD) in an aircraft that can be used to display information to the pilot in numerous configurable ways. Often an MFD will be used in concert with a primary flight display.”

The FAA believes the terms PFD and MFD add clarity to the TAA requirements by
describing and prioritizing the display features and elements for TAA avionics and their respective functions. For example, the term PFD is specific to the use of the primary flight controls to maintain aircraft attitude and positive control. The PFD is used by the pilot to execute appropriate use of the control stick or yoke for pitch and bank, rudder pedals for yaw, and throttle for engine power. The PFD is designed specific to controlling the aircraft attitude and altitude relative to the horizon and the surface of the earth, especially when outside visibility is poor or unavailable. The MFD has a different priority; its function is secondary to the PFD. The MFD is designed for navigational use and position awareness information, even though it may include some PFD features for redundancy. Furthermore, the FAA is requiring certain minimum display elements for both a PFD and MFD, respectively, thereby clarifying what will be considered a PFD or MFD…

Section 61.129(j)(2) requires only the minimum elements of a MFD; it does not preclude the use of a split-screen display or two independent screens contained within a single physical unit. Therefore, a manufacturer may use a split-screen display or two independent screens for the PFD and MFD provided the displays contain the minimum elements required for each…

FAA is clarifying the MFD requirements by first describing what the display shows (i.e., a moving map) and then describing how the display is facilitated (i.e., using GPS navigation). Accordingly, § 61.129(j)(2) now requires the MFD to include, at a minimum, a moving map using GPS navigation. The FAA believes this
revision to the proposed language clarifies that a system with a moving map display common to GPS/WAAS navigators would satisfy the MFD requirement. Additionally, the FAA is requiring the aircraft position to be displayed on the moving map…

FAA removing the phrase “independent additional” from the proposed language to allow a single piece of equipment or single display to satisfy the requirement for both a PFD and MFD. However, to ensure that both displays are visible at the same time, the FAA is requiring the display elements for both the PFD and MFD (paragraphs (j)(1) and (2)) to be continuously visible…

FAA did not intend to exclude systems that provide autopilot functions separate from the MFD. The FAA is therefore separating the “two-axis autopilot” requirement from the MFD requirement. Accordingly, under new § 61.129(j)(3), the two axis autopilot is no longer required to be included as part of the MFD. This change from what was proposed allows the use of independent/aftermarket autopilot systems…

The TAA requirements in no way restrict the use of peripheral or supporting equipment that enables the display functionality described for the PFD and MFD in the TAA requirements…

While there may be different TSOs for the various functions of GPS, moving map, and navigation resulting in separate pieces of underlying equipment, this equipment can support the MFD requirements so long as the MFD includes a moving map that uses GPS navigation with the aircraft position displayed…

The TAA requirements of § 61.129(j) do not require the autopilot to have GPSS. However, § 61.129(j) specifies only the minimum requirements for a TAA. Therefore, an autopilot may have additional features, including GPSS. The “two axis” requirement refers to the lateral and longitudinal axes. The autopilot at a minimum must be able to track a predetermined GPS course or heading selection, and also be able to hold a selected altitude. The autopilot is not, however, required to control vertical navigation other than holding a selected altitude…

Revised Definition of Pilot Time

The new rule changes the definition of pilot time in § 61.1 to read:

Pilot time means that time in which a person—
(i) Serves as a required pilot flight crewmember;
(ii) Receives training from an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device; or
(iii) Gives training as an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device.

Effective Dates

The changes to the regulations become effective as follows:

This rule is effective July 27, 2018, except for the amendments to §§ 61.31(e)(2) and (f)(2), 61.129(a)(3)(ii), (b)(3)(ii) and (j), 61.197, 61.199, 61.412, 61.415, 91.109, and appendix D to part 141, which are effective August 27, 2018; the amendments to §§ 61.1 (amendatory instruction 10 revising the definition of ‘‘Pilot time’’), 61.39, 61.51(e) and (f), 61.57(c), 61.159(a), (c), (d), (e), and (f), 61.161(c), (d), and (e), 135.99, and 141.5(d) which are effective November 26, 2018; and the amendments to §§ 61.3, 63.3, 63.16, 91.313, 91.1015, 121.383, and 135.95, which are effective December 24, 2018.



Proposed Changes to Airport Diagrams

FAA is proposing to remove the inset airport diagrams from instrument procedure charts and the Chart Supplement (A/FD) and instead publish complete airport diagrams for all airports with IFR procedures.

The proposal (detailed FAA briefing here) was discussed at the April 25-26, 2018 meeting of the Aeronautical Charting Forum (complete meeting minutes here).

FAA currently produces:

  • 700 airport diagrams
  • 3000 airport sketches in the Chart Supplement
  • 3000 inset diagrams on terminal procedure charts


The detailed proposal includes the following key points:

  • Eliminate Terminal and Chart Supplement Sketches.
  • All hard-surfaced runway public use airports with IFR procedures will have a published airport diagram.
  • Eliminate cultural features such as trees, creeks, water and power lines etc.
  • Change diagram specifications to incorporate information from the chart supplement and terminal chart sketches.
  • Add geo-referenced information for real-world location and for future data driven product development.

FAA argued that the proposed charting change would:

  • Eliminate maintenance of three types of airport layouts.
  • Create a single standard Airport Diagram for all airports.
  • Print one diagram in one publication (currently printed 4 ways).
  • Free up space in the TPP plate for more relevant procedural information
  • Provide a more robust product.
  • Streamline internal production processes.
  • Deliver a more accurate and updated product.

An FAA representative noted that Jeppesen does not publish inset sketches on its terminal charts. Adopting this proposal would follow that practice.

The proposal generated detailed discussion, and FAA solicited comments from users and organizations such as AOPA.

Cloud Surfing

A few minutes of flying among the clouds during a couple of IFR flights in the Pacific Northwest.

More videos at my YouTube channel, BruceAirFlying.

Setting the CDI on a Conventional Approach (The “Kill Switch”)

If you fly an aircraft with an IFR-approved GNSS, you probably use that “suitable RNAV system” to help you fly all types of approaches, including ILS, LOC, and VOR procedures. In fact, if your aircraft isn’t equipped with DME or ADF, using an IFR-approved GNSS system may be the only way for you to fly many conventional procedures.

“Suitable RNAV systems” based on GNSS are described in AIM 1−2−3. Use of Suitable Area Navigation (RNAV) Systems on Conventional Procedures and Routes, AC 90−100, AC 90-108, and other FAA references.

A critical step in flying conventional approaches while using GNSS to fly transitions/feeder routes is ensuring that the proper guidance is shown on the PFD/HSI as you intercept and then fly the final approach course.

For example, as shown below, when flying the LOC RWY 17 approach at Aurora, OR (KUAO), you could use the GNSS for course guidance as you fly the charted transition from the Battleground (BTG) VOR.



Some systems can automatically switch the CDI from the “magenta line” shown when using GNSS signals to “green needles,” usually labeled VOR/LOC, as you intercept final. But you must always monitor the avionics and, if necessary, use the CDI button (or other switch for your system) to change to VOR/LOC “green needles” before you join the final approach course.


For more information about guidance along the final approach course, see Use of IFR GPS on Conventional Approaches here at BruceAir.

Unfortunately, many pilots fail to confirm this critical step, which often occurs during a high-workload phase of an approach. For example, just as you are about to intercept the final approach course, ATC may issue a rapid-fire vector and approach clearance (“Fly heading 130, maintain 2,000 until established…”), you can be distracted while making a late configuration change, or while switching frequencies to the tower or CTAF.

In fact, this error is so common that many pilots and instructors call the CDI switch the “kill button” (or a similarly ominious name) to emphasize its importance.

I use a graphical reminder to help me ensure that I switch course guidance in plenty of time for a smooth intercept.

Like many pilots, I use a tablet and an aviation app (in my case, primarily ForeFlight) to display charts. Those apps typically have an annotation feature that lets you mark up charts to emphasize important information.


For example, on this chart for another approach at KUAO, I’ve noted a temporary change in minimums.


To remind myself to switch the CDI to “green needles” on conventional approaches, I use the annotation feature to draw a transparent green line along the final approach course.


I mark up the charts for conventional approaches during my preflight planning as I review weather, NOTAMs, procedures that I might fly, and other details.

I organize approaches that I fly often into binders in ForeFlight (other apps have a similar feature), and the markups are preserved between flights, so I don’t have to repeat this process for most of the procedures that I fly.

Because RNAV (GPS) approaches don’t require changing from GNSS guidance, I don’t highlight the final approach segment on those procedures.

To avoid cluttering charts, I also don’t mark the intial steps of a missed approach in magenta to signify that I can return to GNSS guidance to fly the miss, regardless of the type of approach. But if you’re in IFR training or new to using GNSS under IFR, highlighting the miss in magenta might be a useful reminder.

New Simulation and Training Rules Due in June 2018

The final rule is set for publication on June 27, 2018 (see this notice at the Federal Register). I’ll provide a summary here at BruceAir.

You can read more about the NPRM published in May 2016 at my blog, here.

RVR 1800 with AP, FD, or HUD

On May 30, 2017, FAA updated Order 8400.13D to allow “CAT I approaches with a DH of 200 feet and visibility minimums of RVR 1800 [a reduction from the typical 2400 RVR value] at runways with reduced lighting, using an aircraft flight director (FD) or autopilot (AP) with an approach coupler or head-up display (HUD) to DA.”

This change applies to ILS and RNAV (GPS) approaches with LPV minimums. (GBAS approaches are also included, but those procedures are, at present, rare.)

The policy update was announced in the summer 2017 edition of SatNav News.

Here’s an example of the RVR 1800 minimums on the chart for the ILS or LOC Rwy 20 at KALW (Walla Walla, WA).

KALW-ILS-RWY 20-full

This typical category 1 ILS approach has an RVR of 2400 and a DA of 200 ft (1394 MSL).

KALW-ILS-RWY 20-mins
But as the notes for the procedure explain, the # symbol next to the S-ILS 20 minimums means that RVR 1800 is authorized with use of a flight director (FD) or autopilot (AP) or HUD to the DA.

KALW-ILS-RWY 20-notes
FAA Order 8400.13D adds the following information about reducing CAT 1 minimums to RVR 1800:

  • To be eligible for CAT I approaches to RVR 1800, runways must have or be qualified for a Title 14 of the Code of Federal Regulations (14 CFR) part 97 Standard Instrument Approach Procedure (SIAP).
  • Runways must have or be qualified for CAT I DH of 200 feet or less and visibility minimum of not more than 2400 RVR.
  • The runway must have a declared landing distance of 5000 feet or greater.
  • The runway also must have a simplified short approach lighting system with runway alignment indicator lights (SSALR), medium intensity approach lighting system with runway alignment indicator lights (MALSR), or approach lighting with sequenced flashing lights (ALSF-1/ALSF-2)
  • HIRL
  • TDZ sensor of an RVR reporting system.

The order adds that:

Any existing part 97 CAT I SIAP which did not qualify for 1800 RVR due to the absence of TDZ or RCL lighting can be amended to include 1800 RVR visibility.

When 1800 RVR operations are authorized, FAA will update the approach chart. If RVR 1800 minimums are authorized before a chart is updated, a NOTAM will be issued which authorizes RVR 1800. CAT I operations to RVR 1800 will be added to existing CAT I SIAPS in accordance with a schedule established by the Regional Airspace and Procedures Team.

The ILS OR LOC/DME RWY 21R at KPSC (Pasco, WA) is another example of RVR 1800 minimums authorized for an ILS.


The S-ILS 21R minimums line includes two asterisks that point to the notes section, which authorizes RVR 1800 with use of a FD, or AP, or HUD to DA.

The RNAV (GPS) Y RWY 21R at KPSC, updated in August 2017, shows the RVR 1800 minimums applied to an RNAV approach with LPV minimums. On this chart, the # note reference appears next to DA.


New Edition of Instrument Procedures Handbook

FAA has published a new edition of the Instrument Procedures Handbook (FAA-H-8083-16B). You can download a PDF of the IPH at the FAA website here.

The IPH is a complement to the Instrument Flying Handbook (FAA-H-8081-15B), available for download here.

A summary of changes in the new edition of the IPH is available as a PDF in my Aviation Documents folder, here.