Changes to Instrument Rating Cross Country Approach Requirement

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Changes to Instrument Rating Cross Country Approach Requirement Notice Number: NOTC2305
The Federal Aviation Administration (FAA) recently reviewed two legal interpretations 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On February 28, 2022, the FAA rescinded both the Glaser and Pratte legal interpretations, stating the regulation’s plain language requires three different types of approaches, not three different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.
More information is available at: www.faasafety.gov/files/notic...
Send comments/questions to 9-AFS-800-Correspondence@faa.gov
pdfhost.io/v/Vr2Vh1KWE_Glaser...
pdfhost.io/v/pENvP5GrY_Pratte...
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Опубликовано:

8 мар 2022

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Комментарии : 32

@SuperEddietv 2 года назад

The arguments on this subject have been amusing at a minimum. Thanks for the link. Good stuff.

@cfidad7005 2 года назад

I did this flight with my student about a week ago, but we flew in the Socal area, where there is more variety of approaches available. I could see where this would be difficult to abide in some other parts of the country. Even so, I still opted to do a VOR, ILS, and RNAV(APV), just in case. Meets the requirements of 3 different navigation and 3 different approach types by any definition. Will probably keep doing the same. As always, thanks for the content and for helping to spread the good news.

@ToddShellnuttCPC 2 года назад

You can't go wrong with just doing it!

@warrenstump4044 2 года назад

Many thanks Todd for the continued updates!!

@brianb5594 2 года назад

Todd - Funny I asked you this question shortly after getting my Double-I. Thanks for doing this session. Always insightful and great information my brother!

@rn2811 Год назад

I was lucky enough to have done one of those “non-precision” approaches as an LPV. However the DPE made me do a localizer Approach and spiced it up to making it a partial panel as well. Needless to say I passed that instrument check ride.

@mytech6779 2 года назад

Exellent as always.

@claudiom4616 2 года назад

I remember while doing my IFR x-country (about a decade ago), while on my final leg, tower canceled my GPS approach and cleared me for a visual approach. My instructor said, "that's still an approach! It counts as one of your 3! Regs say 3 different approaches, it does not say the must all be instrument." I was skeptical, but the DPE said everything "Looks good" as he reviewed my logbook. I passed the checkride. 🤷🏻‍♂️

@alessio272 2 года назад

DPEs typically don’t try and verify every single skill of an approach. Once they are satisfied with your first two approaches there’s no need to waste any more time.

@ToddShellnuttCPC 2 года назад

There has been much clarification since you did your training, In this FAA InFO, you can read all about when an IAP can be logged. www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info/all_infos/media/2015/InFO15012.pdf

@Wingsnbeers 2 года назад

Thanks for sharing! I didn’t get the Email! 😓 Really helpful video.

@ToddShellnuttCPC 2 года назад

You can if you want. When you visit a page on any of the FAA's websites, look for tools under the page title. If you see a "Subscribe" link, then they offer the service for that page. Next, click on the "Subscribe" link. Then, enter your email address. www.faa.gov/regulations_policies/rulemaking/recently_published/

@codylucero5855 2 года назад

So essentially, I could fly an ILS and a LOC approach (even though they are literally the same exact approach plate), and then a GPS LNAV and call it good, as long as I have the other requirements met such as the 250 mile requirement and the IFR flight plan, etc.

@ToddShellnuttCPC 2 года назад

On the cross country and the checkride, this is acceptable. The ILS uses a different navigational aid than the LOC does. Being that is also provides vertical guidance.

@hunterfagan6272 2 года назад

I’m confused at 17:00 You said that we can use the par, but not the asr because the par is in the acs, but I don’t think the ACS lists PAR or ASR approaches. Based on the letter of interpretation, wouldn’t PAR and ASR approaches be acceptable because they are listed in FAA order 8260?

@Tyler-yb4mc 2 года назад

I love you

@Superxpninja 2 года назад

Hopefully AFS decides to make the asr a non-precision approach. Imo it should be

@IzzyFlys1 Год назад

Quick question about the 250nm requirement aswell I know reg says via airways or atc directed routing , by my Interpretation that means If you were vector to a certain approach fix or your routing took you longer distance than it would have direct to the airport that counts towards the requirement is this correct?

@ToddShellnuttCPC Год назад

That is correct, as long as the total distance exceeds 250 nm. The keyword in 61.65(d)(2) is "cross country." This is where the airplane departs an airport and lands at another. So at some point along your 250 NM route, you must have landed at another airport to satisfy the requirement. A round-robin flight would not count as you did not land at another airport.

@IzzyFlys1 Год назад

@@ToddShellnuttCPC thank you for the clarification and I appreciate the video

@matthewsmall1817 2 года назад

can you mention how to register on the FAA website to receive these?

@matthewsmall1817 2 года назад

I just figured it out

@FlyingtheBigTireCruzer 2 года назад

I have an IFR equipped Experimental I built with "Legacy free" navigation, and I have had a hard time finding any DPE who would give me a check ride in my airplane because they said, "You can't fly 3 approaches with just the GTN-625 WAAS GPS, you need an ILS and VOR". Will this interpretation help me do a check ride in my own airplane with 3 variations of GPS approaches?

@jaimerabins7183 2 года назад

I have an experimental aircraft with a Dynon Skyview and GPS 175 , thus WAAS GPS only , luckily I found an CFI and DPE that let me train and test in my aircraft for Instrument, commercial, CFI, and CFII. Unfortunately it’s up to the CFI and DPE to use your airplane they are given the discretion to decline using your aircraft.

@ToddShellnuttCPC 2 года назад

Unfortunately, no. The ACS states. "The evaluator will select nonprecision approaches representative of the type that the applicant is likely to use. The choices must use at least two different types of navigational aids." So you would still need to conduct another type of navigation aid approach. Best bet would be to find another owner of the same model airplane as yours and do the checkride in that plane. Just my thoughts.

@mytech6779 2 года назад

Kind of of a tangent, but why would you fly IFR without any alternate NAV system? Even if you have two independent GPSS receivers there are still times and places with satellite signal outages. Maybe I'm skewed conservative by living in a land of clouds and mountains.

@FlyingtheBigTireCruzer 2 года назад

@@ToddShellnuttCPC WASS and Non WASS are considered different Navigation systems.

@haroldlocay3946 2 года назад

WAAS and non WAAS GPS are both considered GPS/one NAV aid. You can do all of your training with WAAS only including XC (that is what the memo is referring to) but for the check ride you must use TWO DIFFERENT Nav aids (GPS and another, eg. ILS or VOR). My DPE just got a letter from FAA explaining this clearly. My 2022 Bristell 915 has Garmin 375/WAAS GPS only. So for my upcoming IR Checkride I will rent a plane. PS. Apparently the IR ACS will be updated in the next year or two to allow all WAAS for Checkride. We will see.

@angesfan2334 2 года назад

I dont know where to ask this, but is this regulation/interp retroactive? Like if I did a flight with an ASR approach on the 250nm before this letter does it then count. Or only flights after this came out

@mytech6779 2 года назад

The regulation didn't change, only the interpretation. Beside that the reg doesn't say exactly when a the flight must occur so a previous flight of xyz would be as valid as any new flight of xyz. You could use time logged 50 years ago before the regulation existed at all, just as long as that logged flight meets the all of the current requirements. Just to be clear there is some required flight time with a limited allowable calender frame, but many[most?] of the experience requirements are without calender limits.

@ToddShellnuttCPC 2 года назад

With this LOI, you can not count the ASR until AFS should determine whether ASR should be part of a non-precision instrument approach under §1.1, and whether the use of ASR is considered a navigation system under §61.65(d)(2)(ii)(C). So we need to wait until that is clarified first.