As I said when doing my CFII add-on, I did it with ILS, LOC, and VOR, which only used two navigation systems (LOC/GS and VOR), and that was specifically approved by the FSDO. Or it could be done with LPV, NDB, and VOR. One could meet the requirement with ILS, LOC, and an RNAV/GPS LNAV approach. The regs never said, “3 different navigation systems.” The regs said, “One precision and two non-precision approaches.” There is nothing ambiguous about that and nothing that required any particular navigation system. This kind of thing is enough to give a good CFI nightmares. (I put that in quotes because while it was NOT wrong, it might have been interpreted as that should there have been some kind of investigation.) Of course, this raises a red flag for me: what else have I been doing “wrong” by interpreting the regs simply? It is nice to have things clarified but, like I said, the words have always been clear, but I may have been doing it “wrong”. Just because the airplane didn’t have GPS didn’t mean that I wasn’t well versed in flying GPS-based approaches or in the characteristics of GPS. At first the DPE didn’t think I could do it without GPS in the aircraft but a check with the FSDO produced, “Yes, it meets the requirements in the reg.” (Sounds like the FSDO didn’t know about the Glasser letter either.) He then grilled me mercilessly on GPS during the oral but that was fine. I pointed out that I could meet the, “3 types of approaches, one precision and two non-precision,” using ILS, LOC, and VOR. I even did my CFII checkride in an airplane with no GPS/FMS. The words of the reg have always seemed very clear to me - three different approaches, one precision and two non-precision. Wow! All this time I have been doing this right by doing it wrong … or is that right? Our SAFE CFI insurance was developed by SAFE specifically for CFIs (and is the best value in the business). Our FREE SAFE Toolkit App puts all required pilot endorsements and experience requirements right on your smartphone and facilitates CFI+DPE teamwork. Join SAFE and enjoy great benefits(like 1/3 off ForeFlight)! Your membership supports our mission of increasing aviation safety by promoting excellence in education. To be perfectly clear (thanks to a comment) this FAA memo clarifies *training.* Testing remains unchanged specifying two nav systems for non-precision approaches (but nowhere requires *three* separate nav sources). ILS precision, LOC non-precision works here. (One certainly could be a VOR) Knowledge of VOR seems critical since this is the FAA backup in the MON system if the GPS constellation fails. In testing, Appendix 7 of the Instrument ACSrequires two different *navigational systems* for the non-precision approaches. Furthermore, because the regulations do not define “navigation systems,” Flight Standards Service (AFS) is in the best position to issue policy and guidance on what “navigation systems” mean and which ones may be used under § 61.65(d)(2)(ii)(C)…ongress intended for courts to defer to agencies when they interpret their own ambiguous rules.Ĭlarification was just issued and disseminated with this FAA Legal interpretation, separating “navigational systems” from “approaches” and freeing up training to use a LOC and/or ILS in a training event under CFR 61.65. If a test is flown with improper procedures, heads will roll.Īs a result, the FAA is rescinding both the Glaser and Pratte interpretations. The long X-C has to be verified for qualification. You might think this is silly, but Portland FSDO just terminated 3 DPEs (in one day) for various indiscretions – we try hard to do this job legally and correctly. Until now, if you follow the strict interpretation of “different approach” in the Glasser Letter (as different “navigational system”) you are continually searching around for an operational VOR to execute an approach for training (flying another approach over a “local VOR” is also not legal for testing – has to be the real deal). Conscientious CFIs and DPEs have been carefully skating on the edge of “FAA legality” with the ambiguity in the FAA interpretation of “instrument approaches” in the regs.
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