IFR three approach interpretation

jaymark6655 said:
Maybe, but they shouldn't hold to something they are thinking but isn't writting unless mindreading is now a requirment.
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An em dash might be all they needed. Consider the two different meanings, depending on the em dash:

"Three different kinds of--approaches with the use of navigation systems."

"Three different kinds of approaches--with the use of navigation systems."​

Of course, I'm not an English scholar so this is probably wrong. :rolleyes:
 
Clip4 said:
In the olden days you found it just like the LOC, just flew to the compass locator.
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Wouldn't that just find you the localizer? Then, after a nice leisurely scenic route around a procedure turn, you came back toward the airport and fished for the glide slope. Ah, the good ol' days: no pesky radar vectors and all that talkin', just quietly follow your own recipe. :)
 
Wheels said:
Agreed, but that is the problem with asking lawyers who aren’t pilots to interpret the regulations. They assume that approaches using the same system must be the same type of approach. They don’t have any idea how the approaches actually work and can’t really make an educated interpretation.
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But do they? Or is this something people read into that is just not there? My Long IFR XC was ILS, LOC, and GPS. DPE certainly did not have any problem with that and I know he is by the book and pays close attention to the FAA Counsel opinions.
 
So the issue at hand is whether the reg intends the student to conduct three different types of approaches which all use navigation systems, i.e. no 'cleared for the visual...' or whether the reg intends the student to conduct three different types of approaches that each utilize a different type navigation system.

Here's the reg:

(ii) Instrument flight training on cross country flight procedures, including one cross country flight in an airplane with an authorized instructor, that is performed underinstrument 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.

If we go by the first interpretation i.e. three unique approach types all of which use navigation systems, I would expect the reg to read as it does. But since you don't use an NDB to shoot an ILS and you don't use a localizer to shoot a VOR approach. I would therefore expect that if the second interpretation is correct i.e. shoot three different approaches which use three different types of navigation systems, the reg would read something more like '(C) Three approaches with the use of three different kinds of navigation systems.'

In general, the FAA does not phrase regs arbitrarily. They choose to phrase the regs in specific ways for a reason.
 
They can't get that detailed, because if they did then you may just have approaches that wouldn't count. Think of the LOC with ADF required, or LOC/DME, on the VOR side VOR-A vs VOR-DME.
So then could you not do a NDB and a LOC with ADF required, of course not? A LOC-DME might fly similiar to a VOR/DME, but they are different navigation systems.
 
Yea let's be real, the FAA doesn't care what type of approaches you do. They just want you to do 3 different ones so that you get exposure to the most commonly used types at places other than where you practice. If the flight school that the O.P. is attending says it isn't valid then they should be on the hook for the extra training or have someone from the FAA write a letter of clarification.
 
dtuuri said:
An em dash might be all they needed. Consider the two different meanings, depending on the em dash:

"Three different kinds of--approaches with the use of navigation systems."

"Three different kinds of approaches--with the use of navigation systems."​

Of course, I'm not an English scholar so this is probably wrong. :rolleyes:
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English says that the first one is the proper interpretation. if the second one is intended, a comma should appear where you have the dashes.
However with either interpretation, it doesn't mean "Three different kinds of approaches, each using a different navigation system."
 
jaymark6655 said:
I read it as examiner told him they didn't count, not the school.
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A 141 school typically has their own examining authority, however it matters NOT. It's still the school's approved syllabus that dictates the exam requirement, not the stuff in 61.65.
 
If an ILS approach and a LOC approach are not different kinds of approaches, wouldn't that mean that the required instrument cross-country could not be done in a plane that has only a Nav/Com radio, i.e., no GPS? With a Nav/Com radio, a pilot can do VOR, ILS and LOC approaches, but nothing else, right?

During a checkride, the Instrument ACS requires pilots to fly two nonprecision approaches that "use at least two different types of navigational aids" -- so the FAA knows how to say different types of navigational aids when it wants to. In a Nav/Com-only (no-GPS) plane, the pilot can satisfy the "different navigational aids" requirement by flying a VOR and LOC approach. The ACS also requires a precision approach, and in a Nav/Com-only plane, that can be done by flying an ILS approach.

Why would things be different for a long cross-country? In other words, why would a plane that's good for a checkride be inadequate for a cross-country? I am confident that the DPE or school got it wrong when it said that the cross-country flown by Luv2Fly didn't qualify.
 
Lon33 said:
If an ILS approach and a LOC approach are not different kinds of approaches, wouldn't that mean that the required instrument cross-country could not be done in a plane that has only a Nav/Com radio, i.e., no GPS? With a Nav/Com radio, a pilot can do VOR, ILS and LOC approaches, but nothing else, right?

During a checkride, the Instrument ACS requires pilots to fly two nonprecision approaches that "use at least two different types of navigational aids" -- so the FAA knows how to say different types of navigational aids when it wants to. In a Nav/Com-only (no-GPS) plane, the pilot can satisfy the "different navigational aids" requirement by flying a VOR and LOC approach. The ACS also requires a precision approach, and in a Nav/Com-only plane, that can be done by flying an ILS approach.

Why would things be different for a long cross-country? In other words, why would a plane that's good for a checkride be inadequate for a cross-country? I am confident that the DPE or school got it wrong when it said that the cross-country flown by Luv2Fly didn't qualify.
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I think you make an excellent point. The ACS is brand new and has the benefit of hindsight with respect to clarifying language. The regulation is from a generation older. People today might not appreciate requirements in the same way as those who wrote the rule in the first place. In 1976, a checkride required a VOR, ADF and ILS approach, exactly the same as the cross country requirement then. I can see the FAA rewriting requirements to keep pace with technology. In this case, the ACS appears to have beaten the updating of the regulation.
 
What a mess. The Glaser letter was about PAR use and now is being interpreted to answer another separate question. It appears the FAA never updated AC 61-65 with an answer to this question as they promised. I think the DPE in this case has used the Glaser PAR interpretation to misinterpret the intent of CFR 61.65.

My vote is the LOC / ILS are two different kinds of approaches. The LOC is basically an accurate VOR approach but a similar step down profile to MDA as a VOR approach. $.02
 
You can fly a localizer approach without a glideslope receiver, but you can't fly an ILS without one. If they were the same kind of approach, wouldn't the equipment requirements be identical?
 
And the chart wouldn't be labelled differently if a ILS/LOC were actually the same.. You can have LOC without a ILS... We could probably dig up a case where you can have a ILS without a LOC... But I'm not willing to do that right now.
 
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It's actually "ILS or LOC" on the plates when you have both precision and non-precision minimums.
While you can't have an ILS without a localizer, there are ILS approaches that have no localizer only minimums designated.
 
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flyingron said:
It's actually "ILS or LOC" on the plates when you have both precision and non-precision minimums.
While you can' have an ILS without a localizer, there are ILS approaches that have no localizer only minimums designated.
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I assume you meant "can't".
 
ja_user said:
...We could probably dig up a case where you can have a ILS without a LOC... But I'm not willing to do that right now.
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I think that would be a very looooooong search! ;)
 
Palmpilot said:
I think that would be a very looooooong search! ;)
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Don't discount the FAA's ability to screw up a chart :)

Obviously I meant a published ILS where LOC without GS was not approved, so no way to shoot it as LOC only.
 
dtuuri said:
Wouldn't that just find you the localizer? Then, after a nice leisurely scenic route around a procedure turn, you came back toward the airport and fished for the glide slope. Ah, the good ol' days: no pesky radar vectors and all that talkin', just quietly follow your own recipe. :)
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Nope, the old compass locator with the published altitude gave you all you needed. https://aeronav.faa.gov/d-tpp/1812/00107IL6L.PDF
 
Lon33 said:
If an ILS approach and a LOC approach are not different kinds of approaches, wouldn't that mean that the required instrument cross-country could not be done in a plane that has only a Nav/Com radio, i.e., no GPS? With a Nav/Com radio, a pilot can do VOR, ILS and LOC approaches, but nothing else, right?

During a checkride, the Instrument ACS requires pilots to fly two nonprecision approaches that "use at least two different types of navigational aids" -- so the FAA knows how to say different types of navigational aids when it wants to. In a Nav/Com-only (no-GPS) plane, the pilot can satisfy the "different navigational aids" requirement by flying a VOR and LOC approach. The ACS also requires a precision approach, and in a Nav/Com-only plane, that can be done by flying an ILS approach.

Why would things be different for a long cross-country? In other words, why would a plane that's good for a checkride be inadequate for a cross-country? I am confident that the DPE or school got it wrong when it said that the cross-country flown by Luv2Fly didn't qualify.
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Honestly an interpretation by the FAA that a student could not log an ILS, a VOR and an LOC and could log an ILS, VOR and SDF is nonsense when you understand an SDF is just a localizer based approach with less precision.
 
ja_user said:
Don't discount the FAA's ability to screw up a chart :)

Obviously I meant a published ILS where LOC without GS was not approved, so no way to shoot it as LOC only.
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Sometimes I read things too literally. :redface:
 
Palmpilot said:
I think that would be a very looooooong search! ;)
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All the CAT II and III ones do not have loc minimums. I'm sure there are others. There are a few SA cat I's that are that way for sure.

Only took a few minutes of head scratching to think some of the mountain fields might not have a non-precision ILS. Only took the third airport I tried. ILS RWY 26 into RIL (Rifle, CO).
 
Clip4 said:
Nope, the old compass locator with the published altitude gave you all you needed. https://aeronav.faa.gov/d-tpp/1812/00107IL6L.PDF
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Boy does that approach rekindle a memory. I was real glad to see those lights one snowy night when just about every other runway in the state was below minimums, at least that's how I remember it. That's a great ILS approach.

You have a point. When you can fly at the marker crossing altitude from any direction, you can roll your own NDB/GS approach, like in an emergency.
 
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flyingron said:
A 141 school typically has their own examining authority, however it matters NOT. It's still the school's approved syllabus that dictates the exam requirement, not the stuff in 61.65.
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Except 141 Appendix C says:

c) Each approved course must include the following flight training—

(1) For an instrument airplane course: Instrument training time from a certificated flight instructor with an instrument rating on the approved areas of operation in paragraph (d) of this section including at least one cross-country flight that—

(i) Is in the category and class of airplane that the course is approved for, and is performed under IFR;

(ii) Is a distance of at least 250 nautical miles along airways or ATC-directed routing with one segment of the flight consisting of at least a straight-line distance of 100 nautical miles between airports;

(iii) Involves an instrument approach at each airport; and

(iv) Involves three different kinds of approaches with the use of navigation systems.
 
Clip4 said:
Except 141 Appendix C says:

c) Each approved course must include the following flight training—

(1) For an instrument airplane course: Instrument training time from a certificated flight instructor with an instrument rating on the approved areas of operation in paragraph (d) of this section including at least one cross-country flight that—

(i) Is in the category and class of airplane that the course is approved for, and is performed under IFR;

(ii) Is a distance of at least 250 nautical miles along airways or ATC-directed routing with one segment of the flight consisting of at least a straight-line distance of 100 nautical miles between airports;

(iii) Involves an instrument approach at each airport; and

(iv) Involves three different kinds of approaches with the use of navigation systems.
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And the 141 syllabus may be more detailed/descriptive in what types of approaches are required, so while it’s based on the 141 reg, it’s still controlling.
 
flyingron said:
All the CAT II and III ones do not have loc minimums. I'm sure there are others. There are a few SA cat I's that are that way for sure.

Only took a few minutes of head scratching to think some of the mountain fields might not have a non-precision ILS. Only took the third airport I tried. ILS RWY 26 into RIL (Rifle, CO).
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I misinterpreted his remark as meaning the absence of a physical localizer, not the absence of a published localizer approach or localizer minimums.
 
Palmpilot said:
I misinterpreted his remark as meaning the absence of a physical localizer, not the absence of a published localizer approach or localizer minimums.
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I could have been more clear.
 
I call BS on them. Look at the reality of approaches these days. VOR approach, they are out there. But not as common as they used to be. NDB approach, good luck finding one. So it really leaves ILS Precision approach, LOC non precision. GPS most common is LNAV. GPS LPV Non precision, but precision enough. So that is 4 different types of approaches, based on two different navigation systems.

If the school says the flight didn't meet requirements, then that is their fault, and the fault of the CFII that was on the flight with you, and signed off your logbook stating the requirements for the checkride have been met.
 
TommyG said:
I call BS on them. Look at the reality of approaches these days. VOR approach, they are out there. But not as common as they used to be. NDB approach, good luck finding one. So it really leaves ILS Precision approach, LOC non precision. GPS most common is LNAV. GPS LPV Non precision, but precision enough. So that is 4 different types of approaches, based on two different navigation systems.

If the school says the flight didn't meet requirements, then that is their fault, and the fault of the CFII that was on the flight with you, and signed off your logbook stating the requirements for the checkride have been met.
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Really it is basically vertical nav and non vertical nav. That said shooting a NDB and holding on a NDB raw data with no moving map or GPS is a VERY good skill at situational awareness, if you can’t do it in your plane worthwhile to do it in the sim.
 
dtuuri said:
An em dash might be all they needed. Consider the two different meanings, depending on the em dash:

"Three different kinds of--approaches with the use of navigation systems."

"Three different kinds of approaches--with the use of navigation systems."​

Of course, I'm not an English scholar so this is probably wrong. :rolleyes:
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You coulda used a real —.
 
dtuuri said:
Boy does that approach rekindle a memory. I was real glad to see those lights one snowy night when just about every other runway in the state was below minimums, at least that's how I remember it. That's a great ILS approach.

You have a point. When you can fly at the marker crossing altitude from any direction, you can roll your own NDB/GS approach, like in an emergency.
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Afraid this approach has its days numbered before they pull the NDB, but having a compass locator dialed up on departure was a lot simple than punching a bunch of buttons if you need an emergency return.
 
If they require approached based on three different navaids, then because you did not use a VOR (except for the arc), then you only used two, LOC/ILS and GPS.
 
Thank you. That will double the arrows in my ASCII quiver, Alt+0176 being the other 50°.
 
IK04 said:
If they require approached based on three different navaids, then because you did not use a VOR (except for the arc), then you only used two, LOC/ILS and GPS.
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The use of approaches based on three different naviads isn't what's required. Whats required is that you do three different types of approaches which each use navigation systems.
 
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