IFR three approach interpretation

luv2pilot

luv2pilot

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luv2pilot
So here is the issue, I show up for my 141 School end of course check ride today for my IR and was told I would only be able to complete the Oral part of the test because my long x-country did not meet the qualifications of requirement.

So we depart IFR flight plan with the miles requirement met no issue. Here are the approaches:

Depart KCMA- ILS 25 into KVIS full procedure with ARC
Depart KVIS WEESL1 arrival for LOC8 @ KBUR
Depart KBUR via the SID and shoot RNAV Y 26 at KCMA

It was explained to me that this was not acceptable via the FAR's

There's an FAA letter of interpretation1

[A] pilot may choose any three of the following navigation systems:

  • Non-directional beacon (NDB)
  • Localizer-type directional aid (LDA)
  • Very high frequency omni-range station (VOR)
  • Global Positioning System (GPS)
  • Simplified Direction Facility (SDF)
  • Instrument landing system localizer (LOC)
So I guess I am just super confused as to why this would be, what would you do without a GPS? Its a 1,500 hundred dollar mistake if so and should that really fall on me being a IFR student? Thoughts please.
 
I'm skeptical. What is the letter of interpretation? The FAR merely requires three different types of approaches. Nothing comes to mind why an ILS, LOC and a VOR wouldn't be ok. That's what I did during my training. Accordingly, an ILS, LOC, and a GPS seems fine to me.
 
Right FAR 61.65 only says three different approaches which I completed! Very frustrating to say the least!
 
I haven't started instrument training yet but, I would fight this one. Do have to pay an additional fee to continue later? What do you do at this point, go to the FSDO?
 
There should be any "interpretation" needed. If this is a 141 program, the requirements should be explicitly spelled out in the approved syllabus.
If the syllabus reads as above, then that's what you have to do. However, the above specify navigation systems, NOT approach types. The part 61 just says different approach types using navigation systems. Notice where the word DIFFERENT appears.
 
Looks like a serious communication problem between you and the school.
 
don't think that is the case but we will find out I'm looking into the syllabus but it's grey area I guess. Some have had issues and others not with the exact same thing as far as I can tell but needs to be clearly stated and school needs to clearly understand before they send you out on cross country knowing that this could possibly be an issue or not.... Needs to be this is what gets you through do that! DONE!
 
I’m confused. What exactly did they say is unacceptable?
 
luv2pilot said:
Right FAR 61.65 only says three different approaches which I completed! Very frustrating to say the least!
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Especially when the Part 141 instructor you were paying obviously didn’t know this either. If you paid for this training with a credit card, complete all your training and dispute the charge for the wasted XC. You paid for training meeting the requirements of the regulation and did not receive it.
 
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What does the part 141 approved course state?

So let me get this right.. They said it didn't count because of your ILS? Because an ILS is to close to the LOC? But a LDA or SDF and a LOC would have been fine?
 
The punt to FSSO seemed pretty clear to me...

Read the whole thing, mainly the 2nd paragraph. The original question was around ASR/PAR, which was found to be not Navigation based for the requirements of an IFR XC. The list of acceptable approaches was not mean to be all inclusive. Although I don't know how the hell they missed ILS with all that other crap.
 
ja_user said:
The punt to FSSO seemed pretty clear to me...

Read the whole thing, mainly the 2nd paragraph. The original question was around ASR/PAR, which was found to be not Navigation based for the requirements of an IFR XC. The list of acceptable approaches was not mean to be all inclusive. Although I don't know how the hell they missed ILS with all that other crap.
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Agreed. The legal interpretation is that ASR/PAR is not a "navigation system" not that an ILS doesn't count.

Sounds like either a 141 syllabus issue or a confusion between the 3 different "kinds of approaches" requirement for the cross country and the 3 different "systems" requirement for the checkride itself.
 
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What did they say was unacceptable, the ILS? The only argument I could see is that the ILS and LOC are very similar and could have substituted in a VOR approach instead. If you violated anything it could only be the 141 syllabus as what you did fits the requirement of the FAA.
 
ja_user said:
Although I don't know how the hell they missed ILS with all that other crap.
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An ILS uses a localizer for navigational course guidance. LOC is on the list.

EDIT: The school seems to be saying the LOC and ILS are therefore redundant, you needed to do a third type of course guidance.
 
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I'd call the FSDO and get their input. If they agree that you have not met the requirements, speak with upper management at the school about the mistake they made and how exactly they intend to make it right with you and your checkbook.
 
luv2pilot said:
So here is the issue, I show up for my 141 School end of course check ride today for my IR and was told I would only be able to complete the Oral part of the test because my long x-country did not meet the qualifications of requirement.

So we depart IFR flight plan with the miles requirement met no issue. Here are the approaches:

Depart KCMA- ILS 25 into KVIS full procedure with ARC
Depart KVIS WEESL1 arrival for LOC8 @ KBUR
Depart KBUR via the SID and shoot RNAV Y 26 at KCMA

It was explained to me that this was not acceptable via the FAR's

There's an FAA letter of interpretation1

[A] pilot may choose any three of the following navigation systems:

  • Non-directional beacon (NDB)
  • Localizer-type directional aid (LDA)
  • Very high frequency omni-range station (VOR)
  • Global Positioning System (GPS)
  • Simplified Direction Facility (SDF)
  • Instrument landing system localizer (LOC)
So I guess I am just super confused as to why this would be, what would you do without a GPS? Its a 1,500 hundred dollar mistake if so and should that really fall on me being a IFR student? Thoughts please.
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You only used 2 of the navigation systems. GPS into CMA, localizer into VIS and BUR. You shoulda done a VOR Approach at one of them. Yeah, it could be hard to find three in some parts of the country if you didn’t have GPS. Not a lot of NDB’s left, I think there is just one SDF left in the US. LDA being listed as a different ‘navigation system’ isn’t making sense to me. LDA is a kind of Approach that uses an “Instrument landing system localizer (LOC).” After doing the ILS or LOC Rwy 8 to BUR you could have done the LDA-C to VNY and have used the same ‘navigation system.’ I don’t think the FAA’s letter of interpretation was saying exactly what it was meaning to say.
 
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ILS approaches are certainly not the same as a LOC. Just because the lateral navigation comes from the same type of source, doesn't mean they aren't a different type.
 
The "clarification" doesn't address the question. It only rules that PAR/ASR isn't a navigation system (which defies logic as well, but we're not going there). It doesn't change the fact that the regulation doesn't say "three different navigation systems". It says three different approaches using navigation systems. Someday, the FAA bastards will learn English and use it to write and interpret the regulations rather than making up bullpoop on the fly.
 
ja_user said:
ILS approaches are certainly not the same as a LOC. Just because the lateral navigation comes from the same type of source, doesn't mean they aren't a different type.
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You don't "navigate" via a glide slope.
 
flyingron said:
It doesn't change the fact that the regulation doesn't say "three different navigation systems". It says three different approaches using navigation systems.
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I don't see that. Quoting from the Glaser Letter, "...as it pertains to different kinds of approaches, i.e. three different kinds of navigation systems..."

So, they mean the same.

So reads the rule itself, "Three different kinds of approaches with the use of navigation systems...", i.e., "approaches with the use of navigation systems" as opposed to, say, "ASR".
 
dtuuri said:
You don't "navigate" via a glide slope.
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You certainly do navigate and the glideslope it part of the approach, and it is different than a lot of Localizers with multiple steps downs. It is a different approach.

The letter is about the ASR/PAR not requiring navigation.
 
Wouldn't you consider a Back-Course approach different as well, even though they didn't specify it in the letter? That list was not meant to be all inclusive, and this was clarified in the 2nd letter.
 
ja_user said:
Wouldn't you consider a Back-Course approach different as well, even though they didn't specify it in the letter? That list was not meant to be all inclusive, and this was clarified in the 2nd letter.
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No, the Back Course is still using localizer guidance for navigation. The rule is requiring different "course guidance", or as they put it in the rule, "Three different kinds of approaches with the use of navigation systems."

The LDA is specifically considered as a different system (think DCA), as is an SDF, and maybe the BC ought to be added to the list (I'd be in favor of it), but it isn't much different than a localizer to anybody with an HSI. We know all applicant airplanes have HSIs, right? That must be what the FAA was thinking. :)
 
Maybe it's the foreigner in me, but "Three different kinds of approaches with the use of navigation systems" reads to me any 3 different approaches(as in cannot do 2 ILS) that use any navigation system. If they wanted to specify 3 different navigation systems, it should state something like "Three different kinds of approaches each using a different navigation system."
 
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genna said:
Maybe it's the foreigner in me, but "Three different kinds of approaches with the use of navigation systems" reads to me any 3 different approaches(as in cannot do 2 ILS) that use any navigation system. If they wanted to specify 3 different navigation systems, it should state something like "Three different kinds of approaches each using different navigation system."
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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.
 
genna said:
Maybe it's the foreigner in me, but "Three different kinds of approaches with the use of navigation systems" reads to me any 3 different approaches(as in cannot do 2 ILS) that use any navigation system. If they wanted to specify 3 different navigation systems, it should state something like "Three different kinds of approaches each using different navigation system."
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How about, "...including VOR, ADF, and ILS approaches at different airports." That's how the rule read in 1980.
 
Am I confused on this? I thought doing a LOC (non-precision), ILS (precision) and RNAV is three different approaches, even if you fly them all to the same runway, using the correct rules for each.

Are we saying that IF the ILS is sending vertical guidance but we're only flying the LOC we are "cheating"?
 
Ravioli said:
Am I confused on this? I thought doing a LOC (non-precision), ILS (precision) and RNAV is three different approaches, even if you fly them all to the same runway, using the correct rules for each.
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That is how most pilots interpret it, the lawyers at the FAA decided that it meant that it had to be 3 approaches using different navigation systems. Since the ILS and LOC both use the same system the lawyers think they are the same kind of approach.
 
I see no evidence that doing a LOC, ILS and an RNAV approach during your cross country would not satisfy the FAA's experience requirement.
 
Wheels said:
That is how most pilots interpret it, the lawyers at the FAA decided that it meant that it had to be 3 approaches using different navigation systems. Since the ILS and LOC both use the same system the lawyers think they are the same kind of approach.
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Wild. Since If I do the VOR-A approach I'm using the exact same NAV radio and CDI I would on the ILS/LOC.
 
It is very common that an interpretation comes out, and then another come out to clarify it. The 2nd one clarifies that the initial interpretation did note contain an all inclusive list, and was limited in scope to the question anyway. The initial question was ASR/PAR related....
 
Ravioli said:
Are we saying that IF the ILS is sending vertical guidance but we're only flying the LOC we are "cheating"?
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In an historical context, before RNAV/GPS, they wanted VOR, ADF and ILS approaches at three different airports. Then they rewrote the rule to include other navigation forms and specified them by name in the Glaser Letter as the state of the art existed at the time. The common denominator is lateral course guidance, historically and at the time of Glaser. Would the FAA, today, allow a LOC and ILS to count as two of the three? Not in my view of how they're thinking. They haven't seemed, in the past, to want localizer specialists or VOR specialists or ADF specialists, they want some minimum breadth of experience and that is at least three types. But, hey, write the Chief Counsel, YMMV.
 
dtuuri said:
In an historical context, before RNAV/GPS, they wanted VOR, ADF and ILS approaches at three different airports. Then they rewrote the rule to include other navigation forms and specified them by name in the Glaser Letter as the state of the art existed at the time. The common denominator is lateral course guidance, historically and at the time of Glaser. Would the FAA, today, allow a LOC and ILS to count as two of the three? Not in my view of how they're thinking. They haven't seemed, in the past, to want localizer specialists or VOR specialists or ADF specialists, they want some minimum breadth of experience and that is at least three types. But, hey, write the Chief Counsel, YMMV.
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Maybe, but they shouldn't hold to something they are thinking but isn't writting unless mindreading is now a requirment.
 
Ether way it’s not your problem, their DPE and their CFI all working for their company, ether you are good to go and take your test, or the school gives you another cross country on their dime.
 
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