With the new ACS rules, is GPS alone sufficient for IR?

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MountainDude

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With the new rules, can someone get IR with only a simple GPS, like GPS 175, and 2 G5s? No VORs/ILS receivers.
I am not asking if this is a good idea or not. I am just asking if it's legally possible.
Thank you
 
MountainDude said:
With the new rules, can someone get IR with only a simple GPS, like GPS 175, and 2 G5s? No VORs/ILS receivers.
I am not asking if this is a good idea or not. I am just asking if it's legally possible.
Thank you.
Click to expand...
New rules?
 
darthanubis said:
New rules?
Click to expand...
www.pilotsofamerica.com

New ACS May 24

Amendments to the FAR making the ACS regulatory go into effect May 24 along with new ACS. I have not reviewed all the changes. Most are expected to be minor, but the new Instrument ACS has the big one many have discussed - the removal of the requirement to use at least one land-based...
www.pilotsofamerica.com www.pilotsofamerica.com
 
Florida Flyer said:
May depend on available approaches and dpe
Click to expand...
In this day and age, approach availability with an IFR GPS to meet ACS requirements seems more likely than without with the decommissioning of VORs and NDBs. So can a DPE leaglly say no if the aircraft is suitably equipped to meet ACS criteria?
 
tsts4 said:
So can a DPE leaglly say no if the aircraft is suitably equipped to meet ACS criteria?
Click to expand...
A DPE can choose not to give the checkride in an aircraft that’s not configured to his standards, but if he gives the checkride, he (just like the applicant) is bound by the ACS.
 
tsts4 said:
In this day and age, approach availability with an IFR GPS to meet ACS requirements seems more likely than without with the decommissioning of VORs and NDBs. So can a DPE leaglly say no if the aircraft is suitably equipped to meet ACS criteria?
Click to expand...
Well I guess a DPE can always refuse to take your money, although I can’t imagine why in this case.
 
In Feb 2022 the FAA put out a memo rescinding the Glaser interpretation (2008) and Pratte interpretation (2012). Previous to this, DPEs would frequently not allow ILS and LOC approaches (as an example) on the long IFR cross country <61.65(d)(2)(ii)(C)> to count as different types of approaches since the used the same navigation systems. Obviously now that is not the case. However, I've heard some DPEs are not applying this same logic to RNAV approaches. In other words, not seeing LNAV and LPV approaches (as an example) as different kinds of approaches. If there are examiners still applying this logic, a GPS only equipped aircraft may not work for all the 61.65 requirements. So I would definitely check with the DPE.

Has anyone else run into this situation with DPEs or know of any further guidance from the FAA?
 
Low Level Flyer said:
In Feb 2022 the FAA put out a memo rescinding the Glaser interpretation (2008) and Pratte interpretation (2012). Previous to this, DPEs would frequently not allow ILS and LOC approaches (as an example) on the long IFR cross country <61.65(d)(2)(ii)(C)> to count as different types of approaches since the used the same navigation systems. Obviously now that is not the case. However, I've heard some DPEs are not applying this same logic to RNAV approaches. In other words, not seeing LNAV and LPV approaches (as an example) as different kinds of approaches. If there are examiners still applying this logic, a GPS only equipped aircraft may not work for all the 61.65 requirements. So I would definitely check with the DPE.

Has anyone else run into this situation with DPEs or know of any further guidance from the FAA?
Click to expand...
Just to be sure we're talking apples and apples the 61.65 cross country has different wording than the ACS, and both the purposes and standards can be different.

For the 61.65 required cross country (which you are asking about), the FAA is very clear that

To fulfill the regulatory requirements, an applicant only needs to conduct three different kinds of approaches regardless of the navigation system utilized. Different approaches can be defined by the various lines of minima found on an approach plate. For example, localizer (LOC) minima are one kind of approach operation and instrument landing system (ILS) minima are another kind of approach operation. The same could be true of Area Navigation (RNAV) GPS-titled approach plates, a localizer performance with vertical guidance (LPV) approach is one kind of approach operation and a Localizer Performance (LP) to a circling MDA is another kind of approach operation.”​
FAA Order 8900.1, ¶5-434​

See my "These Three Approaches" article in IFR Magazine (no paywall on this one) discussing the changes.

I have not heard of a DPE not following this official guidance, If they aren't I'd suggest they check with their boss.
 
Last edited:
During the period before the ACS is required on 5/31/2024, the FAA has put out guidance that in essence allows the pilot to be tested to either 8B or 8C version of the IFR ACS.
 

Attachments

  • N_8900.691_FAA FAA guidance during the period 4-1 to 5-31 which ACS can be used.pdf
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@midlifeflyer Your explanation has always been my understanding. But I do know of a couple local DPEs that didn’t see it that way. Using those examiners, we’d have to make sure we did 3 different appproaches with differing nav sources. Example VOR ILS RNAV.
 
Low Level Flyer said:
@midlifeflyer Your explanation has always been my understanding. But I do know of a couple local DPEs that didn’t see it that way. Using those examiners, we’d have to make sure we did 3 different appproaches with differing nav sources. Example VOR ILS RNAV.
Click to expand...
That was the ACS rule before the new one and the 61.65 rule before the updated guidance.
 
They are dumbing it down yet again??

“Just push the correct button on the GPS, and you are IR”..??

Back in the day one actually had to have the skill to do complex things (NDB intersection holding for example)..
 
Kritchlow said:
They are dumbing it down yet again??

“Just push the correct button on the GPS, and you are IR”..??

Back in the day one actually had to have the skill to do complex things (NDB intersection holding for example)..
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Yeah, why would anyone use Google maps with live traffic for navigation on a large screen. I can go to a gas station, buy a paper map, then discuss good routes with the clerk. Once I exit that map, I can repeat the process.
 
Kritchlow said:
They are dumbing it down yet again??

“Just push the correct button on the GPS, and you are IR”..??

Back in the day one actually had to have the skill to do complex things (NDB intersection holding for example)..
Click to expand...
No, just accommodating the reality of navigation at the end of the 1st quarter of the 21st Century. And it’s not as simple as you apparently think. I still see pilots making mistakes since the equipment is far more complex than that NDB.
 
Kritchlow said:
They are dumbing it down yet again??

“Just push the correct button on the GPS, and you are IR”..??

Back in the day one actually had to have the skill to do complex things (NDB intersection holding for example)..
Click to expand...
And they had to do approaches with a 4 course radio range.

Times change. Technology changes.
 
Pinecone said:
And they had to do approaches with a 4 course radio range.

Times change. Technology changes.
Click to expand...
And this is the first credible response I’ve seen.

Yes, I did adf intersection holds on my ir ride in 1986.
Some elders could have said “well you didn’t need to do four course”.

Fair enough.
That said, both are complicated as compared to todays
“Push the button”.
 
True it was harder back in the day. I for one am glad it’s easier now. My ego isn’t tied to my ability to fly an NDB approach or with a single VOR, for example, and I feel no shame whatsoever in maximizing the use of the latest technology as I believe it’s generally safer which is what I care about.
 
Kritchlow said:
And this is the first credible response I’ve seen.

Yes, I did adf intersection holds on my ir ride in 1986.
Some elders could have said “well you didn’t need to do four course”.

Fair enough.
That said, both are complicated as compared to todays
“Push the button”.
Click to expand...
I guess you haven’t seen the errors I see when giving training. They of course show up in initial instrument training, but I’m talking recurrent training/IPCs. Setting up and adjusting an approach in a GPS box is far more complicated than it was with old school VOR and NDB. I even have a short list of “GPS Tasks Pilots Do Not Know How to Do” I draw from for recurrent training purposes. Just this past week…

When the boxes first appeared, the saying was, “easier to fly but more difficult to set up.” Even with, or maybe because of, the advances since then, it’s definitely true today.
 
Kritchlow said:
That said, both are complicated as compared to todays
“Push the button”.
Click to expand...

"Push the button" suggests someone who only knows how to use Direct-to. I find that many pilots don't have a workable understanding of how to do many things using a GPS navigator. Pilots who have only been trained to use conventional navigation systems will often struggle with:

1. What Activate an approach means
2. How to join an approach at IF that is not listed in the approach dialog
3. How to control a hold, more turns, no more turns in an approach
4. How to use OBS mode
5. How to activate a leg
6. How to enter a flight plan route
7. How to edit a flight plan route
8. How to fly a course to a fix
9. How to initiate the missed approach
10. How to fly an ILS using an integrated GPS/ILS/VOR navigator
11. How to fly an LPV
12. What is required to fly an LP
13. How to determine if an LPV to LNAV downgrade is likely
14. Meaning of the chart note "Visual Segment - Obstacles"
15. Meaning of +V annunciation
16. How to do a hold that is not in an approach procedure
17. Meaning of vectors to final when there is a course change at the FAF
18. Meaning of "Fly visual to airport"
Plus many many more things not in this list.
 
midlifeflyer said:
I guess you haven’t seen the errors I see when giving training. They of course show up in initial instrument training, but I’m talking recurrent training/IPCs. Setting up and adjusting an approach in a GPS box is far more complicated than it was with old school VOR and NDB. I even have a short list of “GPS Tasks Pilots Do Not Know How to Do” I draw from for recurrent training purposes. Just this past week…

When the boxes first appeared, the saying was, “easier to fly but more difficult to set up.” Even with, or maybe because of, the advances since then, it’s definitely true today.
Click to expand...

Couldn't agree more. Once properly set up and given no changes from ATC, IFR is easier with an IFR GPS. The amount of information provided really enhances situational awareness. Having said that, I also see a lot more mistakes when I give refresher training or IPCs with GPS than I did when giving the same training to those without GPS. With more options comes the potential for more mistakes.

I also have a list of "GPS tasks pilots don't know how to do" that I make trainees perform. It's very common to see people struggle with these tasks.

Between my full time flying and my part-time instructing, I am currently flying behind 5 different IFR GPS. Sometimes I need to pause to make sure what I'm about to do is correct. Previous to GPS, that wasn't the case. Jumping between different planes configured with VOR, DME and ADF, I didn't usually have to consider any significant differences.

Modern GPS simply increase the possibility of "garbage in, garbage out".
 
John Collins said:
"Push the button" suggests someone who only knows how to use Direct-to. I find that many pilots don't have a workable understanding of how to do many things using a GPS navigator. Pilots who have only been trained to use conventional navigation systems will often struggle with:

1. What Activate an approach means
2. How to join an approach at IF that is not listed in the approach dialog
3. How to control a hold, more turns, no more turns in an approach
4. How to use OBS mode
5. How to activate a leg
6. How to enter a flight plan route
7. How to edit a flight plan route
8. How to fly a course to a fix
9. How to initiate the missed approach
10. How to fly an ILS using an integrated GPS/ILS/VOR navigator
11. How to fly an LPV
12. What is required to fly an LP
13. How to determine if an LPV to LNAV downgrade is likely
14. Meaning of the chart note "Visual Segment - Obstacles"
15. Meaning of +V annunciation
16. How to do a hold that is not in an approach procedure
17. Meaning of vectors to final when there is a course change at the FAF
18. Meaning of "Fly visual to airport"
Plus many many more things not in this list.
Click to expand...
Pilots who have been trained in GPS also struggle with many of those, IMO largely because they haven’t actually been trained in “GPS”, they’ve been trained in “G1000” (or whatever the specific system is.)
 
Kritchlow said:
And this is the first credible response I’ve seen.

Yes, I did adf intersection holds on my ir ride in 1986.
Some elders could have said “well you didn’t need to do four course”.

Fair enough.
That said, both are complicated as compared to todays
“Push the button”.
Click to expand...
Yeah, but. Push the wrong button and it leads to having to push a whole lot more buttons to unf*** what pushing the wrong button ef’d up. There have been some accidents where there is no doubt in my mind that buttonology is what killed the pilot.
 
MauleSkinner said:
Pilots who have been trained in GPS also struggle with many of those, IMO largely because they haven’t actually been trained in “GPS”, they’ve been trained in “G1000” (or whatever the specific system is.)
Click to expand...
Most of those are not system-specific.
 
I will say that planning an IFR cross-country with a WAAS enabled GPS is easier than the pre-GPS days. No more worrying about service volumes, unusable radials, Navaid notams, getting to a distant navaid from your small, out of the way airport, etc. Not that GPS notams are always presented in a user-friendly way.
 
Ed Haywood said:
Seems like that would make a good YouTube video.
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I've done a few of them along the way. Some are one-off with no audio and not much other information I did in the PC or iPad trainer in response to a specific question. This is an example. So many think that to change the approach (a task which made my list because of a fatal accident) you need to remove the old one.

All you really need is a task and you can probably find a video from someone demonstrating it.

The problem with doing a video on the group, is that the way the tasks are done can be very system specific. I have three videos (link to playlist) that each do a single task using three (or four) different GPS systems. GNS, GTN, IFD, and sometimes G1000.
 
midlifeflyer said:
Most of those are not system-specific.
Click to expand...
I would agree, but I’ve tried teaching a lot of people a non-Garmin system, and unless you use Garmin words, it’s extremely difficult.

Just getting past the difference between a DA and an MDA so that they can use proper automation modes can take an astonishing amount of time.
 
MauleSkinner said:
I would agree, but I’ve tried teaching a lot of people a non-Garmin system, and unless you use Garmin words, it’s extremely difficult.

Just getting past the difference between a DA and an MDA so that they can use proper automation modes can take an astonishing amount of time.
Click to expand...
I meant the list of tasks is not system-specific. Neither is the difference between DA and MDA.

But sure, the methods used to do various tasks and some of the verbiage vary by system. Two which immediately come to me are, "green needles vs pink" needles means nothing to a pilot with an Aspen PFD. OBS mode operates differently in Avidyne and Garmin boxes (and from John's list, "course to fix" is not an Avidyne term although it does it).
 
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