These Three Approaches

Editorial Staff

Monday, January 23, 2023 at 03:23 PM ET

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Key Takeaways:

The FAA Chief Counsel rescinded previous restrictive interpretations of instrument rating cross-country requirements, which had demanded "three different kinds of approaches" based on distinct *navigation systems*.
Flight Standards has now clarified that "different kinds of approaches" for the instrument rating prerequisite are defined by the *type of approach minimums*, such as an ILS versus a LOC, or an RNAV LPV Decision Altitude (DA) versus an RNAV LNAV Minimum Descent Altitude (MDA).
This updated guidance provides a simpler, clearer, and more modern interpretation for pilots, aligning with current avionics and navigation systems while maintaining the 250 NM (or 100 NM for helicopters) cross-country distance requirement.

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In “Which Three Approaches?” (September 2022 IFR) we discussed the FAA Chief Counsel’s abandonment of earlier restrictive interpretations of the dual cross-country prerequisite for the instrument rating. The flight, described in §61.65(d)(2)(ii) of the FAA regulations must include “three different kinds of approaches with the use of navigation systems.”

The 2008 Glaser and the 2012 Pratt letters interpreted this as a requirement to use approaches with “three different kinds of navigation systems.” The FAA is moving relentlessly from a system of ground-based navaids to one using RNAV/GPS as the primary means of navigation. VOR and NDB approaches are disappearing through the Minimum Operational Network removal of VOR and the related decertification of redundant and little-used ground-based approaches. This led to problems.