What's new
Van's Air Force

Don't miss anything! Register now for full access to the definitive RV support community.

News from FAA on instrument ACS and IPC

BobTurner

Well Known Member
The FAA has just issued a memo concerning instrument flight tests and instrument proficiency checks. They have retracted previous language and interpretations requiring "2 different non-precision approaches using 2 different navigation systems". The new language drops the reference to navigation systems, it is now just "2 different non-precision approaches". This clarifies that GPS-only aircraft may be used for flight tests and IPCs.
 
I read that memo differently. It doesn't alter the phrase at all, it clarifies prior misinterpretations.

"...test an applicant on three different kinds of approaches, consisting of one precision approach and two non-precision approaches, which must use two different kinds of navigational aids."

Does a GPS-only aircraft use "two different kinds of navigational aids?" I actually don't know, but if so, yay!
 
Last edited:
I read that memo differently. It doesn't alter the phrase at all, it clarifies prior misinterpretations.

"...test an applicant on three different kinds of approaches, consisting of one precision approach and two non-precision approaches, which must use two different kinds of navigational aids."

Does a GPS-only aircraft use "two different kinds of navigational aids?" I actually don't know, but if so, yay!

Read it again, carefully. The above quote is from the ACS. The memo notes that this phrase is not consistent with the latest interpretation of the fars, which require multiple different approaches but do not require different nav aides.
 
Read it again, carefully. The above quote is from the ACS. The memo notes that this phrase is not consistent with the latest interpretation of the fars, which require multiple different approaches but do not require different nav aides.

Thanks Bob!

Next up: Basic Med for safety pilots?
 
**********
FAA Safety Team | Safer Skies Through Education
Changes to Instrument Rating Cross Country Approach Requirement
Notice Number: NOTC2305
The Federal Aviation Administration (FAA) recently reviewed two legal interpretation and determined they were overly restrictive. The Glaser (2008) and Pratte (2012) legal interpretations focused on the requirements of an instrument rating under § 61.65. Specifically, the requirement to use three different kinds of approaches with the use of navigation systems to meet the requirements of § 61.65(d)(2)(ii)(C). These interpretations inaccurately concluded that an applicant for an instrument rating must use three different kinds of navigation systems to meet these requirements.
On February 28, 2022, the FAA rescinded both the Glaser and Pratte legal interpretations, stating the regulation’s plain language requires three different types of approaches, not three different navigation systems. Certificated flight instructors (CFI) and designated pilot examiners (DPEs) should be aware that the requirements for an instrument rating may be met by performing three different approaches, regardless of the source of navigation.
*********
The above plain language interpretation is from the FAA. Note the last sentence.

Basic Med for safety pilots. Well, the FAA administrator has promised this. We’ll see. Since this makes perfect sense I have my doubts! -:)
 
As I read it, yes this allows a single navigation system, but your instrument rating still requires 2 Non Precision and one Precision approach. It further clarifies that a PAR is considered a precision approach.

So you could get away with a GPS only device, if you had access to use and demonstrate a PAR approach. I do not believe there are any other precision approaches currently that do not rely on radio navigation.

I believe there is a draft AC circulating 90-119 that would allow for LPV to be changed from non-precision to a precision approach.

Just my .02
 
Wonderful. So now we can "officially" have all our eggs in one basket with regard to IFR approaches. That's not a positive step, in my opinion.

I know, I know, to each their own and all that... just call me old-fashioned and I'll be happy to keep my VOR/ILS capability. GPS can and does fail, sometimes even intentionally.
 
The FAA has just issued a memo concerning instrument flight tests and instrument proficiency checks. They have retracted previous language and interpretations requiring "2 different non-precision approaches using 2 different navigation systems". The new language drops the reference to navigation systems, it is now just "2 different non-precision approaches". This clarifies that GPS-only aircraft may be used for flight tests and IPCs.

Does that mean that they now accept an LPV as a precision approach? I always thought there position was it was not. Also, how do you get two different non-precision approaches via GPS.

Larry
 
Last edited:
Strange, I have a different interpretation than the posters above me.

To me, this is only applicable to the Section 61 .65(d)(2)(ii)(C) requirements, which is the cross country flight with 3 different approaches.

This doesn't change the practical test or what is considered precision/non-precision.
 
Totally confused

What is ACS?

What’s the original verbiage?

What’s the new verbiage?

How is an LPV not a precision approach? It has the same decision altitude as an ILS approach. ILS equipment at airports are out of service quite often. And when they are out of service they are out for weeks or months. I have yet to see or hear of gps satellites be out of service
 
LPV: technically an LPV does not quite meet the ‘precision approach’ standards. However, the current ACS already says that an LPV to minimums of 300’ or lower can be used in lieu of an ILS.

Different non precision approaches but all using gps: my interpretation is that the faa is preparing to allow LPV to 400’ min, LNAV to straight in min, LNAV to circle to land, as different kinds of approaches.

New verbage: not out yet. This memo directs some faa division to fix the ACS.

GPS perfect? I have experienced first a downgrade (LPV to LNAV), then a complete loss (big red X over the GTN) while doing a gps approach, so it can happen. Don’t get too complacent.
 
Last edited:
LPV

Currently LPV’s are 300’ minimums. Do you mean the FAA is going to increase it to 400’ minimums and are going to allow LPV’s to be equivalent to ILS? Isn’t ILS equipment for airports expensive to maintain and many airports are no longer fixing them since the airports have GPS approaches?

Is all this to get your IFR rating or does this also apply for your IFR currency?
 
Currently LPV’s are 300’ minimums. Do you mean the FAA is going to increase it to 400’ minimums and are going to allow LPV’s to be equivalent to ILS? Isn’t ILS equipment for airports expensive to maintain and many airports are no longer fixing them since the airports have GPS approaches?

Is all this to get your IFR rating or does this also apply for your IFR currency?

There are now many LPV approaches to DA(H) of 200’, ‘just like’ a cat 1 ILS. But technically they are just out of some tolerance requirement to be called ‘precision’ approaches, but the existing ACS explicitly allows their use, when DH is 300’ or lower, to demonstrate the precision approach requirement even though they are not precision approaches!

LPV’s to higher than 300’ DH have always been on the ACS list of approaches that can be used to meet the non-precision requirement. The limitation was in the phrase ‘using different nav aides’, which, apparently, no longer has any legal basis so this will be removed.

This has little to do with IFR currency. The ‘6 approaches in 6 months’ rule never specified different approach types.

BTW, sorry for the achronyms. ACS is ‘airmen certification standards’, the successor to the PTS, ‘Practical Test standards’.
 
What is the requirement for IFR alternates in low weather? IIRC there used to be a bit about needing VHF equipment at either the primary or alternate in low weather - did that get changed?
 
LPV

The precision approach issue is an ICAO issue. Essentially most LPV approaches are to the same DH/DA as an ILS. The difference is that most LPV approaches require 3/4 mile visibility vs 1/2 for most ILS. This is really only a factor for Part 135 where the operator cannot start the approach unless the visibility is above minimums.
Also many LPV approaches have only runway lights. Full approach lights, touchdown and centerline lights allow approaches as low as 1800 RVR for Cat I ILS.
 
What is the requirement for IFR alternates in low weather? IIRC there used to be a bit about needing VHF equipment at either the primary or alternate in low weather - did that get changed?

This requirement still exists, but only for GPS's that are TSO'd under TSO 129 (non-WASS). WAAS-enabled GPS units which are TSO'd under 145/146 (WAAS TSO) are approved for sole-source navigation, with no requirements for non-gps backup.

BTW, I'm with you. I like having a non-gps method of navigation just in case, and, as I mentioned, I have seen a TSO'd GTN fail while doing an approach (fortunately we were getting close to the airport and were in VMC by then). A no-nav miss out of LVK could raise the blood pressure: LVK is in a valley, below radar service. And the surrounding hills (up to 4000') result in non-standard climb gradient requirements. No issue for most RV's but in a loaded 172 climbing blind, trying to find the low spots in the hills...I don't like to think about it. I never did learn what happened on that approach. GTN worked the next day. Might have been bad satellite geometry (but box didn't generate a warning). I suspect interference, either big brother testing, or a truck going down the interstate.
 
The precision approach issue is an ICAO issue. Essentially most LPV approaches are to the same DH/DA as an ILS. The difference is that most LPV approaches require 3/4 mile visibility vs 1/2 for most ILS. This is really only a factor for Part 135 where the operator cannot start the approach unless the visibility is above minimums.
Also many LPV approaches have only runway lights. Full approach lights, touchdown and centerline lights allow approaches as low as 1800 RVR for Cat I ILS.

This is a bit of a "chicken or egg" issue. Most LPV approaches have only runway lights is correct. But all approaches to such a runway will always have visibility minimums of 3/4 mile or more, not because of an issue with gps, but because if the visibility was down to 1/2 mile then at a 200' decision height you would see NOTHING!. You always need approach lighting to get 1/2 mile visibility minimums, ILS or LPV. And most of the airports with approach lighting get LPV minimums of 200' - 1/2 mile.
 
Does that mean that they now accept an LPV as a precision approach? I always thought there position was it was not. Also, how do you get two different non-precision approaches via GPS.

Larry

I flew an LPV for my precision approach during my checkride back in 2014. The Flight School, the Kings training material and obviously the DPE were in agreement that an LPV, while not technically classified as a precision approach, nevertheless qualified and the instrument PTS listed it as such too.

So the 2013 change 5 to the 2010 PTS replaced the APV note with LPV verbiage in Aircraft and Equipment Required for the Practical Test section and said this: “Note: A localizer performance with vertical guidance (LPV) approach with a decision altitude (DA) greater than 300 feet height above terrain (HAT) may be used as a nonprecision approach; however, due to the precision of its glidepath and localizer-like lateral navigation characteristics, an LPV can be used to demonstrate precision approach proficiency (AOA VI Task B) if the DA is equal to or less than 300 feet HAT.”

The current ACS basically says the exact same thing:
Localizer Performance with Vertical Guidance (LPV Minimums)
Localizer performance with vertical guidance (LPV) minimums with a decision altitude (DA) greater than 300 feet height above touchdown (HAT) may be used as a nonprecision approach; however, due to the precision of its glidepath and localizer-like lateral navigation characteristics, an LPV minimums approach can be used to demonstrate precision approach proficiency if the DA is equal to or less than 300 feet HAT.”

So you see, the FAA has allowed the use of an LPV with a low enough DA to be used as a precision approach for many years now.
 
Last edited:
So a local father son team with an RV14 they built just went through this.
They just had a IFR check ride with a GTN625 in their plane and were checked out by the DPE using it as the basis of approaches necessary.
He signed them off, but the FAA came back and required a VOR/ils ground based approach as required and they had to rent a 172 to complete this.
The memorandum above is now not worth the paper its printed on.
 
He signed them off, but the FAA came back and required a VOR/ils ground based approach as required and they had to rent a 172 to complete this.
The memorandum above is now not worth the paper its printed on.

(Sigh). When you said ‘FAA’ I’ll bet you meant ‘FSDO’. These guys seem to never talk with Washington. Ten years ago I asked OAK FSDO about a LODA for transition training. ‘Never heard of it, can’t be done’ was their response. Only after I furnished a few N numbers of owners who already had this LODA did they say, Oh, we didn’t know.
Too bad your friends didn’t go straight to EAA or AOPA, have them call the administrator and ask why his FSDO’s wouldn’t follow his instructions.
 
Back
Top