Conscientious CFIs and DPEs have been carefully skating on the edge of “FAA legality” with the ambiguity in the FAA interpretation of “instrument approaches” in the regs. Until now, if you follow the strict interpretation of “different approach” in the Glasser Letter (as different “navigational system”) you are continually searching around for an operational VOR to execute an approach for training (flying another approach over a “local VOR” is also not legal for testing – has to be the real deal). You might think this is silly, but Portland FSDO just terminated 3 DPEs (in one day) for various indiscretions – we try hard to do this job legally and correctly. The long X-C has to be verified for qualification. If a test is flown with improper procedures, heads will roll.
As a result, the FAA is rescinding both the Glaser and Pratte interpretations. Furthermore, because the regulations do not define “navigation systems,” Flight Standards Service (AFS) is in the best position to issue policy and guidance on what “navigation systems” mean and which ones may be used under § 61.65(d)(2)(ii)(C)…[C]ongress intended for courts to defer to agencies when they interpret their own ambiguous rules.
Clarification was just issued and disseminated with this FAA Legal interpretation, separating “navigational systems” from “approaches” and freeing up training to use a LOC and/or ILS in a training event under CFR 61.65.
In testing, Appendix 7 of the Instrument ACS requires two different *navigational systems* for the non-precision approaches. (One certainly could be a VOR) Knowledge of VOR seems critical since this is the FAA backup in the MON system if the GPS constellation fails. ILS precision, LOC non-precision works here.
To be perfectly clear (thanks to a comment); this FAA memo clarifies *training.* Testing remains unchanged specifying two nav systems for non-precision approaches (but nowhere requires *three* separate nav sources).
Fly safe out there (and often)!
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