FAA Rescinds Legal Rulings On Obsolete IFR Training Requirement


On Feb. 28, the FAA issued Notice No: NOTC2305, which concludes that previous legal interpretations of the requirements of FAR 61.65(d)(2)(ii)(C) are “overly restrictive.” The regulation deals with the requirements for completing the cross-country portion of training for the instrument rating and says in “plain language” (words from the FAA statement) that the applicant must complete three different types of instrument approaches as part of the flight. But two “legal interpretations,” one from 2008 and the second reached in 2012, concluded that the three approaches must involve three separate navigation systems, for example VOR, ADF and ILS.

Apparently taking to heart that while modern GPS-based navigators often include VOR/LOC capability for non-precision VOR approaches and ILS precision approaches, fewer and fewer aircraft are equipped with automatic direction finding (ADF) receivers to access non-directional beacons (NDBs). And further, most instrument approaches in the system are now satellite-based. Many legacy approaches now use the original procedure as an overlay, using GPS navigation and position data.

NOTC2305 rescinds both interpretations and clarifies that the regulation simply requires three different types of approaches, not the use of three different navigation sources. The FAA wrote, “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.”

Mark Phelps
Mark Phelps is a senior editor at AVweb. He is an instrument rated private pilot and former owner of a Grumman American AA1B and a V-tail Bonanza.

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  1. I had never even heard of that previous (obviously ridiculous) interpretation.

    But funny how they can simply rescind their own legal interpretations when they realize they made an error. It’s almost like it shouldn’t take 4 years to fix the rules regarding flight training in experimentals when they can just issue a new legal interpretation…

    • I guess it’s safe to stop practicing A-N approaches.
      But I do miss listening to Rush on my ADF radio.
      Now, apparently, there will be no baseball games, either.

      • I’m not old enough to have flown A-N Ranges. But, out of curiosity, were there A-N Approaches? (I thought that they were Enroute only.)

        I also miss listening to Rush on our ADF. And, before the days of GPS, the ADF, on a strong AM station (during the day) was a good backup for Gyro failure.

        • Yes Era, (Range approaches)
          Back in ’64, I picked up a Fed in Van Nuys, CA in my PA23 Apache for an ATR check ride.
          We flew to the “high desert” area where he told me to shoot a range approach (on one engine) to Palmdale plant 42.
          No problem – homed in on one of the range legs, followed it in & passed over the cone of silence, gear down & descended to the MDA.
          I needed to hold that “til the time was up for a missed approach.
          I had the good engine firewalled & continued to slowly LOOSE airspeed.
          Well, before I got to the “times up” point, I had gone a couple knots below
          VMC, which at that point, I knew I FLUNKED.
          Believe it or not, I thanked him for failing me – know why?
          BECAUSE I DID NOT RETRACT THE GEAR in order to maintain the airspeed!!!
          And, NEVER forgetting that, may have saved me & others from a possible future disaster.

          • Old but sage advice:
            When do you lower the gear, on approach?
            When it is NECESSARY to do so, in order to land.

          • My Dad tells the story of shooting an AN approach in an SNB (Navy Beech 18). He hit the cone of silence, got the tone, dropped the gear, and got silence. Retracted the gear and got the tone, dropped the gear and cone of silence again.

            The winds aloft were strong enough that when he dropped the gear, he backed up.

            FYI, right over the AN station there was no signal, called the cone of silence. So you would fly inbound on one leg, then at the cone of silence, configure, and start decent on a heading, time, then turn onto an inbound leg. A teardrop approach, similar to some VOR High approaches where the VOR is on or near the airport.

        • Yup, there were A-N approaches, with minimums as low as 200 feet.
          Glad to hear that others knew how to use the ADF needle to keep the dirty side down, in a pinch. I taught that old trick to many instrument students.

      • How do you stop practicing A-N approaches when the last one was decommissioned in the 60s? Just asking. LOL

  2. There is an assumption in some of the comments that the FAA made an error and had to back track. You have to look at it within the context of2008 and 2012. GPS WAAS with approaches flown to LPV DA mins were barely starting to gain traction by 2012 and many IFR GPSs were not WAAS. Customary installations in the 2000’s for a “well equipped ”IFR airplane included VOR, ILS, a non-WAAS IFR GPS and maybe an ADF. So, it was acceptable to talk about three types of “navigation systems” vs. three different types of approaches. FAA is simply realizing that VOR and NDB approaches are mostly gone (decommissioning or lack of ADF) and that we (light general aviation)navigation is GPS. However, I think a more precise definition of what constitutes three different types of approaches is needed.  For example: GPS approach to LPV mins, GPS approach to LNAV mins (using dive & drive technique) and circling, would that be three different types of approaches? Or could a differing characteristic be: precision, non-precision and circling – regardless of underlying technology?