Types of Approaches for the Instrument Cross Country
I instruct for a part 141 university. I recently completed the 250NM instrument cross country with a student. We went to three airports and executed three different approaches (GPS, ILS, LOC). As per FAR 61.65(d)(2)(ii)(C) Three different kinds of approaches with the use of navigation systems, I feel that we met the requirements for the three different approaches. I was told, however, that we did not as per an FAA Letter of Interpretation issued in 2008 to Danny Glaser. In the letter, Rebecca Macpherson (Assistant Chief Counsel for Regulations) lists the above mentioned regulation as it was in 2008, but then goes on in another paragraph to interpret it as three different kinds of navigation systems. I am confused as to how she can list the regulation: Three different kinds of approaches with the use of navigation systems and then state that you must use three different kinds of navigation systems. I interpret the intent of the regulation to mean that you must use a navigation system(s) of some sort to execute three different approaches. In other words, visual, ASR, or PAR approaches do not count as was asked by Mr. Glaser in his letter. Does anyone have any thoughts? I've been instructing for many years and have never had an examiner question the types of approaches for the cross country.
1 Replies
Whoever told you that letter says ILS and LOC approaches aren't "different" within the context of 61.65d is misinterpreting the Glaser letter.  The FAA has long accepted that ILS and LOC are "different" approaches since one is precision and one is nonprecision.  Same, according to the Instrument-Airplane ACS, for RNAV(GPS) LNAV/LP versus LPV (at least when the LPV DH is 300 or less).  The only thing the Glaser letter is saying is that you can't use a ground-controlled radar approach (ASR or PAF) to meet this requirement -- they want you to be following needles, not controller instructions.  As such, GPS+ILS+LOC meets the requirement.    If whoever told you otherwise has further questions, they should be referred to AFS-810, which manages this regulation.

I would also point out that if this were true, nobody could meet the requirement without a GPS or ADF, and that is clearly wrong.

That said, the three must all be "different".  You can't do two VOR's and an ILS, or two LNAV's and an ILS to meet the requirement.