As the title suggests, the FAA has changed their opinion on the three approaches required for the instrument XC for the instrument rating (61.65(d)(2)(ii)(C)). Previous FAA opinion was that you needed to use three different types of navigation systems to fulfill this requirement, the memo below rescinds that opinion.
Here's a link to the notice;
Here's the actual memo;
Given the paucity of radar approaches these days, it really doesn't have any significant effect. What would help would be a finding that LPV and LNAV are considered different for this purpose just as ILS and LOC are. And I've already sent an email to Flight Standards and Legal requesting clarification on that point. Maybe AOPA Governmental Affairs can give them a push on that issue.
That's a very good point Ron, I'll get that through the channels to Gov't Affairs.
Got an email from AFS-810 this morning -- right quick response. Here's the relevant portion:
"Acceptable approach operation combinations that meet the requirements of § 61.65 could be an approach operation to a PAR decision altitude (DA), an ASR to a minimum descent altitude (MDA) and a Localizer (LOC) flown to the MDA. Another example could be flying to a Localizer Performance with Vertical guidance (LPV) DA and a Lateral Navigation (LNAV) MDA and a Localizer Performance (LP) to a circling MDA on RNAV (GPS) titled approaches. A third example combination could be a VHF Omnidirectional Range (VOR) approach to an MDA, a LOC to a circling MDA and an Instrument Landing System (ILS) to a DA. This is not an all-inclusive list."
So, LP, LPV, and LNAV are three different approaches for 61.65(d)(2)(ii) purposes. Good to know. Anyone who says otherwise should be referred to:
Brandon B. Enea
Aviation Safety
Aviation Safety Inspector (OPS)
General Aviation & Commercial Division
Training and Certification Group, AFS 810
(O) 682-216-6517
Hoss At AOPA:
AOPA has an article on this topic as well. It can be found here.
Unfortunately, that doesn't explicitly address the RNAV(GPS) sub mode issue, but the AFS-810 email above does.
Unfortunately, that doesn't explicitly address the RNAV(GPS) sub mode issue, but the AFS-810 email above does.
Yep, just threw that out there for reference. You are correct it doesn't address the issue you brought up. I'm glad 810 was able to get back to you so quickly. I'll send this to Gov't Affairs as well.