IFR X-country requirement - what are "three different kinds" of approaches?

[Mileage]

The IFR checkride requirements include a 250nm cross-country with three different types of approaches. The exact language in 61.65 is:

"Instrument flight training on cross country flight procedures, including one cross country flight in an airplane with an authorized instructor, that is performed under instrument flight rules, when a flight plan has been filed with an air traffic control facility, and that involves—

"(A) A flight of 250 nautical miles along airways or by directed routing from an air traffic control facility;

"(B) An instrument approach at each airport; and

"(C) Three different kinds of approaches with the use of navigation systems."

I believe "three different kinds" has traditionally been interpreted to mean really different, like ILS, VOR, NDB and RNAV, but with fewer ground-based options I understand DPEs are accepting RNAVs as long as they are flown in different ways. My CFII says that as long as one approach is non-precision and two are precision, three RNAVs count. My online research suggests it could count but you need 3 different minimas (e.g., LNAV, LNAV+V, LPV) for them to count. I'm asking because we are potentially looking at an LNAV and two LPVs and I don't want to have to redo the long cross country.

Would especially love to hear from CFII's who have had students go through recent IFR checkrides or DPEs who are applying standards.

 

[flyingron]

Your CFI is confused. Three different kinds of approaches mean what you think it means. You can do three non-precision approaches as long as they are all different, i.e, one VOR, one LOC, and one RNAV (GPS).

He is conflating the CHECKRIDE requirement that mandates three different approaches be performed, one of which must be a precision approach and two must be different non-precision approaches. For the purposes of these approaches on the checkride, the definition of precision means "with vertical guidance," and non-precision means "without vertical guidance. This is now at odds with the FAA definitions which perpetuate their assinine half-assed ICAO compliance.

 

[midlifeflyer]

My articles in IFR Magazine on the subject. There are FAA references for this, so it shouldn't be a mystery.

Which Three Approaches?
These Three Approaches.

 

[Mileage]

My articles in IFR Magazine on the subject. There are FAA references for this, so it shouldn't be a mystery.

Which Three Approaches?
These Three Approaches.

So would an RNAV flown to an LPV DA, another flown to an LNAV MDA, and another flown to an LNAV/VNAV DA count?

 

[midlifeflyer]

So would an RNAV flown to an LPV DA, another flown to an LNAV MDA, and another flown to an LNAV/VNAV DA count?

That's exactly what it says. Personally, I would avoid the LNAV/VNAV thing unless (a) you have real LNAV/VVAV equipment or (b) the approach does not have LPV minimums. But, my personal preference aside, but you have plenty of choices without leaving the RNAV world. LNAV, LP, LPV, and circling minimums

Overall, Flight Standards has been excellent in recognizing the move from a NAS relaying on ground-based navaids to one based on GPS. They did it here and they did it with the new Instrument ACS. Hang around here and at some point you'll come across a thread or so about pilots deciding to upgrade their IFR avionics and getting rid of not only their old ADF but their old VLOC receivers. The wisdom of that decision aside, one can meet the FAR flight requirements and complete the instrument checkride without a ground-based navaid installed.

 

[luvflyin]

That's exactly what it says. Personally, I would avoid the LNAV/VNAV thing unless (a) you have real LNAV/VVAV equipment or (b) the approach does not have LPV minimums. But, my personal preference aside, but you have plenty of choices without leaving the RNAV world. LNAV, LP, LPV, and circling minimums

Overall, Flight Standards has been excellent in recognizing the move from a NAS relaying on ground-based navaids to one based on GPS. They did it here and they did it with the new Instrument ACS. Hang around here and at some point you'll come across a thread or so about pilots deciding to upgrade their IFR avionics and getting rid of not only their old ADF but their old VLOC receivers. The wisdom of that decision aside, one can meet the FAR flight requirements and complete the instrument checkride without a ground-based navaid installed.

So three different lines of minimums on the same approach counts as three different kinds of approach???

 

[MauleSkinner]

unless (a) you have real LNAV/VVAV equipment

As in Baro VNAV?

 

[midlifeflyer]

As in Baro VNAV?

Yeah.

So three different lines of minimums on the same approach counts as three different kinds of approach???

I guess in theory But it would be kind of silly to do travel a total of 250 NM one way with an instructor on an IFR flight plan and do all of the approaches at the only remote airport, land there, and not try to meet any of the requirements on the way back home.

 

[murphey]

That's exactly what it says. Personally, I would avoid the LNAV/VNAV thing unless (a) you have real LNAV/VVAV equipment or (b) the approach does not have LPV minimums. But, my personal preference aside, but you have plenty of choices without leaving the RNAV world. LNAV, LP, LPV, and circling minimums

Overall, Flight Standards has been excellent in recognizing the move from a NAS relaying on ground-based navaids to one based on GPS. They did it here and they did it with the new Instrument ACS. Hang around here and at some point you'll come across a thread or so about pilots deciding to upgrade their IFR avionics and getting rid of not only their old ADF but their old VLOC receivers. The wisdom of that decision aside, one can meet the FAR flight requirements and complete the instrument checkride without a ground-based navaid installed.

When I had the GPS installed, the shop offered to add a switch so one CDI could work with either the SL30 or the GPSs. No way - I don't want single point of failure. The GPS talks to the HSI, the SL30 talks to the CDI (and the ADF still works if there were any within 100 miles and the DME is flakey). Pueblo, Colorado (KPUB) used to have PAR approaches for everyone but now only for the military.

 

[MauleSkinner]

So three different lines of minimums on the same approach counts as three different kinds of approach???

The thing I find interesting about it is that unless you can manually downgrade your navigator, you’re essentially flying a WAAS LPV to 3 different altitudes. You’re not getting the parallel vs localizer-like CDI deflection.

Theoretically you’d level off at MDA on the LNAV approach, but I struggle to get people to actually do that.

But bottom line is that if you have a WAAS airplane with no ground-based navigation, you can still meet the requirements.

 

[midlifeflyer]

The thing I find interesting about it is that unless you can manually downgrade your navigator, you’re essentially flying a WAAS LPV to 3 different altitudes. You’re not getting the parallel vs localizer-like CDI deflection.

To some degree, we can manually downgrade in the GPS world in a way we couldn't in the ground-based world. Turning off WAAS on a Garmin GPS degrades the unit down to LNAV. If your ADS-B transponder does not have an independent WAAS source, the legality of doing that is questionable, but I've seen it done even then.

But I think degradability or it's lack it's just a byproduct of what we have. For example, even pre-magenta, we could fly an ILS glideslope to circling minimums.

Theoretically you’d level off at MDA on the LNAV approach, but I struggle to get people to actually do that.

I really haven't had that issue and I would have no problem "busting" a pilot on an IPC for busting minimums. I think that's a pretty basic failure. The scenario I use for LOC only or LNAV (when I can't or won't disable WAAS) is a NOTAM. GS Unusable or unreliable. In the case of both LOC and LNAV, ILS or LPV Minimums NA. Or straight-in minimums NA. I got that idea when we had some runway work at my home base and the DA was NA for both the ILS and the identical RNAV. Sometimes I make it up; but other times, they are real. I recently gave an IPC where for one of the airports, straight-in minimums were not authorized. Continue merrily down the glidepath below MDA? "Uh-oh. You just hit a construction crane!"

BTW, I do read the NOTAMs for practice sessions even under VFR. I didn't used to and then, one day, I was working with a pilot. Neither of us read them, and, boy, were we surprised when, on an ILS approach, we got the GS but no lateral guidance!

 

[MauleSkinner]

I really haven't had that issue and I would have no problem "busting" a pilot on an IPC for busting minimums. I think that's a pretty basic failure.

I deal primarily with commercial operators, most of whom have authorization to use an MDA as a DA. There are some restrictions on that, but for the approaches we use for checkrides it’s legit. Unfortunately I need to see them level off at MDA for other reasons, and I doubt that the average pilot I work with has done an approach without DA capability in real life for a long time. Habits are hard to break.

 

[luvflyin]

I deal primarily with commercial operators, most of whom have authorization to use an MDA as a DA. There are some restrictions on that, but for the approaches we use for checkrides it’s legit. Unfortunately I need to see them level off at MDA for other reasons, and I doubt that the average pilot I work with has done an approach without DA capability in real life for a long time. Habits are hard to break.

To do that “…use an MDA as a DA…” thing, don’t you have to do it above the MDA? Add like 30 feet or so and call it a Derived DA?

 

[midlifeflyer]

To do that “…use an MDA as a DA…” thing, don’t you have to do it above the MDA? Add like 30 feet or so and call it a Derived DA?

That's what the AC says about it.

 

[luvflyin]

That's what the AC says about it.

How many feet is it? What’s the AC number?

 

[MauleSkinner]

To do that “…use an MDA as a DA…” thing, don’t you have to do it above the MDA? Add like 30 feet or so and call it a Derived DA?

Not under the conditions of their OpSpecs.

 

[Clip4]

So three different lines of minimums on the same approach counts as three different kinds of approach???

Yes, but you are really cheating yourself doing that. Ideally an ILS, a VOR and an RNAV is a better choice.

 

[RussR]

BTW, I do read the NOTAMs for practice sessions even under VFR. I didn't used to and then, one day, I was working with a pilot. Neither of us read them, and, boy, were we surprised when, on an ILS approach, we got the GS but no lateral guidance!

Interesting, that really shouldn't happen. If the localizer is out of service, the GS should have been turned off too.

To do that “…use an MDA as a DA…” thing, don’t you have to do it above the MDA? Add like 30 feet or so and call it a Derived DA?

No, well yes, sort of. Meaning that anybody can add 50 ft or whatever to the MDA and just decide that's a new Derived DA, and use it as a DA. As long as you don't go below the MDA, you can start your missed approach at whatever altitude you want. No approval or anything required.

But Part 121 and 135 operators may have an OpSpec that allows them to instead use the actual MDA as a DA without adding anything. This does depend on certain other factors, one of which is that an ILS approach must be published to that runway (even if it's out of service). This is because the MDA provides at least 250 ft of obstacle protection, and an ILS DA is both lower than that MDA and provides fewer feet of protection. So in these situations, sinking below MDA by 50 feet or so as you go missed still has adequate safety margins. But it's something that the operator needs to be approved to do, and the pilots need to be trained on (it's in our annual training).

Yes, but you are really cheating yourself doing that. Ideally an ILS, a VOR and an RNAV is a better choice.

I agree with this. Is the OP saying there isn't an ILS within any reasonable distance? That seems possible but not too likely, unless they are in a pretty remote area. If there IS an ILS, then flying an ILS, LPV, and LNAV would be far preferable than just three RNAVs.

One of the recurring problems I see on IPCs is that pilots have routinely forgotten how to fly an ILS. Not the actual flying, but the setup and surrounding details. Like remembering you have to tune in the frequency. Switch the CDI. ID the station. And then on the missed, probably switch back to RNAV. Oh and by the way, if you're using an autopilot and/or flight director, it usually reverts to Roll mode when you switch navigation inputs. I see it again and again where they miss all this stuff because they just don't ever have to do it when flying RNAVs. If quizzed on the ground, they know it, but in the air the RNAV habits override.

 

[midlifeflyer]

Interesting, that really shouldn't happen. If the localizer is out of service, the GS should have been turned off too.

One would think so. Not that day.

 

[luvflyin]

Interesting, that really shouldn't happen. If the localizer is out of service, the GS should have been turned off too.



No, well yes, sort of. Meaning that anybody can add 50 ft or whatever to the MDA and just decide that's a new Derived DA, and use it as a DA. As long as you don't go below the MDA, you can start your missed approach at whatever altitude you want. No approval or anything required.

But Part 121 and 135 operators may have an OpSpec that allows them to instead use the actual MDA as a DA without adding anything. This does depend on certain other factors, one of which is that an ILS approach must be published to that runway (even if it's out of service). This is because the MDA provides at least 250 ft of obstacle protection, and an ILS DA is both lower than that MDA and provides fewer feet of protection. So in these situations, sinking below MDA by 50 feet or so as you go missed still has adequate safety margins. But it's something that the operator needs to be approved to do, and the pilots need to be trained on (it's in our annual training).



I agree with this. Is the OP saying there isn't an ILS within any reasonable distance? That seems possible but not too likely, unless they are in a pretty remote area. If there IS an ILS, then flying an ILS, LPV, and LNAV would be far preferable than just three RNAVs.

One of the recurring problems I see on IPCs is that pilots have routinely forgotten how to fly an ILS. Not the actual flying, but the setup and surrounding details. Like remembering you have to tune in the frequency. Switch the CDI. ID the station. And then on the missed, probably switch back to RNAV. Oh and by the way, if you're using an autopilot and/or flight director, it usually reverts to Roll mode when you switch navigation inputs. I see it again and again where they miss all this stuff because they just don't ever have to do it when flying RNAVs. If quizzed on the ground, they know it, but in the air the RNAV habits override.

That makes sense, that there has to be an ILS whether it’s working or not. What’s the assumed dip below DA when missing because you don’t have the runway environment in sight at DA? I think I remember that being 70’

 

[midlifeflyer]

One of the recurring problems I see on IPCs is that pilots have routinely forgotten how to fly an ILS. Not the actual flying, but the setup and surrounding details.

This is the reason I use one on IPCs if they have the equipment. I even want it fully coupled if they have an autopilot. I see more errors there than with any modern approach.

 

[Clip4]

One would think so. Not that day.

That’s why preflight planning for IFR should include a determination if an ILS is monitored or not.

 

[midlifeflyer]

That’s why preflight planning for IFR should include a determination if an ILS is monitored or not.

At least that day, there was a NOTAM approach was NA, so monitoring wasn't an issue.

 

[geezer]

The thought of flying IFR in a plane with sole navigation sourced from GPS satellites gives me the willies.

A quality ADF could be a life saver, providing navigation to a destination city, followed by radar vectors to the airport.

At the airport, vectors to a straight in, and descend to the MDA for the non precision approach, should get you in.

The L charts had the frequency and call letters of the radio towers with the height information, and I hope that is still there.

Half a century ago, I had a friend at KCGS, College Park, MD, who had a Bonanza with an airline ADF factory installed, plus long range tanks and tip tanks. He flew from Miami to KCGS, direct to WMAL, non stop. He tuned the station on the ground, and flew an IFR flight plan. Since he was alone, no weight and balance problems with full fuel, but a screw top to container for used coffee He had sandwiches and thermoses of water and coffee.

 

[StraightnLevel]

Yes, but you are really cheating yourself doing that. Ideally an ILS, a VOR and an RNAV is a better choice.

If the aircraft isn’t VOR current, could you do RNAV, ILS, and back-course LOC?

 

[midlifeflyer]

How many feet is it? What’s the AC number?

Sorry. I missed that question. It's AC 120-108A. the CDFA AC. It does not state a specific altitude, only that, "Operators should discuss how to calculate a DDA to ensure the aircraft does not descend below the MDA when accomplishing a missed approach on a CDFA." I'm not sure how there can be a universal number applicable to every aircraft.

 

[RussR]

That makes sense, that there has to be an ILS whether it’s working or not. What’s the assumed dip below DA when missing because you don’t have the runway environment in sight at DA? I think I remember that being 70’

It's not really specified in those terms, but mathematically it's 1460*tan(glideslope angle), so for a normal ILS (or LPV), 1460*tan(3 deg) = about 76 feet.

 

[RussR]

If the aircraft isn’t VOR current, could you do RNAV, ILS, and back-course ILS?

Back-course LOC, not ILS (there will not be a glideslope with the BC), but sure that would meet the requirement. The trick might be finding a BC approach. I know for me here in OKC, the closest one is Hutchinson, KS, over 150 nm away.

Although HUT is a good lunch stop, so I have definitely taken clients there, and got to show them a BC approach along the way.

 

[midlifeflyer]

I know for me here in OKC, the closest one is Hutchinson, KS, over 150 nm away.

We had one very close by, at FAY, until about two weeks ago. The Gateway shows only 45 left currently and I'm sure some of those must be slated for cancellation.

 

[MauleSkinner]

Back-course LOC, not ILS (there will not be a glideslope with the BC), but sure that would meet the requirement. The trick might be finding a BC approach. I know for me here in OKC, the closest one is Hutchinson, KS, over 150 nm away.

Although HUT is a good lunch stop, so I have definitely taken clients there, and got to show them a BC approach along the way.

You can do lazy 8s over KHUT and get most every type of approach you want.

Although a couple of people I trained argued just a little longer than necessary that “they should just put in an ILS” so they wouldn’t have to train a BC.

 

[RussR]

You can do lazy 8s over KHUT and get most every type of approach you want.

You're not kidding. Great training environment. I just looked, and:

ILS
LOC BC
LPV
LNAV-only
VOR with DME required
VOR without DME required (timing table)
DME arcs
HILPT
PT

I wonder if they have any flight school, and if they even bother to fly anywhere else!

 

[MauleSkinner]

You're not kidding. Great training environment. I just looked, and:

ILS
LOC BC
LPV
LNAV-only
VOR with DME required
VOR without DME required (timing table)
DME arcs
HILPT
PT

I wonder if they have any flight school, and if they even bother to fly anywhere else!

Unfortunately they recently got rid of their NDB.

 

[Clip4]

If the aircraft isn’t VOR current, could you do RNAV, ILS, and back-course LOC?

Or you could just log the VOR check will en-route. It’s not like you won’t have the time or opportunity.

 

[Jim_R]

Although HUT is a good lunch stop, so I have definitely taken clients there, and got to show them a BC approach along the way.

World-class space museum there, too, that also happens to have an SR-71 static display in the lobby.

Home - Cosmosphere

Tour the Cosmosphere

cosmo.org

 

[RussR]

World-class space museum there, too, that also happens to have an SR-71 static display in the lobby.

Home - Cosmosphere

Tour the Cosmosphere

cosmo.org

Agreed, it's fantastic. Lots of Soviet space exhibits too, which you don't see very often.

And they have reciprocity with the EAA museum through the ASTC, which means if you're an EAA member you can get in free.

And there's a Salt Mine you can tour too. And an Amish community.

My annual King Air recurrent training is at FlightSafety in Wichita. Last year my wife came up with me and we took a day and played tourist. Hutchinson was a surprisingly interesting place to go, we easily spent the whole day there.

 

[brcase]

To some degree, we can manually downgrade in the GPS world in a way we couldn't in the ground-based world. Turning off WAAS on a Garmin GPS degrades the unit down to LNAV. If your ADS-B transponder does not have an independent WAAS source, the legality of doing that is questionable, but I've seen it done even then.

took me a little bit to figure out one of our other instructors was doing that and then not re-enabling WAAS when he was done. I was trying to figure out why I couldn't get vertical navigation on an LPV approach.

If we don't have ground navigation available. I usually try to do an LPV approach, an LNAV approach, and a Circling approach off the LNAV or LPV. We are fortunate that one of the approaches to our airport is strictly an LNAV approach so it easy to have students fly that one. If flying an LPV as an LNAV approach, Disabling the WAAS works well, or as a minimum, make sure they fly it all the way to the MAP.

Brian
CFIIG/ASEL

 

[midlifeflyer]

took me a little bit to figure out one of our other instructors was doing that and then not re-enabling WAAS when he was done. I was trying to figure out why I couldn't get vertical navigation on an LPV approach.

That definitely happens. I take notes when I fly with someone. If I turn it off , I make a note of it in red. No guarantee, but it helps.

If we don't have ground navigation available. I usually try to do an LPV approach, an LNAV approach, and a Circling approach off the LNAV or LPV. We are fortunate that one of the approaches to our airport is strictly an LNAV approach so it easy to have students fly that one. If flying an LPV as an LNAV approach, Disabling the WAAS works well, or as a minimum, make sure they fly it all the way to the MAP.

Brian
CFIIG/ASEL

We're in relatively decent shape. Not LNAV, but we do have a few with LP minimums, one only 21 NM away. It's a quiet airport with opposing RNAV approaches, one LP and one LPV. Depending on the prevailing winds, it works out well. We also have a real LOC-only just 22 NM away. Unfortunately it's DME-only and I avoid using DME-required approaches unless the pilot has real DME, but in a pinch for a change of pace, at least it doesn't have a green glideslope.

 

[Matthew]

World-class space museum there, too, that also happens to have an SR-71 static display in the lobby.

Home - Cosmosphere

Tour the Cosmosphere

cosmo.org

Heh - my favorite HUT story:

Many years ago the FBO where I was a renter sponsored a fly-in to HUT. We probably had a dozen planes, maybe more. The plan was half would take a direct route and half would take a slightly longer route so we wouldn’t all arrive at the same time. What we didn’t know is we would all arrive at the same time anyway. The other thing we didn’t know was another group, completely unrelated to ours, also planned a fly in and another 10-12 planes got there the same time we did. Tower was working a Bonanza doing practice approaches and all of a sudden got nearly 2 dozen 172s and Warriors. I think he spit out his Saturday morning coffee. It all worked out. The Bonanza volunteered to hold, the controller went into OSH mode, all of us paid attention to situational awareness and we all got handled just fine. Eventually the Bonanza asked if he was cleared for the approach.

Yes, that museum is outstanding. I’ve been there several times and should go back again someday. I don’t know if the steakhouse restaurant is still there inside the airport terminal building, but it always had good reviews.

 

[RussR]

I don’t know if the steakhouse restaurant is still there inside the airport terminal building, but it always had good reviews.

It is.

I have never eaten dinner there (which is reportedly excellent), but the lunch buffet is worth the trip itself.

 

[flyingcheesehead]

We also have a real LOC-only just 22 NM away. Unfortunately it's DME-only and I avoid using DME-required approaches unless the pilot has real DME

Why?