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 and testing. You might think this is silly, but Portland FSDO just terminated 3 DPEs for various indiscretions in one day – we try hard to do this job legally and correctly. 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).
Clarification was finally issued and disseminated with this FAA Legal interpretation, separating “navigational systems” from “approaches” and freeing up training and testing to use a LOC and/or ILS in a training/testing event or two different RNAV approaches; thank goodness!
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