Dear Designees:

On 02/28/2022 the Office of the Chief Council (AGC-240) issued a memorandum rescinding two legal interpretations pertaining to instrument training requirements under 14 CFR § 61.65. Specifically, the memorandum clarified the instrument approach procedures that may satisfy § 61.65(d)(2)(ii)(C). Although the Instrument Rating – Airplane Airman Certification Standards (ACS) was referenced, it did not alter the testing requirements of Instrument Approach Procedures as specified in Area of Operation VI and Appendix 7 of the ACS.

The ACS directs the evaluator to test an applicant on three different kinds of approaches, consisting of one precision approach and two non-precision approaches, which must use two different kinds of navigational aids. The ACS provides acceptable examples of those instrument approaches which may be used during the practical test for the precision and non-precision instrument-approach testing requirements. Therefore for an example, conducting three GPS approaches during an instrument rating practical test would not meet FAA-testing requirements.

Should you have any further questions, please contact your Managing Specialist.

Sincerely,

Designee Standardization Branch (AFS-640)

Cc: Managing Specialists

Message coordinated with the Training and Certification Group (AFS-810)