Clarification of Different Kinds of Approaches. Section 61.65(d) contains the aeronautical experience requirements for a person applying for an Instrument—Airplane rating. Section 61.65(d)(2)(ii)(C) states, in relevant part, that an applicant must complete 40 hours of actual or simulated instrument time that includes at least one cross-country flight that is performed under instrument flight rules (IFR) and involves “three different kinds of approaches with the use of navigation systems.” The FAA previously issued legal interpretations indicating that the three different kinds of approaches must utilize three different kinds of navigation systems. The FAA has since rescinded the legal interpretations. To fulfill the regulatory requirements, an applicant only needs to conduct three different kinds of approaches regardless of the navigation system utilized. Different approaches can be defined by the various lines of minima found on an approach plate. For example, localizer (LOC) minima are one kind of approach operation and instrument landing system (ILS) minima are another kind of approach operation. The same could be true of Area Navigation (RNAV) GPS-titled approach plates; a localizer performance with vertical guidance (LPV) approach is one kind of approach operation and a Localizer Performance (LP) to a circling MDA is another kind of approach operation. Subparagraph 5-433A3) above discusses the types of approaches. This paragraph also applies to § 61.65(e)(2) and (f)(2).