Definition of simulated instrument conditions

[bsalai]

Does anyone know if Simulated Instrument Conditions is defined anywhere?

The reason for the question is whether one can log instrument time, say
at night, when you don't look outside, but don't wear foggles or a hood?

I can't find anything in the rules that defines simulated instrument
conditions, but since the rule for logging instrument time says both
that flight has to be solely by referenct to instruments in actual or
simulated instrument conditions, that would suggest that more is
required than "solely by reference to instruments" and therefore that
some sort of view limiting device is required.

It would certainly be easier if they defined simulated insturment
conditions though.

Brad

[Peter Clark]

On Sun, 29 Jan 2006 14:40:00 GMT, bsalai >
wrote:

>Does anyone know if Simulated Instrument Conditions is defined anywhere?
>
>The reason for the question is whether one can log instrument time, say
>at night, when you don't look outside, but don't wear foggles or a hood?
>
>I can't find anything in the rules that defines simulated instrument
>conditions, but since the rule for logging instrument time says both
>that flight has to be solely by referenct to instruments in actual or
>simulated instrument conditions, that would suggest that more is
>required than "solely by reference to instruments" and therefore that
>some sort of view limiting device is required.

It wouldn't seem logical to me that "just not looking outside" would
ever count for instrument time.

The now unavailable part 61 FAQ said "Normally, in order to log
instrument flight time under “simulated instrument conditions,” the
pilot needs to be utilizing a view limiting device".

Therefore, to get IMC time out of anything else it needs to meet the
requirements for actual instrument time (real IMC or the classic "VMC
with no useful horizon at night", like looking out over water or unlit
ground with no moonlight etc.

[Gary Drescher]

"bsalai" > wrote in message
.. .
> Does anyone know if Simulated Instrument Conditions is defined anywhere?
>
> The reason for the question is whether one can log instrument time, say at
> night, when you don't look outside, but don't wear foggles or a hood?
>
> I can't find anything in the rules that defines simulated instrument
> conditions, but since the rule for logging instrument time says both that
> flight has to be solely by referenct to instruments in actual or simulated
> instrument conditions, that would suggest that more is required than
> "solely by reference to instruments" and therefore that some sort of view
> limiting device is required.
>
> It would certainly be easier if they defined simulated insturment
> conditions though.

This is one of the most confusing aspects of the FAA's terminology.

It turns out that if you *need* to fly by reference to instruments (for
example, at night with no moon over unlit terrain) then that counts as
actual (not simulated) instrument conditions--although it does not count as
instrument *meteorological* conditions (IMC), and hence does not require
being IFR rather than VFR. But it can be logged as instrument time.

But no, the FAA never actually defines the term "instrument conditions" (as
opposed to "instrument meteorological conditions"). The FAA used to have an
online FAQ that contained this explanation, but they recently removed it. So
now it's relegated to the status of a newsgroup rumor--or you could send a
letter or email to your FSDO asking about it. If enough people do that,
perhaps the FAA will be prompted to define the term.

--Gary

[Peter Clark]

On Sun, 29 Jan 2006 09:57:44 -0500, "Gary Drescher"
> wrote:

> The FAA used to have an
>online FAQ that contained this explanation, but they recently removed it. So
>now it's relegated to the status of a newsgroup rumor--or you could send a
>letter or email to your FSDO asking about it. If enough people do that,
>perhaps the FAA will be prompted to define the term.

Actually, FWIW the FAQ said:

"There is no official FAA definition of “actual instrument time” or
“simulated instrument time” in the FARs, FAA Orders, advisory
circulars, FAA bulletins, etc. And probably the reason why the FAA has
never officially defined “actual instrument time” or “simulated
instrument time” is because in all of the aeronautical experience
requirements for pilot certificate and/or ratings in Part 61 the rule
does not differentiate between “actual instrument time” as opposed to
“simulated instrument time.” In fact, in Part 61 it only refers to the
aeronautical experience for instrument time to be “. . . instrument
flight time, in actual or simulated instrument conditions . . .” So it
is irrelevant whether the instrument flight time is logged as “actual
instrument time” or “simulated instrument time.” Part 61 only refers
to “actual instrument conditions” or “simulated instrument
conditions.”"

[Jim Macklin]

At night, with no horizon and no moon you have actual
instrument conditions. You can simulate instrument
conditions in many ways, yellow plastic curtains and blue
goggles, Foggles, a hood or just look only at the panel.
There is no requirement for a hood.
About 20 years ago, the FAA in Wichita came up with a device
to block the pilot's view forward on the King Air 300, which
required a type rating and that the pilot be able to see the
entire cockpit and reach all the controls. They developed
and approved the use of a sheet metal device that was held
on the glare shield by a spring clamp. There were two metal
pieces attached in such a manner that the pilot could not
see straight ahead but allowed the examiner to see at an
angle through the pilot's windshield. The co-pilot and side
windows were not covered at all.
Eventually, they quit using it at all.


--
James H. Macklin
ATP,CFI,A&P

--
The people think the Constitution protects their rights;
But government sees it as an obstacle to be overcome.
some support
http://www.usdoj.gov/olc/secondamendment2.htm
See http://www.fija.org/ more about your rights and duties.


"bsalai" > wrote in message
.. .
| Does anyone know if Simulated Instrument Conditions is
defined anywhere?
|
| The reason for the question is whether one can log
instrument time, say
| at night, when you don't look outside, but don't wear
foggles or a hood?
|
| I can't find anything in the rules that defines simulated
instrument
| conditions, but since the rule for logging instrument time
says both
| that flight has to be solely by referenct to instruments
in actual or
| simulated instrument conditions, that would suggest that
more is
| required than "solely by reference to instruments" and
therefore that
| some sort of view limiting device is required.
|
| It would certainly be easier if they defined simulated
insturment
| conditions though.
|
| Brad

[Ron Rosenfeld]

On Sun, 29 Jan 2006 14:40:00 GMT, bsalai > wrote:

>Does anyone know if Simulated Instrument Conditions is defined anywhere?
>
>The reason for the question is whether one can log instrument time, say
>at night, when you don't look outside, but don't wear foggles or a hood?
>
>I can't find anything in the rules that defines simulated instrument
>conditions, but since the rule for logging instrument time says both
>that flight has to be solely by referenct to instruments in actual or
>simulated instrument conditions, that would suggest that more is
>required than "solely by reference to instruments" and therefore that
>some sort of view limiting device is required.
>
>It would certainly be easier if they defined simulated insturment
>conditions though.
>
>Brad

It is not defined in the regulations. But it was "defined" in a published
FAA Chief Counsel legal interpretation some twenty or so years ago:

==============================================
--quoted text--
First, you ask for an interpretation of Section 61.51(c)(4) of the
Federal Aviation Regulations (FAR) regarding the logging of instrument
flight time. You ask whether, for instance, a flight over the ocean on
a moonless night without a discernible horizon could be logged as
actual instrument flight time.
***
As you know, Section 61.51(c)(4) provides rules for the logging of
instrument flight time which may be used to meet the requirements of a
certificate or rating, or to meet the recent flight experience
requirements of Part 61. That section provides in part, that a pilot
may log as instrument flight time only that time during which he or
she operates the aircraft solely by reference to instruments, under
actual (instrument meteorological conditions (imc)) or simulated
instrument flight conditions. "Simulated" instrument conditions occur
when the pilot's vision outside of the aircraft is intentionally
restricted, such as by a hood or goggles. "Actual" instrument flight
conditions occur when some outside conditions make it necessary for
the pilot to use the aircraft instruments in order to maintain
adequate control over the aircraft. Typically, these conditions
involve adverse weather conditions.
To answer your first question, actual instrument conditions may
occur in the case you described a moonless night over the ocean with
no discernible horizon, if use of the instruments is necessary to
maintain adequate control over the aircraft. The determination as to
whether flight by reference to instruments is necessary is somewhat
subjective and based in part on the sound judgment of the pilot. Note
that, under Section 61.51(b)(3), the pilot must log the conditions of
the flight. The log should include the reasons for determining that
the flight was under actual instrument conditions in case the pilot
later would be called on to prove that the actual instrument flight
time logged was legitimate.
========================================
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

[Peter Clark]

On Sun, 29 Jan 2006 10:48:41 -0600, "Jim Macklin"
> wrote:

>At night, with no horizon and no moon you have actual
>instrument conditions.

FWIW, according to the old FAQ,

"I agree with your statement that just because a person is flying “. .
.. by sole reference to instruments . . .” has nothing to do with
whether the flight can be logged as “actual instrument time” or
“simulated instrument time.” Only the weather conditions establish
whether the flight is in “actual instrument conditions.” And that is
dependent on the weather conditions where the aircraft is physically
located and the pilot makes that determination as to whether the
flight is in “actual instrument conditions” or he is performing
instrument flight under “simulated instrument conditions.” But for a
“quick and easy” answer to your question, it was always my
understanding if I were flying in weather conditions that were less
than the VFR weather minimums defined in § 91.155 and I was flying
“solely by reference to instruments” then that was the determining
factor for being able log instrument flight under “actual instrument
conditions.”

Otherwise, if I were flying solely by reference to instruments in VMC
conditions then I would log it as instrument flight in “simulated
instrument conditions.” In your example, the flight is clear of clouds
and in good visibility conditions at night over the desert with an
overcast above and no visible horizon. But other examples could
include flight between sloping cloud layers or flight between layers
of clouds at night. These could equally meet the requirement for
operations that can only be accomplished solely by reference to
instruments. But, the lack of sufficient visual reference to maintain
aircraft control without using instruments does not eliminate the
possibility of collision hazard with other aircraft or terrain."

[Peter Clark]

On Sun, 29 Jan 2006 13:09:13 -0500, Ron Rosenfeld
> wrote:

>On Sun, 29 Jan 2006 14:40:00 GMT, bsalai > wrote:
>
>>Does anyone know if Simulated Instrument Conditions is defined anywhere?
>>
>>The reason for the question is whether one can log instrument time, say
>>at night, when you don't look outside, but don't wear foggles or a hood?
>>
>>I can't find anything in the rules that defines simulated instrument
>>conditions, but since the rule for logging instrument time says both
>>that flight has to be solely by referenct to instruments in actual or
>>simulated instrument conditions, that would suggest that more is
>>required than "solely by reference to instruments" and therefore that
>>some sort of view limiting device is required.
>>
>>It would certainly be easier if they defined simulated insturment
>>conditions though.
>>
>>Brad
>
>It is not defined in the regulations. But it was "defined" in a published
>FAA Chief Counsel legal interpretation some twenty or so years ago:
>
>==============================================
>--quoted text--
>First, you ask for an interpretation of Section 61.51(c)(4) of the
>Federal Aviation Regulations (FAR) regarding the logging of instrument
>flight time. You ask whether, for instance, a flight over the ocean on
>a moonless night without a discernible horizon could be logged as
>actual instrument flight time.
> ***
> As you know, Section 61.51(c)(4) provides rules for the logging of
>instrument flight time which may be used to meet the requirements of a
>certificate or rating, or to meet the recent flight experience
>requirements of Part 61. That section provides in part, that a pilot
>may log as instrument flight time only that time during which he or
>she operates the aircraft solely by reference to instruments, under
>actual (instrument meteorological conditions (imc)) or simulated
>instrument flight conditions. "Simulated" instrument conditions occur
>when the pilot's vision outside of the aircraft is intentionally
>restricted, such as by a hood or goggles. "Actual" instrument flight
>conditions occur when some outside conditions make it necessary for
>the pilot to use the aircraft instruments in order to maintain
>adequate control over the aircraft. Typically, these conditions
>involve adverse weather conditions.
> To answer your first question, actual instrument conditions may
>occur in the case you described a moonless night over the ocean with
>no discernible horizon, if use of the instruments is necessary to
>maintain adequate control over the aircraft. The determination as to
>whether flight by reference to instruments is necessary is somewhat
>subjective and based in part on the sound judgment of the pilot. Note
>that, under Section 61.51(b)(3), the pilot must log the conditions of
>the flight. The log should include the reasons for determining that
>the flight was under actual instrument conditions in case the pilot
>later would be called on to prove that the actual instrument flight
>time logged was legitimate.
>========================================
>Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Way for the FAQ from 7/05 and the Chief Council to say different
things on the exact same question! :)

[[email protected]]

Ron:

I wrote the chief counsel's office about fifteen years ago on this
issue of logging "black hole time" after a long dispute about it on
AVSIG.
They sent me a copy of the above - supporting my position that the
criterion was "solely by reference to instruments" as opposed to "IMC"
for the logging of instrument time.

Reminds me of a time flying VFR over the top at night and the
controller asking my flight visibility. I said about 250,000 miles.
After the silence, I said that all I could see was the moon.

[Ron Rosenfeld]

On Sun, 29 Jan 2006 13:20:29 -0500, Peter Clark
> wrote:

>Way for the FAQ from 7/05 and the Chief Council to say different
>things on the exact same question! :)

Chief Counsel trumps FAQ's.

But the Chief Counsel opinion seems to advise a complete description as to
the nature of the conditions, rather than just logging "actual"


"The log should include the reasons for determining that
the flight was under actual instrument conditions in case the pilot
later would be called on to prove that the actual instrument flight
time logged was legitimate."


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

[Ron Rosenfeld]

On 29 Jan 2006 11:17:44 -0800, wrote:

>Ron:
>
> I wrote the chief counsel's office about fifteen years ago on this
>issue of logging "black hole time" after a long dispute about it on
>AVSIG.
> They sent me a copy of the above - supporting my position that the
>criterion was "solely by reference to instruments" as opposed to "IMC"
>for the logging of instrument time.
>
> Reminds me of a time flying VFR over the top at night and the
>controller asking my flight visibility. I said about 250,000 miles.
>After the silence, I said that all I could see was the moon.


I've certainly experienced black hole time. I recall departing KPVC (on
Cape Cod) one overcast night in the winter. It was clearly VMC, but until
I got close to the shoreline N of BOS, I would not have been able to
control the airplane without reference to instruments.

I'll have to remember your celestial visibility comment, though. But if I
can see the stars, do I report in miles or light years? :-))


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

[David Cartwright]

"Jim Macklin" > wrote in message
news:4o6Df.69914$QW2.8391@dukeread08...
> About 20 years ago, the FAA in Wichita came up with a device
> to block the pilot's view forward on the King Air 300, which
> required a type rating and that the pilot be able to see the
> entire cockpit and reach all the controls. They developed
> and approved the use of a sheet metal device that was held
> on the glare shield by a spring clamp. There were two metal
> pieces attached in such a manner that the pilot could not
> see straight ahead but allowed the examiner to see at an
> angle through the pilot's windshield. The co-pilot and side
> windows were not covered at all.

We have something similar in our club's PA-28 - except we have a louvred
side-window cover as well, so that if you're right next to it, you can't see
out, but if you're in the other seat you can. Works very well, and is much
better than those lousy foggles.

Of course, there's nothing on the right-hand window; all you need there,
though, is a decent-sized instructor/colleague and the view through the
window can be amply blocked :-)

D.

[Matt Barrow]

> wrote in message
oups.com...
> Ron:
>
> I wrote the chief counsel's office about fifteen years ago on this
> issue of logging "black hole time" after a long dispute about it on
> AVSIG.
> They sent me a copy of the above - supporting my position that the
> criterion was "solely by reference to instruments" as opposed to "IMC"
> for the logging of instrument time.
>
> Reminds me of a time flying VFR over the top at night and the
> controller asking my flight visibility. I said about 250,000 miles.
> After the silence, I said that all I could see was the moon.

Moonless night over a cloud deck.

One that got my screwed up was fying along on top of a cloud deck that was
pitched at about a 30 degree angle -- pretty hard to override the
inclination to assume a flat deck below you.

Matt Barrow

[Jim Macklin]

About 40-50 years ago two airliners had a mid-air collision
over NYC, flying VFR between sloping cloud layers. They saw
each other and took evasive action visually, and had the
collision because they saw each other.


--
James H. Macklin
ATP,CFI,A&P

--
The people think the Constitution protects their rights;
But government sees it as an obstacle to be overcome.
some support
http://www.usdoj.gov/olc/secondamendment2.htm
See http://www.fija.org/ more about your rights and duties.


"Matt Barrow" > wrote in message
...
|
| > wrote in message
|
oups.com...
| > Ron:
| >
| > I wrote the chief counsel's office about fifteen years
ago on this
| > issue of logging "black hole time" after a long dispute
about it on
| > AVSIG.
| > They sent me a copy of the above - supporting my
position that the
| > criterion was "solely by reference to instruments" as
opposed to "IMC"
| > for the logging of instrument time.
| >
| > Reminds me of a time flying VFR over the top at night
and the
| > controller asking my flight visibility. I said about
250,000 miles.
| > After the silence, I said that all I could see was the
moon.
|
| Moonless night over a cloud deck.
|
| One that got my screwed up was fying along on top of a
cloud deck that was
| pitched at about a 30 degree angle -- pretty hard to
override the
| inclination to assume a flat deck below you.
|
| Matt Barrow
|
|

[Jose]

bsalai wrote:

> The reason for the question is whether one can log instrument time, say
> at night, when you don't look outside, but don't wear foggles or a hood?

If you are in visual conditions, somebody must be looking out the
window to avoid aluminum showers. If you are in the soup, then you are
in actual and the question is irrelevant. I hope you aren't really
asking whether or not you can go up alone in VMC and just "not look out
the window". Such an act would qualify one for a Darwin. :)

With an appropriate safety pilot, it is still important to not be
distracted by what is outside, which usually means some sort of view
limiting device. Too much peripheral information comes in otherwise,
and you are not really controlling the aircraft solely WRT instruments.

Jose
(alas posting from google until my computer comes back up)