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#61
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"Steven P. McNicoll" wrote...
The rule does not say that. The rule says, ""A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions." So, literally, it must be below VFR minimums or you must wear a hood. Not quite... The FAA maintains a "Part 61 FAQ" at http://www.faa.gov/AVR/AFS/AFS800/DOCS/pt61FAQ.doc, which addresses "Frequently Asked Questions on 14 CFR Part 61 and represents FAA Flight Standards Service policy as it relates to this regulation." In the Mar 30, 2000 version I found the following, starting on p. 50 (page 98 in the latest, which I just downloaded): QUESTION 1: The question came up about logging "actual" instrument time when over the desert at night with no visual references. When you are flying with sole reference to instruments, is that actual time? If not, is it "simulated" instrument time? Our take on the question is actual instrument time can only be logged when the aircraft is in IMC. The weather determines actual instrument time, not flying by sole reference to instruments. That settles the actual instrument question, but what about "simulated" instrument time? Our feeling is it can be logged as "simulated instrument time." It would be the same as having a hood on while flying by sole reference to instruments. What about the requirement for a safety pilot under these conditions? Our answer is "no" because the pilot is still able to "see and avoid" conflicting traffic. .. . . 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. .. . . Normally, in order to log instrument flight time under "simulated instrument conditions," the pilot needs to be utilizing a view limiting device. But, the only place in the rules requiring a view limiting device will be found under §61.45(d)(2) as part of the equipment for a practical test. Otherwise, no where else in the rules, orders, bulletins, or advisory circulars does it specifically state that pilots need to be utilizing a view limiting device. But, except for meteorological conditions as in our examples above, how else, could a pilot comply with §61.51(g) for logging instrument flight time [i.e., ". . . when the person operates the aircraft solely by reference to instruments . . ."] unless the pilot was utilizing a view limiting device when logging instrument flight time in simulated instrument conditions? QUESTION 3: I have not been able to find a definition of "actual" conditions in the FARs or the AIM, but I believe that the definition of actual is somewhat more restrictive than IMC. Please confirm that the following is correct: Is IMC is simply visibility’s, clearances from clouds, and ceilings less than the minima for VMC (AIM -pilot controller/glossary) "Actual" requires that the pilot be flying the airplane solely by reference to instruments, which means he must be either completely in the soup (i.e. zero-zero) or in conditions which provide no horizon reference of any kind. Therefore, being in IMC conditions is not always adequate for logging actual. ANSWER 3: Ref. §61.51(g); As previously answered above in Answer 1 above, there is no official FAA definition on "actual instrument time" or "simulated instrument time" in the FARs, FAA Orders, advisory circulars, FAA bulletins, etc. Part 61 merely refers to the instrument time in reference to aeronautical experience to be ". . . instrument flight time, in actual or simulated instrument conditions . . ." Otherwise the reference is merely instrument flight time, in actual or simulated instrument conditions. Now the term "actual" in reference to instrument conditions that require operations to be performed solely by reference to the aircraft instruments are sometimes subjective. No question that "actual" instrument conditions exist with flight in clouds or other phenomena that restrict visibility to the extent that maintaining level flight or other desired flight attitude, can only be accomplished with reference to the aircraft instruments. This goes back to earlier statement in Answer 1 where I said 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." Your realization that "IMC" and "VMC" and also, in fact, "IFR" and "VFR" are not necessarily related to "actual" conditions is accurate. These terms are used with respect to airspace operating requirements. Per §91.155, a flight may be in IMC (requiring IFR operations) with four (4) miles visibility in Class E airspace above 10,000'MSL (more than 1,200'AGL), but still be in VMC (allowing VFR operations) with only one (1) mile visibility in Class G below 10,000'MSL during day time, . That is why none of these terms were used in §61.51(g) to describe when we may or may not log instrument flight time. IMC and VMC are used in association when describing airspace weather conditions. VFR or IFR are used to describe operating requirements [i.e., §91.173 requiring IFR flight plan for operating in controlled airspace under IFR, §691.169 information required for operating on an IFR flight plan; §91.155 basic VFR weather minimums, etc]. QUESTION 4: As far as logging an approach in actual, is there any requirement (i.e. must it be in actual conditions beyond the final approach fix)? Assume that the pilot was flying single-pilot IFR so he couldn't simply put on the hood if he broke out? ANSWER 4: §61.51(g)(1) and §61.57(c)(1)(i); Again the only place where it defines logging "instrument flight time" means ". . . a person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments . . . ." As for logging an "actual" approach, it would presume the approach to be to the conclusion of the approach which would mean the pilot go down to the decision height or to the minimum decent altitude, as appropriate. If what you’re asking is whether it is okay to fly to the FAF and break it off and then log it as accomplishing an approach, the answer is NO. |
#62
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"Steven P. McNicoll" wrote...
The FAA affirms that there are times when you can be technically above VFR minimums (not in the clouds and sufficient visibility), but the horizon and the ground is obscured and those qualify for actual instrument conditions, even though it's not bad enough to require IFR. Which is literally contrary to the FARs. How is it contrary to the FARs (and which ones)? The weather is not subject to FARs, and neither is an individual pilot's real-time ability to maintain level flight -- he either CAN do so by means of outside references, or he CANNOT; and that may change dynamically. |
#63
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"Gary Drescher" wrote...
That's self-contradictory, because the FAA explicitly defines "IFR conditions" as conditions that do NOT meet the VFR visibility requirements (AIM Pilot/Controller Glossary). .. . .which isn't regulatory in nature (i.e., not a part of the FARs). |
#64
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"John R Weiss" wrote in message news:rcbUb.91085$U%5.470879@attbi_s03... "Gary Drescher" wrote... That's self-contradictory, because the FAA explicitly defines "IFR conditions" as conditions that do NOT meet the VFR visibility requirements (AIM Pilot/Controller Glossary). . . .which isn't regulatory in nature (i.e., not a part of the FARs). And it makes no difference because the rule says "instrument conditions" not IFR conditions. |
#65
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"Steven P. McNicoll" wrote...
'IFR conditions' and 'instrument conditions' are not necessarily the same thing. How do they differ? According to "the FAA" (John D. Lynch, GENERAL AVIATION CERTIFICATION BRANCH, AFS-840): 'This goes back to earlier statement in Answer 1 where I said the weather conditions establish whether the flight is in "actual instrument conditions." And that is dependent on the weather conditions where the aircraft is physically located and the pilot makes that determination as to whether the flight is in "actual instrument conditions" or he is performing instrument flight under "simulated instrument conditions."' (Part 61 FAQ, 7/14/03, p. 99) Note: "the pilot makes that determination" |
#66
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"Eclipsme" wrote in message ... I don't think so. Think about being in multiple solid, sloping layers. No horizon at all. More than VFR viz, but definitely IFR. Not according to the regulation. |
#67
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"John R Weiss" wrote in message news:rcbUb.91085$U%5.470879@attbi_s03... . . .which isn't regulatory in nature (i.e., not a part of the FARs). This is: Title 14--Aeronautics and Space CHAPTER I--FEDERAL AVIATION ADMINISTRATION, DEPARTMENT OF TRANSPORTATION PART 1--DEFINITIONS AND ABBREVIATIONS § 1.1 General definitions. IFR conditions means weather conditions below the minimum for flight under visual flight rules. |
#68
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"Ron Natalie" wrote in message . .. And it makes no difference because the rule says "instrument conditions" not IFR conditions. Same thing. |
#69
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"John R Weiss" wrote in message news:wBaUb.220881$xy6.1133716@attbi_s02... ...OR you could just as easily have better than 3 miles visibility, 1,000' clearance from the clouds, and NO way to determine the horizon from outside reference: cumulus in the distance, towering cumulus in the area, sloped tops of stratus in a front... Yes, you can easily have that, but that is not IFR conditions. |
#70
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"Ron Natalie" wrote in message . .. According to the FAA counsel, it just means conditions that require you to fly on instruments. The FAA counsel is at odds with the regulations. |
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