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#71
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"John R Weiss" wrote in message news:G2bUb.216614$I06.2379975@attbi_s01... 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. That's fine, but we're discussing what the regulation actually says. |
#72
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"John R Weiss" wrote in message news:qcbUb.91084$U%5.469867@attbi_s03... 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. 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. |
#73
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"John R Weiss" wrote in message news:6mbUb.221265$xy6.1135343@attbi_s02... According to "the FAA" (John D. Lynch, GENERAL AVIATION CERTIFICATION BRANCH, AFS-840): 'This goes back to earlier statement in Answer 1 where I said the weather conditions establish whether the flight is in "actual instrument conditions." And that is dependent on the weather conditions where the aircraft is physically located and the pilot makes that determination as to whether the flight is in "actual instrument conditions" or he is performing instrument flight under "simulated instrument conditions."' (Part 61 FAQ, 7/14/03, p. 99) Note: "the pilot makes that determination" Read the regulation. |
#74
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"Steven P. McNicoll" wrote...
That's fine, but we're discussing what the regulation actually says. IIRC, the original question was regarding the propriety or "legality" of logging approaches and/or instrument time. FAA Flight Standards has weighed in as saying it is up to the pilot to determine what to log in "questionable" circumstances. Since the bare regulations are unclear, it would be wise to follow the Flight Standards guidance. You can nitpick individual regs -- which have already been cussed, discussed, and re-interpreted ad nauseum -- all you want. However, that will not likely give any more useful information to the average pilot. Ultimately, it will be someone who represents Flight Standards who will accept or challenge the pilot's logbooks, not an Air Traffic Controller. |
#75
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"John R Weiss" wrote in message news:AFdUb.217912$I06.2383445@attbi_s01... IIRC, the original question was regarding the propriety or "legality" of logging approaches and/or instrument time. Ron Natalie wrote: "It is what the regs literally say. All they say is you have to be in instrument conditions. Doesn't say anything about flight rules. This was affirmed in the following opinion by FAA counsel." |
#76
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"Steven P. McNicoll" wrote...
That's fine, but we're discussing what the regulation actually says. IIRC, the original question was regarding the propriety or "legality" of logging approaches and/or instrument time. Ron Natalie wrote: "It is what the regs literally say. All they say is you have to be in instrument conditions. Doesn't say anything about flight rules. This was affirmed in the following opinion by FAA counsel." Ummm... The original referred directly to the lack of visible horizon during an instrument approach. The post was: ----- Original Message ----- From: "Ron Garrison" Newsgroups: rec.aviation.ifr Sent: Thursday, January 29, 2004 4:11 PM Subject: Logging approaches I had a 'first' last week, and I am looking for other peoples thoughts on this one. It was my first (I believe) loggable instrument approach in what was legally VMC. I was flying from the San Francisco bay area down to Burbank. The reported conditions were sky clear, visibility 4 miles in haze, with the ILS 8 in use, no mention of visual approaches. The visibility part was right, from about 4,000 feet down to the surface there was about 4 miles visibility based on when the runway appeared. I could see the ground below just fine the whole time, but looking forward there was no visible horizon. I considered the approach loggable because: 1) navigation aids were required to find the airport 2) There was no visible horizon so the attitude indicator was required to identify and maintain the desired aircraft attitude. Any differing opinions on this one? |
#77
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"John R Weiss" wrote in message news:36gUb.176434$sv6.932027@attbi_s52... Ummm... The original referred directly to the lack of visible horizon during an instrument approach. The post was: ----- Original Message ----- From: "Ron Garrison" Newsgroups: rec.aviation.ifr Sent: Thursday, January 29, 2004 4:11 PM Subject: Logging approaches I had a 'first' last week, and I am looking for other peoples thoughts on this one. It was my first (I believe) loggable instrument approach in what was legally VMC. I was flying from the San Francisco bay area down to Burbank. The reported conditions were sky clear, visibility 4 miles in haze, with the ILS 8 in use, no mention of visual approaches. The visibility part was right, from about 4,000 feet down to the surface there was about 4 miles visibility based on when the runway appeared. I could see the ground below just fine the whole time, but looking forward there was no visible horizon. I considered the approach loggable because: 1) navigation aids were required to find the airport 2) There was no visible horizon so the attitude indicator was required to identify and maintain the desired aircraft attitude. Any differing opinions on this one? Yeah, I read it. Threads evolve. |
#78
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"Steven P. McNicoll" wrote in message hlink.net... "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. The FAA counsel is also at odds with the regulation WRT 100 hour inspections acording to Natalie. I wonder if the FAA counsel understands the implications of the terms "gross negligence" and "restraint of trade". Much like the MIDO making a lubrication chnage for DC-9s for Kelly on "no basis". |
#79
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"Tarver Engineering" wrote in message ... .. The FAA counsel is also at odds with the regulation WRT 100 hour inspections acording to Natalie. I don't know where Tarver keep pulling this nonsense up. I never said that FAA counsel was at odds. What I said is that certain A&P schools and other non FAA types were at odds with the regulation. The regs and the FAA counnsel are clear that rental without flight instruction do not require 100 hour inspections. What I disagree with the FAA interpretations on is whether experimentals should be banned from flight instruction for hire. The 100 hour rules have very specific wording on flight instruction, the similar prohibition on carrying passengers for hire is missing from the experimental rules. It merely says you can't use experimentals for carrying passengers for hire. It's clear if you search back in google, that Tarver seems to be off in a world of his own when it comes to responding to anybody else's post. Why he's decided to pick on me today is unclear. |
#80
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It's in the FAR's. You can log actual IMC if you have to use the
instruments to fly the airplane. This can occur and you still meet VFR visibility requirements. For instance, between layers at night. You are in IFR conditions if you are flying and do not have the VFR minimums, ie 500 below, 1000 above and 2000 horizontal and 3 miles visibility in Class E below 10k etc. If you were less than 1000' above a cloud deck in Class E airspace you would be in IFR conditions and be navigating by looking outside, that is, NOT navigating by looking at the instruments. Thus you could not log actual IMC for this time. And yes, you can be legal IFR and not be on an IFR flight plan or have an IFR clearance. Class G airspace allows you to fly in IFR conditions without a clearance. You only need a clearance in CONTROLLED airspace (A,B,C,D and E). This is all USA of course other countries differ. Judah wrote in message . .. "Ron Natalie" wrote in : Yes, but immaterial. The weather can still be legal VFR, but bad enough to cause yout to fly solely by instruments. The FAA has affirmed this is legally logable as instrument time. Where'd they do that? |
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