Logging actual instrument time?

[siucavflight]

I guess then I should go back and record about 400 hours of actual instrument time in my logbook. Thanks.

 

[JeffSKDTW]

To both pilotmyf and siucavflight :

Logging actual instrument conditions at night, with no horizon or method of telling you what the plane is doing is 100% legal. There is no question about it and I've asked many senior flight instructors and 4 different examiners and they've all told me .. if its night, you can't see the horizon and you are 100% on the instruments to determine the status of the plane, you can log it as actual.

Ask on ProPilot's FAR forum. I'm sure you'll get the same answer from "Doc"

In fact, the legality of logging actual on a moonless night etc. stems from a legal opinion issued by the FAA Assistant Chief Counsel:

FAA Legal opinion, NOTE: FAR 61.51(c)(4) is now codified in 61.51(g), the concepts cited remain valid. the opinion has been edited for brevity:

"November 7 1984



Mr. Joseph P. Carr



Dear Mr. Carr:

This is in response to your letter asking questions about instrument flight time.



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.



Second, you ask for an interpretation of Section 61.57(e)(2) of the FAR, noting that Advisory Circular 61-65A, Certification: Pilots and Flight Instructors, seems to contain advice contrary to your understanding of the rule.



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.



[Answer to second question deleted due to not being pertinent to this discussion -- Doc]

Sincerely,

/s/

John H. Cassady

Assistant Chief counsel

Regulations and Enforcement Division"

 

[siucavflight]

Answers my question. I now have 476.4 actual instrument hours instead ofthe 82.3 that I used to have.


I am so glad that one mans opinion allowed me to do this.

 

[pilotmyf]

To both pilotmyf and siucavflight :

Logging actual instrument conditions at night, with no horizon or method of telling you what the plane is doing is 100% legal. There is no question about it and I've asked many senior flight instructors and 4 different examiners and they've all told me .. if its night, you can't see the horizon and you are 100% on the instruments to determine the status of the plane, you can log it as actual.

Ask on ProPilot's FAR forum. I'm sure you'll get the same answer from
"Doc"

You better make sure the chief pilot at your next job feels the same way about logging actual in severe clear. A guy flying in AZ with 100 actual and 1000 total time might send some red flags. All it takes is a little doubt about your logbook from an employer to get your butt eliminated from a job opprotunity. Last time I checked, examiners aren't big employers. PLAY THE GAME!!!!!!!, stay conservativeon your entries.

 

[midlifeflyer]

You better make sure the chief pilot at your next job feels the same way about logging actual in severe clear.

Yeah! Better makes sure that the chief pilot at you next job agrees with the FAA!

If not, you never know where else the operation disagrees with the FAA. Maybe maintenance? Maybe rule of flight? Maybe the weather conditions that are permissible. Maybe...

 

[midlifeflyer]

Answers my question. I now have 476.4 actual instrument hours instead of the 82.3 that I used to have.

Do you =really= have almost 500 hour of flight time in VMC during which you were unable to keep the airplane upright without your instruments?

Having been over water and in sparse unlit areas at night, I've never really had that problem.

 

[siucavflight]

Do you =really= have almost 500 hour of flight time in VMC during which you were unable to keep the airplane upright without your instruments?

Having been over water and in sparse unlit areas at night, I've never really had that problem.

I am not going to log it. I am going to keep logging my actual time as time when I was in weather less than VMC. I was being sarcastic.

I know many chief pilots at many different corporations, and if anyone walked in there and told them that they were logging instrument time when flying at night time in VMC they would laugh at them.

 

[labbats]

If you don't know up from down without your instruments, it's loggable. Otherwise, leave it alone. I've flown with too many old students with hundreds of hours IMC logged that were a handful in the soup, due to their version of "no-ground = no-VFR". VFR on top is not IMC.

 

[pilotmyf]

Yeah! Better makes sure that the chief pilot at you next job agrees with the FAA!

If not, you never know where else the operation disagrees with the FAA. Maybe maintenance? Maybe rule of flight? Maybe the weather conditions that are permissible. Maybe...

You're missing the point, if you want to be a cfi until you lose your medical, log all time as actual, nobody will care, you can tell all the hangar flyers about your thousands of hours of actual and watch their awe toward you. My guess is you have students that want 135/121 jobs. Don't screw them by telling them to log that questionable actual. Who cares what local FSDOs say about, they all have different opinions on many issues, and your student might be getting a job in a different FSDO area. Plus, Their prospective employers will laugh at them, and the excuse "MY instructor told me it was alright" will no doubt get a good belly laugh.

So here's the skinny, what is legal and acceptable is different (just like what is legal and what is safe). Legal to the FAA might not be acceptable to HR and the chief pilot. AND THEY HIRE YOU!!!!!!!!!!!!!!!!!!!!!!!!, not the FAA!!!!!!!!!!!!

 

[midlifeflyer]

Who cares what local FSDOs say about, they all have different opinions on many issues, and your student might be getting a job in a different FSDO area.

You're missing one small point. I wouldn't believe anything that a local FSDO told me on any regulatory issue. This isn't a FSDO interpretation.

It's an interpretation by the people who have the ultimate final word about what the FAR mean.

Besides, the rule doesn't permit pilots to log all or even most night flights as IFR. If a pilot with 3000 hours in his logbook came to me and said he had logged 400 hours actual in VMC, I probably wouldn't hire him. Without some real good explanation about the conditions that made him unable to keep the airplane upright in VMC so often, I'd think he was either lying or a =very= bad pilot.

Your HR issue is a legitimate one. But logging is an FAA data issue. Showing an employer that you have real experience is a presentation issue.