Logging IFR in VMC

[V-1]

V-1,

Instead of making jest of Buzo's uncle and calling it b.s. instrument time, you could just admit that you're wrong. After all, you wouldn't need that one-line entry if you knew the reg to begin with. You make a good point about the interpretations though. Why aren't those published in the FAR/AIM?

If you'd read my earlier post, you'd see I quoted the reg., which seems quite black and white, word for word. I was not aware of the 18-year old interpretation that avbug referred to. I think I did admit I was unaware of that interpretation, and that an interpretation generally superceded written regulations. I remember thanking avbug for his information, but I might have just thought I did.

I'm waiting for someone to say now that they have an interpretation that allows them to log as multi-engine p.i.c. the time they spent working line service marshalling a twin into a parking spot.

My point was, if you have to question whether something is instrument experience, it probably isn't. If you log it as such you're just fooling yourself, which might get you killed someday. I'm probably a little overly-sensitive about the issue because I've seen a pilot get into weather beyond his capabilities and kill himself and an innocent passenger while I was holding, waiting my turn to follow him into that airport.

Anyhow, had I just come out and admitted I didn't know how to interpret a regulation that seemed to be black-and-white it wouldn't have been very entertaining, now would it? Poor Buzo's uncle got caught in the middle, for that I apologize.

Regards,
V-1

 

[jethro]

V1 - here's the quandary; as per your interpretation (and what I believed to be the case as well) you run into a scenario where a pilot is flying @ 6000 feet on an IFR flight plan in Class E with solid overcast below him with tops at 5800. So we have an IFR flight plan in IFR conditions, but of course it would be a sham to log as actual instrument time since it would be illegal not to have your head out of the cockpit scanning for traffic (making the horizon obviously discernable).

BTW - your interpretation of logging multi PIC is too strict. I just have a wood board in my backyard with two fans and a seat attached to it; works great and keeps you cool in the summer... fuel, maintenance, and insurance sure is a bitch ain't it?

 

[172driver]

Depends if those clouds are sloping, puffed up, smooth and flat, a layer above, etc. If you can't fly straight and level when all attitude instruments are covered up, you are in actual.

V-1,

Fair enough. Didn't mean to criticize you. I'm learning every day that the regs aren't what I thought them to be.

 

[Guam360]

V-1,

Are you logging "actual", now that you are flying an RJ at FL270 to BNA, clear and a million?

 

[A Squared]

V-1,

For some reason you insist on interpreting this as a "loophole" and "b.s" and now in your latest post, you are suggesting that logging time this way will get you killed "which might get you killed someday." ..... why stop there? it's probably fattening and will raise your cholesterol level too....
The logging of instrument time, whether simulated of actual, is to meet requirements for certification or currency. It is what it is: the amount of time you've spent controlling an airplane with no outside references, nothing more, nothing less. no loophole, no b.s., no "yer gonna get killed...."

If you really are flying the airplne without any outside references, log it. how would this be somehow inferior to time flown under the hood, or time spent in a cloud?

I log a fair amount of instrument time this way. I fly a lot in the wee hours of the morning over uninhabited country. On a dark moonless night with a high overcast, there's absoulutely nothing out there to provide an attitude reference, no stars, no lights on the ground, no nothing. You can stare as hard as you like at the windshield and all it will ever be is a cold, dark glass rectangle. If you stare at it long enough, eventually you will be upside down, because you should be looking inside at the instruments.

Yet you insist that even though I'm using nothing but the instruments, that this isn't instrument flight, and it's BS and will kill me. Perhaps you could explain how this time is somehow inferior to time under the hood, or time in clouds? As far as the clouds go, on one of these really dark nights you ofen have no idea whether or not you're actually in a cloud, nor do you care, it doesn't make any difference in how you fly. If it's a really dense cloud, sometimes you'll notice some moisture on the windshield, and the icing lights will reflect off the inside of the cloud. Other than that, it's the same inside or out of a cloud; there's nothing to see and you fly by instruments.

You're right, the regulation is pretty black and white. It says you may log instrument flight time when actual conditions require you to use the instruments to fly. It was you who attempted to add non-existent requirements about VFR minimums and Instrument Meteorological Conditions. If the FAA had intended for those to be factors, they would have written that into the regulation.

The interpretation doesn't change the regulation at all, it merely confirms that the words mean what they mean, nothing more. The interpretion was necessary as people have a tendancy to add more to it than is written in the words.

regards

 

[surplus1]

Fair enough. Didn't mean to criticize you. I'm learning every day that the regs aren't what I thought them to be.

172,

Hey, you've been doing pretty good holding your own. Don't be intimidated. Plain old common sense is often (but not always) a lot more important than some arguement about who knows what about which FAR.

Let's not forget that the FAR's are written by lawyers and so, by the way, are the interpretations of the FAR's. There has to be some semblance of order in what we do and the government has to have some means of controling the activity. The public needs some semblance of quantifiable safety. That's why we have all these rules. Much like the millions of "laws" that regulate every moment of our lives in just about everything that somebody somewhere can think of. Many are good and many are rules for the sake of rules.

An "intepretation" of an FAR is no more than the "opinion" of the FAA's legal counsel. It can and will be used against you if what you do is ever "questioned" legally, e.g., by some fellow that got hired by the FAA and works in a FSDO (thereby becoming an expert on all matters aeronautical). It is valid until some other FAA legal counsel comes along and interprets the same reg differently, which has happend.

Also, the reg may be "interpreted" by legal counsel a dozen times, but if the guy running that department in the FAA doesn't agree, he'll keep the "interpretation" on the back burner for years. A typical person who did that frequently was Anthony Broderick (Deputy Administrator) who has since retired. The world isn't perfect in General Aviation, Commercial Aviation or the FAA.
Don't lose sleep over it. Don't ignore the rules deliberately either.

This thing you all are arguing about is no big deal really. Frankly, who do you think really cares about the technical nuances of what you logged as instrument time? Nobody but you. Who gives a hoot whether you log an hour in a cloud or outside of a cloud? Nobody!!

Don't misunderstand, I comprehend why the question was asked and I'm not knocking the guy for asking it. Avbug, as usual, gave an accurate interpretation. So did the Uncle airline, excuse me "major" airline captain that's #15. If you can't keep the thing right side up without the gauges, it's instrument time. All of the other technicalities and rules and interpretations don't amount to much. You're either flying by reference to instruments or your're not. Common sense.

Do you need an Instrument Rating to fly by reference to instruments? NO you don't. I guarantee you the airplane doesn't have a clue as to what rating you have or don't have. If you know how to control by sole reference to instruments, then you do it. If you have a "rating" but you can't control the aircraft, what good will that do?

Now if you ask "do I need and instrument rating to fly by IFR", then obviously the answer is yes. Why? Because that's the law.

You log time because you need to do that to qualify for initial certificates and ratings. After you get them, you log time to qualify for additional ratings and to be able to prove "currency". You log time to meet somebody's requirements for a particular job. Once you have the job you want and the ratings you need, why do you need to log time at all. Truth is you really don't. Other than what you need to prove currency, you don't have to log at all if you don't want to.

Moral of all that BS. 1) Don't make a mountain out of a mole hill. 2) Use common sense, 3) Don't fly where you can't see or stay right side up without instruments, unless you know how to fly by instruments. 4) Log whatever you want.

As a rule of thumb, if you've logged more than 10% of your total time as actual instrument, be prepared to answer questions. It will only take a few moments in a simulator for a skilled evaluator to figure out if you're full of it or for real.

Meanwhile, enjoy flying. It used to be fun. Don't let the "experts" make it so complicated for you that it isn't.

 

[avbug]

What he said.

 

[V-1]

V-1,

Are you logging "actual", now that you are flying an RJ at FL270 to BNA, clear and a million?

Although we've (mostly I've) managed to make this regulation so grey that I could stretch it enough to cover that idea, I've got enough real actual instrument time that I rarely log any instrument time anymore.

I have to admit that I've always logged time, particularly instrument time, conservatively - even more conservatively than I thought, since I was unfamiliar with the 18-year old interpretation. I also failed to realize that I'd been interpreting 61.51 (g)(1)'s phrase "actual or simulated instrument flight conditions" as "instrument flight rules conditions", which is the closest written definition of "instrument flight conditions" (This entire thread has been about discussing the omission of one word - "rules".) I have been able to find - prior to seeing the 18-year old interpretation, which, as Surplus1 pointed out, will not keep you from being violated by some inspectors, if one wants to examine your logbooks. A non-instrument rated pilot will probably raise some eyebrows if he/she has a couple of hundred hours of actual instrument in their logbook. Sure, you'll probably win the case ultimately, but at what expense? I don't see how it's worth the hassle.

I've also seen relatively low-time pilots, as I once was, get in over their head when serious weather rolls in. No matter what definition you use to log instrument time, flying along in cruise flight at 6500 feet VFR using the instruments as necessary to keep the airplane upright with no significant altitude, heading, and course tolerances to follow is not the same as flying an ILS to landing through fog with weather conditions 100 & 1/2. I've seen an instrument-rated pilot who was in over his head kill himself and a passenger in these conditions. If you have a 300-foot altitude deviation, or a one mile course deviation in the first situation, it doesn't matter - except to your pride. In the second scenario, you'd probably find yourself and your aircraft strewn over a few acres.

The difference between the two scenarios is that the VMC pilot logging actual will see the airport when he/she gets there, probably a few miles before they get there. That's worth a nice, fuzzy feeling. The guy flying through IMC conditions very well may not. There is, in my opinion, a night and day difference between two legally loggable "actual" scenarios - despite the fact that the interpretation allows both scenarios to be logged as "actual". Warning-I'm going to try another attempt at humor here...Perhaps what I need is to start another column in my logbook. I now will log "simulated", "actual", and "actual as clarified by John H. Cassady, Assistant Chief Counsel, which doesn't necessarily mean IMC and should not be construed as such" I can see now I'm going to have to order a custom-made logbook in order to fit that title into the column.

As Surplus1 said, "Log whatever you want." Just be careful it doesn't give you a false sense of confidence. That's when flying becomes dangerous. For A Squared, it's not the logging of actual instrument time by anyone's definition that "will get you killed" (my quote), what "will get you killed" is not putting the experience you do have into the proper perspective. I'm sure the participants in this discussion are all wise enough to do that. I know of one pilot who wasn't. He and his passenger, oblivious to the danger, paid the ultimate price.

If you really are flying the airplne without any outside references, log it. how would this be somehow inferior to time flown under the hood, or time spent in a cloud?

I'd agree that flying the airplane without any outside references is closer to, and better experience than flying under the hood, which can only be logged as simulated instrument time (unless, of course, you're wearing a hood while flying in actual because you're scared to see the inside of cloud, or some other strange reason).

I hope this further explains my opinion, but I suspect it won't. Thanks to all of you for helping me see that "IFR conditions" are not the same as "instrument flight conditions".

P.S., I'm still p1ssed about all the multi-engine p.i.c. I didn't know I could log while marhalling twins in at my old line service job!

Regards,
V-1

 

[A Squared]

V-1

>>>>>This entire thread has been about discussing the omission of one word - "rules".


Yep, to a large degree this is true. Whether you beleive as I do that the original intent was to include *any* time that you are flying by instruments or you believe as you seem do that the original intent was to only include time in IMC or IFR conditions, the end result is the same, the regulation doesn't include the word "rules" and so it has to be read without that word. Often legal issues come down to exactly that: the inclusion or omission of one word.

I think that initially, you made the mistake of reading the regulation with what *should* be, or what you think makes sense in your mind, and as a result, read something in that wasn't there. I've certainly done the same thing myself in other cases, it's human nature.



>>>>>No matter what definition you use to log instrument time, flying along in cruise flight at 6500 feet VFR using theinstruments as necessary to keep the airplane upright with no significant altitude, heading, and course tolerances to follow is not the same as flying an ILS to landing through fog with weather conditions 100 & 1/2.


Well, yes, I would certainly agree that flying an approach is much more demanding than flying enroute, but what of it? If you look at anyone's logbook, thier instrument time will include some time enroute. Perhaps we should only log instrument time inside the IAF? Or perhaps we should have 2 columns in our logbook, instrument time enroute, and instrument time on approach?

Just to clarify, the operations I am speaking of are IFR, on IFR clearences, at IFR altitudes and we're not always assured of getting a visual at our destination, and yes, we do in fact fly ILS's to a landing at 100 & 1/2.


regards

 

[surplus1]

V-1, et al.

Here's a "war story" that relates to what we're talking about and, I think, makes it clear why flight in instrument conditions is
"instrument time", regardless of the weather, or the FAR's. or legal counsel, or the bible according to Chuck Yeager or Bob Hoover, or Orville and Wilbur, etc.

This is a true story. I won't name the airline or the location, but it happened.

The airport is in the suburbs of a medium sized city but on the outskirts, where there is not much lighting. There is one runway, more than 10,000 feet long. We will say it's Rwy 18/36. The approach to 36 is over land, with a full ILS, etc. The approach to 18 is over the ocean. The threshold of 18 is less than 1,000 feet from the cliffs that mark the end of the ocean and the begining of the land. No approach lights. Just some lead lights, red warning lights on the cliffs and a PAPI.

The airplane is a DC-9-51 operated by a scheduled airline with an experienced flight crew. But, both crewmembers are new to the DC-9 and this is their first scheduled flight in the type after training. It is night time. There is no moon. The official weather is CAVU. There are 120 px on board and a crew of 5. The aircraft is new and there is not even one deferred item. Rwy 36 is the active.

Cleared for TO, the aircraft rolls. It is heavy (long flight) and uses a lot of runway but there is still about 3,000 ft left . Rotation is normal, lift off, over the end of 18 climbing with a body angle of about 20 degrees. It crosses the shoreline and forward and peripheral visibility outside goes to zero instantly. Cockpit lights are full on, white. Thirty seconds later, the aircraft strikes the water and buries itself in 800 ft of ocean. All hands lost.

Probable cause, confirmed by tapes and recorder. Flight crew attempting to maintain control by visual reference in "instrument conditions" lost control of the aircraft and flew it into the ocean.

Maybe they should not have been "logging" instrument flight time. But there is no doubt that they should have been flying by reference to instruments only and the flight conditions were IMC, even though there wasn't a cloud within a hundred miles and the visibility was officially and actually, unlimited.

Did they know how to fly by instruments? You bet they did, but they just weren't doing it. Now put a pilot with no instrument qualifications in the same situation in a light aircraft and where do you think that airplane will wind up when it leaves the shoreline?

What the reg says, who interprets it or how it is interpreted, what the FSDO thinks, or the #15 airline captain, or me, or you or even avbug (pun intended), don't amount to a hill of beans. If you can't see out and you can't stay right side up without seeing out, or if you can see out, but what you can see is not adequate for control, you had better be flying on the clocks or the glass. Anytime you're doing that, it is instrument time. Log it, and be happy you got the thing on the ground to where you can.

Fly safe.

PS. If you happen to know any Naval aviators, ask them when the US Navy says they can officially log instrument time.

PSS. The first time you cross the pond in the dark, let me know if yout think crusing at 330 is instrument time or not. After you get to the other side that is.