logging actual while not instrument rated

[TMetzinger]

From another post:

I completely agree with this. I also think that it's a good idea for non-IR pilots to fly in actual with IR pilots (even though the time can't be logged) because it is good experience. I've done this a couple of times with my mentor, who has his IR.

Actually, the time CAN be logged. A non-instrument rated pilot may log time in actual, and even act as PIC in some circumstances where he'd also log actual.

A non IR pilot cannot ACT as PIC under IFR. That's the limitation.

So, some examples - you're a rated pilot, but not instrument rated:

If you're up flying with an instrument rated pilot who is acting as PIC, and he lets you fly the airplane in actual - you can log it as actual AND PIC. If the rated pilot is a CFII and giving you instruction, you can also log Dual Received.

If you're up flying solo, and you run into a cloud and escape, or run into other conditions (moonless night, or over water) where you have to use the instruments to maintain control of the airplane, you can log that as actual and PIC.

It's a good idea to log the circumstances of the flight so that you can remember why you were logging the time as actual.

 

[dmccormack]

If you're up flying solo, and you run into a cloud and escape, or run into other conditions (moonless night, or over water) where you have to use the instruments to maintain control of the airplane, you can log that as actual and PIC.

It's a good idea to log the circumstances of the flight so that you can remember why you were logging the time as actual.

Tim,

While the letter of the law (and I think it's more loophole than intent) may permit this, VFR-only pilots (and non-current instrument pilots) shouldn't be in actual, period.

If the log-able time is more than 30 seconds (or however much time it takes to do a 180), there's some serious 'splainin to do.

Here's a good ASF Report on Spatial Disorientation.

 

[mantakos]

If the log-able time is more than 30 seconds (or however much time it takes to do a 180), there's some serious 'splainin to do.

I presume the "splanation" is "I was flying with my instructor, who is a CFII, under an IFR flight plan. I know that I am not qualified to act as PIC under those conditions, but my CFII was acting as PIC. I understand the difference between logging and acting PIC, and so I correctly logged that time as 'actual instrument', PIC, and flight instruction received".
-harry

 

[dmccormack]

I presume the "splanation" is "I was flying with my instructor, who is a CFII, under an IFR flight plan. I know that I am not qualified to act as PIC under those conditions, but my CFII was acting as PIC. I understand the difference between logging and acting PIC, and so I correctly logged that time as 'actual instrument'".
-harry

If you're up flying solo, and you run into a cloud and escape, or run into other conditions (moonless night, or over water) where you have to use the instruments to maintain control of the airplane, you can log that as actual and PIC.

I was referring to that occasion.

I hope you would log the IMC with a CFII, as either Simulated or Actual is acceptable/ required for the IR.

 

[TMetzinger]

Let me start by saying that I agree that what is safe, what is smart, and what is in compliance with regs are three different things.

I agree that a cloud encounter should be exited with the 180 we're all taught. And I agree that flying by instrument reference should be left to those who've been trained. And I'm familiar and agree with the stats on spatial disorientation.

The night and overwater flying is a little grayer - I could certainly consistently keep the airplane upright on instruments after about 10 hours of instrument training, and long before I completed the rating. The rating is, after all, about both controlling the airplane by instrument reference, AND about operating in the IFR system. One could be perfectly competent at one and not the other.

And flying with an appropriately rated and current pilot? To me that's perfectly acceptable, and the PIC's call to make. It's gravy if the PIC is an instructor and it becomes loggable as dual, but not required. I was ferrying an airplane for a friend of mine last month as he isn't yet instrument rated. We took off on an IFR plan, I put on the hood (he was safety pilot), and we were VFR for about 12 minutes before we went in the clouds. I took the hood off and we continued, and I let him fly a bit when we were established in cruise. I was in the left seat, he was an instrument student past his first phase check, and he did just fine maintaining altitude and making the turns necessary on our routing. So he got to log some SIC time as a safety pilot, and some PIC/Actual time as well on that trip.

So I'm not endorsing the idea that a non-IR pilot should go out and find some actual. I was just pointing out that there are circumstances (some very risky, some very safe) where a non-IR pilot can both experience AND LOG actual instrument time.

 

[mantakos]

I was referring to that occasion.

You're absolutely right. I didn't notice the specifics of the quote that you were responding to. Too much writing, not enough reading, on my part.
-harry

 

[dmccormack]

So I'm not endorsing the idea that a non-IR pilot should go out and find some actual. I was just pointing out that there are circumstances (some very risky, some very safe) where a non-IR pilot can both experience AND LOG actual instrument time.

I think the only time it should be logged is when it was intended (such as dual, etc).

I've flown with a pilot who claims he "has flown in the clouds plenty" has no IR, and can barely keep the localizer needle centered for more than 30 seconds. Glideslope? Don't even ask...

Flying IFR is about self discipline and instrument interpretation, as well as flying in the weather and ATC systems.

Flying in the dark and referencing the panel is a good start, but it's not Instrument Flying.

I'm being pretty adamant on this point because I think the continued VFR into IMC accident rate is clear evidence that too many VFR pilots think their few brushes with "Instrument flying" adequately prepares them for an encounter with IMC.

It doesn't.

 

[poadeleted20]

If you're up flying solo, and you run into a cloud and escape, or run into other conditions (moonless night, or over water) where you have to use the instruments to maintain control of the airplane, you can log that as actual and PIC.

While this is true, it would be unwise to create a legal admission of wrongdoing by logging the inadvertent encounter with the cloud. The "moonless night" scenario (in which you would be legal as it's still legal VMC) would be another story.

 

[TMetzinger]

Good point - but a cloud encounter at night is forgivable in my mind, you can't see the sucker in the dark, if it's an isolated cloud. Now if it's part of an overcast that's something else entirely.

 

[poadeleted20]

I think the only time it should be logged is when it was intended (such as dual, etc).

Keep in mind that one can be in actual instrument conditions without being in IMC, e.g., the "moonless night" scenario. Thus, it is entirely possible for a non-IR pilot to be in actual instrument conditions legally, and safely. There's no reason not to log the time in such a situation as "actual instrument" time, and the FAA Chief Counsel's office has said so.

That said, it is also possible to have a totally unsatisfactory result in such a situation, like JFK Jr., who apparently encountered actual instrument conditions in VMC on his final flight but did not handle it well enough to survive.

 

[poadeleted20]

Good point - but a cloud encounter at night is forgivable in my mind

Perhaps, but I fear the FAA would not be as understanding if they read about it in your logbook. Caveat aviator.

 

[redcloud]

What is the purpose or need to log, even if legal to do so, these odd situations. They don't add to your currency or and probably add little to your proficiency. If your earn the rating, use prudent judgement, and FLY; you will accumulate plenty of useful time for your precious logbook. Besides, do you really want to explain those esoteric entries to an examiner at a future test for a new rating?

Scott

 

[dmccormack]

Keep in mind that one can be in actual instrument conditions without being in IMC, e.g., the "moonless night" scenario. Thus, it is entirely possible for a non-IR pilot to be in actual instrument conditions legally, and safely. There's no reason not to log the time in such a situation as "actual instrument" time, and the FAA Chief Counsel's office has said so.

That said, it is also possible to have a totally unsatisfactory result in such a situation, like JFK Jr., who apparently encountered actual instrument conditions in VMC on his final flight but did not handle it well enough to survive.

Exactly the incident that comes to mind when discussing VFR at night.

I took a student out over the ocean last week at night and faced due east, then said, "OK, open your eyes and fly."

No horizon, no references.

 

[dmccormack]

Keep in mind that one can be in actual instrument conditions without being in IMC, e.g., the "moonless night" scenario. Thus, it is entirely possible for a non-IR pilot to be in actual instrument conditions legally, and safely.

"Legally" -- yes.

"Safely" -- I'm not so sure.

I tend to agree with a mentor CFI I've flown with who says night flying is instrument flying, and should be approached that way.

Short little VFR tours over well-lit areas are one thing, but XC over unlit tracts are something completely different.

 

[gismo]

I presume the "splanation" is "I was flying with my instructor, who is a CFII, under an IFR flight plan. I know that I am not qualified to act as PIC under those conditions, but my CFII was acting as PIC. I understand the difference between logging and acting PIC, and so I correctly logged that time as 'actual instrument', PIC, and flight instruction received".
-harry

Hard to do that solo.

 

[sba55]

Tim,

While the letter of the law (and I think it's more loophole than intent) may permit this, VFR-only pilots (and non-current instrument pilots) shouldn't be in actual, period.

That's a generalization that doesn't apply to everyone. I may have been in actual IMC, by myself (never intentionally, obviously), at night, for 30 minutes at 70 hours or so. Lots of pilots can do this. Any VFR pilot ought to be able to fly straight in level in IMC, IMO.

-Felix

 

[Henning]

Tim,

While the letter of the law (and I think it's more loophole than intent) may permit this, VFR-only pilots (and non-current instrument pilots) shouldn't be in actual, period.

If the log-able time is more than 30 seconds (or however much time it takes to do a 180), there's some serious 'splainin to do.

Here's a good ASF Report on Spatial Disorientation.

Don't see how you're figuring that. I did a good bit of my IFR training in actual, and even before that, I did a good bit of flying through actual with an old timer I used to fly with. What's the problem?

 

[SkyHog]

That's a generalization that doesn't apply to everyone. I may have been in actual IMC, by myself (never intentionally, obviously), at night, for 30 minutes at 70 hours or so. Lots of pilots can do this. Any VFR pilot ought to be able to fly straight in level in IMC, IMO.

-Felix

Agreed, 100%. As a pilot that flew most of his hours between 80 and 150 at night, I don't think I ever lost my bearing flying because I had no horizon. If I had, I would have fallen back on my training or admitted to ATC that I was screwed.

But it never happened. Why? Because its not hard to fly straight and level on instruments.

 

[dmccormack]

Don't see how you're figuring that. I did a good bit of my IFR training in actual, and even before that, I did a good bit of flying through actual with an old timer I used to fly with. What's the problem?

Were you solo in IMC prior to the IR?

 

[dmccormack]

I don't think this discussion is heading in the right direction. As I was reminded on another thread, some read these posts and learn from them.

In that case I want to be 100% clear (and on the record!).

Non-Instrument Rated (not just "trained" -- rated -- "passed the test and have the certificate") pilots or IR pilots who are not current (legally or otherwise) should not fly Actual -- moonless night, in the clouds, duct tape over the windscreen -- whatever.

Period, End of Story.

(If that's not clear enough....)

IF you think you have the ability and proficiency -- get the rating.

IF you have a need to fly in those conditions, -- get the rating.

IF you think you can fly that stuff and what's the big deal it's not so hard I do it all the time in Flight Sim --get the rating.

And if you have the rating, fly in actual or at the very least under the hood often enough to stay proficient.

Not convinced? read this.

Or This.

Or This.

The Fatal Accident Record speaks loudly and clearly if you remain unconvinced, search The NTSB accident database for "non-instrument rated private pilot"

Don't fly actual unless you have been trained and proven proficient.

 

[poadeleted20]

"Legally" -- yes.
"Safely" -- I'm not so sure.

I am, because it's done all the time. The question is how well the pilot was trained on basic instrument work during PPL training, and whether s/he practices it enough. As always, what is safe for one pilot may not be safe for another, so there's no fixed answer, and that's why I said, "it is entirely possible...," not "it is..."

 

[dmccormack]

I am, because it's done all the time. The question is how well the pilot was trained on basic instrument work during PPL training, and whether s/he practices it enough. As always, what is safe for one pilot may not be safe for another, so there's no fixed answer, and that's why I said, "it is entirely possible...," not "it is..."

I think there's a tendency to overestimate one's skills, and in this case, that has continuing fatal consequences.

 

[TMetzinger]

Dan - if the point of our regulations was to completely maximize safety, then night VFR flying would be prohibited. Hell, flying single pilot, single engine, non-turbine.... would all be prohibited

Fortunately, the rules allow the Pilot in Command to exercise his judgement. While I agree that flying at night increases risk, I don't agree that we should eliminate it from the list of discretionary activities a private pilot may enjoy.

I also have to take exception to your "I don't think this thread is headed in the right direction". That implies that you know what the "right" direction is, and anyone who disagrees is wrong. And when talking about aviation, right and wrong are not clearly defined. The best we can come up with is "in compliance" and "not in compliance" with the regs, and even THAT isn't crystal clear sometimes. In my opinion, one of the things that makes private aviation in this country so special is the freedom it gives pilots to exercise their judgment. As long as the activity doesn't pose a blatant threat to anyone except the knowing/willing participant, it's permitted. Start involving paying passengers and other "unknowing" participants, and the rules get tighter.

I think flying in conditions where you would reasonably expect to have to control the airplane solely by reference to instruments when you are not instrument rated is risky. However, that's not the same as saying that if you do end up in that situation, you can't log the time. You can, which was the point of this thread to begin with.

 

[dmccormack]

Dan - if the point of our regulations was to completely maximize safety, then night VFR flying would be prohibited. Hell, flying single pilot, single engine, non-turbine.... would all be prohibited

Fortunately, the rules allow the Pilot in Command to exercise his judgement. While I agree that flying at night increases risk, I don't agree that we should eliminate it from the list of discretionary activities a private pilot may enjoy.

I also have to take exception to your "I don't think this thread is headed in the right direction". That implies that you know what the "right" direction is, and anyone who disagrees is wrong. And when talking about aviation, right and wrong are not clearly defined. The best we can come up with is "in compliance" and "not in compliance" with the regs, and even THAT isn't crystal clear sometimes. In my opinion, one of the things that makes private aviation in this country so special is the freedom it gives pilots to exercise their judgment. As long as the activity doesn't pose a blatant threat to anyone except the knowing/willing participant, it's permitted. Start involving paying passengers and other "unknowing" participants, and the rules get tighter.

I think flying in conditions where you would reasonably expect to have to control the airplane solely by reference to instruments when you are not instrument rated is risky. However, that's not the same as saying that if you do end up in that situation, you can't log the time. You can, which was the point of this thread to begin with.

Tim,

I understand your point and you are correct. I don't want to live in a risk-free, Nanny-run world either.

But I think there were a few posts that seemed to indicate that "it's OK to fly actual VFR -- I do/did it all the time."

There "risk tolerance" and there is "stupidity."

Everyone can make his/her own judgment, but list me in the "Flying actual when not Instrument rated and current is stupid" crowd.

For the record:

• VFR-into-IMC is the number one cause of fatal GA accidents
• A VFR-into-IMC accident occurs (on average) once a week in the US
• OVER 80% of the VFR-into-IMC accidents result in fatalities

Dan

 

[flyingcheesehead]

That's a generalization that doesn't apply to everyone. I may have been in actual IMC, by myself (never intentionally, obviously), at night, for 30 minutes at 70 hours or so. Lots of pilots can do this. Any VFR pilot ought to be able to fly straight in level in IMC, IMO.

What's going to keep them from flying into other VFR pilots in IMC? Worse yet, what's going to keep them from flying into the IFR rated, current, and cleared pilots who are in IMC?

 

[TMetzinger]

In the kind of IMC we're talking about, seeing other airplanes isn't the problem - visibility is often GREAT. But what's missing is a horizon - you're over mountains , or over water, and there's no moon - you may be able to see for a gazillion miles, but you can't trust the horizon you might see.

 

[dmccormack]

In the kind of IMC we're talking about, seeing other airplanes isn't the problem - visibility is often GREAT. But what's missing is a horizon - you're over mountains , or over water, and there's no moon - you may be able to see for a gazillion miles, but you can't trust the horizon you might see.

Actual is flight "Solely by reference to the instruments," and, in those cases, I suppose the argument could be made that VFR is "safe" in "Actual."

My concern is the slippery slope that leads to overconfidence and eventual disorientation when real, inside-the-clouds IMC is encountered.

IMHO, VFR-only pilots should not be flying in those conditions. True, it's only an opinion, but the abysmal fatality record (once a week) supports my opinion.

 

[midlifeflyer]

My concern is the slippery slope that leads to overconfidence and eventual disorientation when real, inside-the-clouds IMC is encountered.

IMHO, VFR-only pilots should not be flying in those conditions. True, it's only an opinion, but the abysmal fatality record (once a week) supports my opinion.

I don't think you'll get too much disagreement about VFR flight into clouds or low visibility conditions that due to weather and similar phenomena and I don't think anyone here has suggested that a VFR pilot flying into those conditions is a good idea.

But I'm not too sure about "slippery slopes" from night VFR in remote or other areas where there are few good visual references under an overcast down to VFR flight into IMC. I think the perception of whether there is a problem there or not is pretty pilot and geographic specific. My WAG is that pilots who are trained in or encounter those conditions regularly are more attuned to what it takes to fly safely in them than those who are not.

 

[dmccormack]

I don't think you'll get too much disagreement about VFR flight into clouds or low visibility conditions that due to weather and similar phenomena and I don't think anyone here has suggested that a VFR pilot flying into those conditions is a good idea.

But I'm not too sure about "slippery slopes" from night VFR in remote or other areas where there are few good visual references under an overcast down to VFR flight into IMC. I think the perception of whether there is a problem there or not is pretty pilot and geographic specific. My WAG is that pilots who are trained in or encounter those conditions regularly are more attuned to what it takes to fly safely in them than those who are not.

I respectfully -- but wholeheartedly -- disagree.

Fatal VFR into IMC is almost always the result of continued flight into deteriorating conditions.

Several key facts point to the slippery slope:

• Very rarely do VFR-only pilots launch into IMC (though some do)
• Very few VFR-into-IMC fatalities are Student or Low time pilots

This appears to indicate a much greater respect for marginal weather/ conditions for these pilot subgroups. This respect apparently wanes as more experience is gained.

While there are no metrics to support a supposition that VFR pilots "get away with" an encounter with IMC or near-IMC conditions and thereby develop false confidence, but common sense points to this all-too-common human trait as a key causal factor.

If we get away with it once, we're more likely to push and expect to get away with it the next time.

Another factor is that 10 hours under the hood 6 years ago while preparing for the PP does not make one current on the gauges today. Even IFR pilots (should) know that instrument flying is a perishable skill that needs to be exercised in order to be reliable.

As far as Night VFR in remote or unlit areas, consider this NTSB report.

If you're not convinced VFR-into-IMC is all that bad, consider:
2 Fatalities: Night VFR
3 Fatalities: Night VFR into IMC
3 Fatalities: Over Water VFR
4 Fatalities: Night VFR

Now maybe I'm over-reacting, but this thread started as advice on how/when to log actual even though not IR. That's fine, but as another poster pointed out, it's rather pointless and in fact may be questioned if your logbook is evaluated by the FAA for some reason (especially if the review is due to some event).

There was also some discussion on the differences between in-the-clouds IMC and other on-the-gauges IMC (Moonless night, featureless terrain, etc).

That's fine as well, but I think somebody needs to mention (since this is a public forum, after all) that those conditions do not adequately prepare a non-instrument rated pilot to fly in Instrument meteorological conditions, and the VFR pilot flying IMC becomes a hazard to himself and (as another mentioned) other aircraft flying IMC.

So if I'm over-reacting or misunderstanding the point, you'll bear with me if I restate what should be obvious -- if you as a VFR-only pilot want/need to fly in any form of IMC, get the instrument Rating and then stay current.

If you're so proficient you can fly on the gauges already, then invest in the minuscule number of dual hours, the written, and the flight test and get yourself rated, then fly IFR as often as possible and build up your proficiency.

{RANT}

I think some would be better served using the time and energy they expend avoiding the rating actually earning the rating.

{/RANT}

 

[poadeleted20]

In following this disucussion, the terms "actual instrument conditions" and "IMC" have been tossed about, sometimes inaccurately, interchangeably, or inappropriately. Keep in mind that the two are not synonymous, and have significantly different legal meanings. One can be in IMC without being in actual -- say, flying at 10,500 MSL within 1 mile of the only cloud in the sky on an otherwise clear, sunny day. OTOH, one can be in actual without being in IMC, say, by flying around over the Chesapeake Bay on a very hazy summer day (no horizon, and the ground visible only nearly straight down, but with 3 miles flight vis and no clouds). Of course, the inside of a cloud is both IMC and actual, and that's no place for a non-IR pilot to be. However, I would think that any non-IR pilot should be able to safely handle the illegal sub-1-mile passage of that only cloud in the sky. OTOH, the hazy day in Maryland could be a significant challenge even if legal.

Y'all be careful, now, hear?

 

[nosehair]

So if I'm over-reacting or misunderstanding the point, you'll bear with me if I restate what should be obvious -- if you as a VFR-only pilot want/need to fly in any form of IMC, get the instrument Rating and then stay current.

You'll bear with me if I re-state the obvious here, also:

The original issue is LOGGING. Can I log this time?

No matter the whys or wherefores. I am a firm believer in logging the flight as it occurs. That's the reason for logging - keeping a record of the flight.

Even if I'm a student pilot, and I inadvertanly get into IMC conditions, I should ( and would - and did) log that event. It is a memory. Why would I not? It was inadvertant, and I exercised my 91.3 emergency authority and operated the aircraft solely by reference to instruments until I was able to regain VFR conditions. To not log it is lying.

You are going off on the rant that logging will induce reckless behavior.

Maybe so, in some cases, and I respect your concern, but that's not the issue.

 

[dmccormack]

You are going off on the rant that logging will induce reckless behavior.

Maybe so, in some cases, and I respect your concern, but that's not the issue.

That was not my intent, as I don't believe "logging will induce reckless behavior" but I do think that the implication of acceptability is dangerous (all parents with daughters who lived through the Britney Spears era will know exactly what I'm talking about...)

I agree with the approach of my primary instructor -- go into the clouds and you die. No well, maybe, perhaps, wherefores, therefore, or other weasel terms.

Of course I did hood training (more than required, actually). And I logged actual at 30 hours (real actual -- clouds, rain, low vis and clg) as he demonstrated an ILS approach.

But once I had my ticket, I had no illusions about my VFR abilities in Instrument conditions. And quite frankly that's as it should be.

Is this approach overcautious? Perhaps.

But -- again-- check the accident record. More GA fatalities occur from VFR-into-IMC than any other cause. And personally I think this horrendous rate is due to a lack of caution in the GA pilot population.

So while the issue is logging actual, I stand by my earlier post in which I said that the amount of time logged solo IMC without an IR should be minuscule.

To paraphrase Hobbes -- "The life of VFR man in the state of IMC is nasty, poor, brutish, and short."

 

[dmccormack]

In following this disucussion, the terms "actual instrument conditions" and "IMC" have been tossed about, sometimes inaccurately, interchangeably, or inappropriately. Keep in mind that the two are not synonymous, and have significantly different legal meanings. One can be in IMC without being in actual -- say, flying at 10,500 MSL within 1 mile of the only cloud in the sky on an otherwise clear, sunny day. OTOH, one can be in actual without being in IMC, say, by flying around over the Chesapeake Bay on a very hazy summer day (no horizon, and the ground visible only nearly straight down, but with 3 miles flight vis and no clouds). Of course, the inside of a cloud is both IMC and actual, and that's no place for a non-IR pilot to be. However, I would think that any non-IR pilot should be able to safely handle the illegal sub-1-mile passage of that only cloud in the sky. OTOH, the hazy day in Maryland could be a significant challenge even if legal.

Agreed.

Here's an explanation from AOPA:

Logging actual instrument flight time depends on the weather, not what you can or cannot see.

FAR 61.51(g), Logging instrument flight time, (1) 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.

The regulations define actual instrument conditions in Part 170, which regulates Navigational Facilities, and gives the definitions for a number of terms used throughout the regulations.


FAR 170.3: Instrument flight rules (IFR) means rules governing the procedures for conducting flight under instrument meteorological conditions (IMC) instrument flight.


FAR 170.3: Instrument meteorological conditions (IMC) means weather conditions below the minimums prescribed for flight under Visual Flight Rules (VFR).


FAR 91.155 gives the minimum VFR weather conditions, which are the dividing line between VFR and IFR flight. When the weather conditions are below the weather minimums for the airspace you're flying in, you can log actual instrument time (and you must comply with all the other regulations governing IFR flight, naturally).


So the only time you can log your night flights as actual IFR time is when the weather is below VFR minimums because darkness isn't a meteorological condition. You can, however, log your night flights, where you're flying in VFR conditions but can't see a thing, as simulated instrument time, because the darkness 'simulates' flight in IMC. If effect, darkness and the lack of ground lights is nothing more than a view limiting device you don't have to wear.

 

[TMetzinger]

Sorry, if the reg said:
FAR 61.51(g), Logging instrument flight time, (1) 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 meteorological conditions

Then AOPA's interpretation would be correct. It doesn't, and theirs isn't.

Ron correctly identified the difference - IMC refers to weather conditions and regulations. Instrument Flight Conditions are NOT formally defined anywhere, but the FAA (I believe there is a formal counsel opinion on this - Ron would know) has said that instrument FLIGHT conditions are any time when you MUST use the flight instruments to keep the airplane upright.

 

[Henning]

Were you solo in IMC prior to the IR?

Sorry, I missed where the person was solo.

 

[dmccormack]

Logging instrument flight time. (1) 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.

The time cannot be logged as "actual" only when flown "solely by reference to instruments."

The additional qualifier is "under actual or simulated instrument flight conditions."

From AOPA:

The FAA's Office of Chief Counsel letter of interpretation (Nov 84) stated:

"Actual instrument conditions may occur during a flight on 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 of whether such a flight could be logged under 14 CFR Part 61 Section 61.51 is subjective and based in part on the sound judgment of the pilot.

The logbook entry should include the reasons for determining the flight was under actual instrument conditions in the event the entry is challenged.” (Emphasis mine)


​

That seems to be a fairly narrow case of legal VFR conditions being logged as Actual. It sounds like there should be adequate justification for the determination.

 

[flyingcheesehead]

Fortunately, the rules allow the Pilot in Command to exercise his judgement. While I agree that flying at night increases risk, I don't agree that we should eliminate it from the list of discretionary activities a private pilot may enjoy.

Tim,

I don't think Dan suggested that at all:

I tend to agree with a mentor CFI I've flown with who says night flying is instrument flying, and should be approached that way.

"Should be approached that way" is far from "should be required." FWIW, I agree 100% that night flying should be approached like instrument flying. When I was working on my Private, I don't recall getting any instruction in terrain avoidance. Yeah, I'm in the "flat" midwest, but even here there's plenty of spots where there is terrain close enough to airports and high enough to be a concern. OVS, for example, is one place that I'm really glad I flew to during the day first.

Probably the biggest thing is just using IFR altitudes and such. Obstacle Departure Procedures are a biggie!

One sad example of why this can be important: We recently lost one of the Med Flight helicopters from UW Hospital. They had dropped off a patient at LSE. They departed, turned towards MSN, and flew right into a bluff. Had they read this...

LA CROSSE, WI
LA CROSSE MUNI
TAKE-OFF MINIMUMS: Rwy 3, 600-1. Rwy 13, 900-1.
DEPARTURE PROCEDURE: Rwy 18, climb to
3000' on LSE VOR/DME R-180 before proceeding
on course. Rwy 21, immediate climbing left
turn to 3000' on LSE VOR/DME R-180 before
proceeding on course. Rwy 31, climb runway
heading to 2400 before turning left.

They might still be alive. I'm obviously not saying with 100% certainty that that's the cause of the accident, there could have been a mechanical failure as well, but it's quite possible that using IFR procedures despite being VFR could have made the difference if it wasn't a mechanical issue. But, when I heard about the crash, the ODP was the first thing I thought of - You need a pretty long climb to the south before turning on course to Madison. Even CAVU, at night you just can't see those hills, and hills don't make the "unlit obstruction" NOTAMs either.

Using IFR procedures at night can save your life. Plain and simple.

 

[SkyHog]

I actually got into an argument with some dude some night at my home airport. He saw me ready to launch, and asked how long ago I got my IR.

"I don't have it."

How the hell can you take off into a dark sky, no reference to the ground, near mountains and not have your IR? How do you know when its safe to descend?

"I suggest you go back to private ground school. They taught that to you there."

Nope, never, night flying should REQUIRE an IR!

"Tell that to AOPA. I'm sure they'll get right on restricting a perfectly legal and safe activity to make a pilot who is unsure of his own abilities feel better about himself. If you'll excuse me, I need to go prepare my plane for departure. Have fun waiting 30 minutes for your instrument clearance."



He was pretty quiet, but I think he realized I was right. There's no need to add a requirement because you're not a good enough pilot to handle something.

 

[TMetzinger]

The time cannot be logged as "actual" only when flown "solely by reference to instruments."

The additional qualifier is "under actual or simulated instrument flight conditions."

From AOPA:


The FAA's Office of Chief Counsel letter of interpretation (Nov 84) stated:

"Actual instrument conditions may occur during a flight on 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 of whether such a flight could be logged under 14 CFR Part 61 Section 61.51 is subjective and based in part on the sound judgment of the pilot.​

The logbook entry should include the reasons for determining the flight was under actual instrument conditions in the event the entry is challenged.” (Emphasis mine)​

That seems to be a fairly narrow case of legal VFR conditions being logged as Actual. It sounds like there should be adequate justification for the determination.

Wait - you previously quoted AOPA saying IMC (as defined in 170.3) was required to log actual instrument time. Then you provided the final word on the subject, from the FAA, which clearly states that that you CAN log actual without being in IMC as defined by FAR 170.3 (which was my point, wasn't it)? I'll grant that the conditions that allow that are rare, and in the subjective judgment of the pilot, but they do exist.

A pilot CAN log Actual Instrument Time without being in a cloud, without being in less than VFR weather. That's all I've ever said. Not that it was smart, not that I encouraged it, but that it could be done in compliance with regulations.

Dan, I am attacking your logic here, not your underlying opinion that flying on instruments without being rated is risky and should be discouraged... So please don't take this at all personally - next time I'm up around AGC on an Angel flight I'd like to buy you lunch and show you I'm not a rabid ****head, just an engineer.

Best wishes,

 

[TMetzinger]

Using IFR procedures at night can save your life. Plain and simple.

Hell, using them in the DAY can save your life - no argument. This year we had a gentleman depart FRR and fly his perfectly good airplane into a mountain, same cause - not being familiar with the area and not following the IFR ODP.

I'm surprised at the helo crew - most professional operators require the use of ODPs at night unless the crew is intimately familiar with the area.