Why is that a problem with my argument?
He said "training", and you only need 15 hours of instrument training for the IR-A rating. While the three hours of "flight training in a single-engine airplane on the control and maneuvering of an airplane solely by reference to instruments" required for the PP-A rating does count towards the 40 hours of total instrument time required for the IR-A rating, it does not count towards the 15 hours of "instrument flight training" required for that rating.
I had never heard of an "instrument scan" until PoA and then read about it in the IFH.
Hmmm... well I'd argue, and it looks like we agree, that the three hours for the PPL is still instrument "training", just not allowed toward the 15 needed with a double eye. It's not wasted, was my only point, which is how the post struck me.
We do not agree. Per Flight Standards and the Chief Counsel, it is training time, and it is instrument time, but it is not "instrument flight training" time. It was made that way specifically so a CFI-Airplane with no instrument instructor rating could give all the training required for PP-Airplane.
On that we do agree.
I agree, also, that it is not "wasted" training or instrument time. However, the specific terminology is important for the FAA's purposes.
Ok, we mostly agree.
I would say the terminology isn't as important as you think. The logging rules differentiate between "flight" and "ground" "training" as the "type of training". The "conditions of flight" are where "instrument" time is logged. So, on the day the student receives the three instrument hours from an ordinary CFI (not CFII) it's logged as flight training and instrument time from an authorized instructor. It doesn't lose that status with calendar time, but I'm sure we could find more interesting things to disagree about, like my next post for instance.
In my humble opinion, that's not the case at all. I've always been amazed at how easily student pilots took to flying instruments during the three hours of required instrument time. Maybe I was just exceptionally good at teaching it,
, but I doubt that. I always finished that training and the night requirement before the cross country sign-off. I even had them doing ASR approaches, both gyro and no gyro and DF steers, at night, under the hood. All in just three hours. I've often said you learn instrument flying in three hours, but it takes another 37 hours to learn how to do it in the IFR system. YMMV.
In my humble opinion, that's not the case at all. I've always been amazed at how easily student pilots took to flying instruments during the three hours of required instrument time. Maybe I was just exceptionally good at teaching it,
Chapter 3 AFH introduces Integrated Instrument instruction which does not specify a specific "scan". But one of the common errors is insufficient scan.
It most certainly can be VMC, but it can also be actual instrument conditions. I can be flying on a clear visibility high overcast night over Kansas with no stars/moon and no horizon and no ground lights and still be able to another airplane 20 miles away so I can avoid running into it. And that's all VMC is about -- the ability to see and avoid other aircraft, and nothing else. VMC has nothing whatsoever about your ability to keep the airplane right side up without looking at the instruments. As noted above, the best example of this was JFK Jr, who was in actual instrument conditions but also as in good VMC.
You should try flying out in Garrett County or on the downwind-base to 32 at Ocean City. We lose one in the Atlantic Ocean off the beach at OC every couple of years that way.
Don't bet your life on it.
Yes. You are in VMC. You are further from clouds than the VFR cloud clearances require and the vis is greater than 3 miles (or 5, depending on altitude).
And that's the point for VMC, you can see and avoid other aircraft. VMC does NOT mean that you can control the aircraft by visual reference alone.
No one is arguing against the G.C.'s letter. It is perfectly legal for a VFR-only pilot to fly in that scenario, and for many, it is probably perfectly safe. If they are not among those many, then they shouldn't be doing it, and no one should be capable of influencing them into trying it. It requires a level of proficiency at instrument flying that the PPL standards don't require.
Two separate questions, whether you need to file IFR, and whether you have the experience to continue without visual reference. The first: you do NOT need to file IFR, you are perfectly legal to continue. The second is entirely between you and your inner voice.
I can't fault anything you said -- what is legal isn't necessarily safe/smart, and that's why judgment is a pass/fail item on every practical test. But it's important to keep the terminology straight when having these discussions since there are legal ramifications to the use of the various terms, not to mention confusion in trying to explain it all if those terms are misused.
That's true even during the daytime -- think "hazy milk bowl over water" or "between layers".
