Logging actual instrument time

[BlackHwk27]

Trying to find out how most people log actual instrument time. I can't seem to locate a definitive answer.

 

Would you log just that time that you are in "the soup", Or even if above an overcast layer since you can't reference the actual horizon and are still on an IFR flight plan and referencing instruments? I appreciate any input.

[CharyouTree]

No horizon=instruments

[rotorrodent]

Trying to find out how most people log actual instrument time. I can't seem to locate a definitive answer.

 

Would you log just that time that you are in "the soup", Or even if above an overcast layer since you can't reference the actual horizon and are still on an IFR flight plan and referencing instruments? I appreciate any input.

 

if you are using a "view limiting" device, it is simulated. If you are actually flying by reference to instruments, it is actual.

 

Flying over the desert at night (black hole) would be actual. Basically, if you have to use instruments to keep yourself sunny side up, then it is actual.

 

Try not to get wrapped about the axles on this one! Use good judgement and reason!

 

Cheers

 

Rotorrodent

[Shaun]

The only opinion I could find on this matter was from 20 years ago, on the jet.careers forums.

 

 

"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©(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.

 

As you know, Section 61.51©(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((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.

 

Sincerely,

/s/

John H. Cassady

Assistant Chief counsel

Regulations and Enforcement Division"

 

 

 

If I were an employer however, I would put no-horizon night flights below actual IMC flights given:

 

-the disorientation moving between layers,

-the stress factor of not being able to see other aircraft

-and the stress that you might make an auto with a landing light in the moonless scenario, but not in 0-0 IMC.

[rick1128]

The FAA has changed the definition of instrument time in the last couple of years. You now have to be in the 'soup' or under a hood to log instrument time. In the past, if you were between layers you could log it as instrument time. No longer.

[Gomer Pylot]

I don't think the horizon has a lot to do with it, per se. If you have to maintain control of the aircraft by using the instruments, it's instrument time in my logbook. It may be in cloud, it may not be, but there are certainly conditions outside of clouds in which you have to use the instruments to control the aircraft, day or night.

[heligirl03]

I don't think the horizon has a lot to do with it, per se. If you have to maintain control of the aircraft by using the instruments, it's instrument time in my logbook. It may be in cloud, it may not be, but there are certainly conditions outside of clouds in which you have to use the instruments to control the aircraft, day or night.

 

I think Gomer's got it (big surprise ). Particularly if you file (but not necessarily I suppose), you are "actually" IFR regardless of whether you are IMC or not, e.g. over open ocean in broad daylight or at night across the desert/midwest fields/etc. You are relying on your instruments for navigation and/or attitude and, if you filed, you are specifically utilizing the privileges of your Instrument rating.

[Shaun]

The FAA has changed the definition of instrument time in the last couple of years. You now have to be in the 'soup' or under a hood to log instrument time. In the past, if you were between layers you could log it as instrument time. No longer.

 

Do you have a source for this?

[Eggbeater]

I think Gomer's got it (big surprise ). Particularly if you file (but not necessarily I suppose), you are "actually" IFR regardless of whether you are IMC or not, e.g. over open ocean in broad daylight or at night across the desert/midwest fields/etc. You are relying on your instruments for navigation and/or attitude and, if you filed, you are specifically utilizing the privileges of your Instrument rating.

 

I would have to disagree. I think the term "Actual IFR" confuses the issue by merging the definitions of Actual Instrument and Simulated Instrument (Actual Instrument being anytime conditions require sole reference to the instruments and Simulated Instrument being anytime a view limiting device is used, regardless of whether you are on an Instrument flight plan). Of course, all the typical limitations apply eg I think the Robinsons require reference to ground or celestial illumination for night flying, therefore there would never be a situation where you would legally fly a Robinson at night in conditions requiring sole reference to the instruments.. And of course flight into IMC is prohibited in a Robinson, so it is safe to say one would never log Actual Instrument time in a Robbie. As a side note, whenever I do recurrency training in our company's Class D simulator, which should allow logging of actual flight time, I log only Simulated Instrument even when we are in the clouds. I'm not 100% sure if that is correct, but I decided to err on the more conservative side.

 

Of course, you could log "Actual IFR" anytime on the IFR structure, even in VMC, but it isn't the same as actually flying in the clouds and logging "Actual Instrument". I would bet that it would not meet any company's requirements for Actual Instrument time. Anyone with any thoughts on the above?

[heligirl03]

Often I hear that the only way to accrue any significant time in the "actual" column is to hit up the GOM for a few years. They are IFR anytime they head offshore, but certainly not IMC every time. So how do you guys/gals out there log it? What do company regs suggest? I wonder if 200hrs of "actual" IMC in FW would trump 200hrs of "actual" mixed VMC/IMC in RW...all other quals being more or less equal for the same RW position...

[SkidKid]

This topic, I thought, should be short and sweet. What it has turned out to be is thought provoking. In my career, I have only logged "Actual Intrument" time as that time in "Actual IMC". Simple and easy. "Simulated (or hood for the rest of you old timers) time" was that not in IMC, but simulating the conditions. Simple and easy.

 

But in reading your responses, I did some research and came up with varying opinions to my basic assertions. From PilotsofAmerica.com is the following:

 

--------------------------------------------------------------------------------

 

On another forum the question came up about logging insturment time when there were basically no outside references that could be seen due to overcast and unlit terrain. In researching the answer, I discovered what I knew to be true turned out to be wrong. Here is what I posted and what I found out.

 

 

I just looked up the Part 61 FAQ on this, and it indicates otherwise. I am going to post it here and you can wade through it and see what you think. This will end up being a long post.

 

QUESTION: 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.

 

ANSWER: Ref. § 61.51(g); The only definition in the rules is the definition on “instrument flight time” and that is addressed in § 61.51(g) and is defined as:

 

(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.

 

However, I understand your question to be that you’re asking for a definition of “actual instrument time” as opposed to “simulated instrument time.” I believe you’re interchanging the terms “actual instrument time” where the rules only state “actual instrument conditions.” And you state “simulated instrument time” but the rules only state “simulated instrument conditions.” There is no official FAA definition of “actual instrument time” or “simulated instrument time” in the FARs, FAA Orders, advisory circulars, FAA bulletins, etc. And probably the reason why the FAA has never officially defined “actual instrument time” or “simulated instrument time” is because in all of the aeronautical experience requirements for pilot certificate and/or ratings in Part 61 the rule does not differentiate between “actual instrument time” as opposed to “simulated instrument time.” In fact, in Part 61 it only refers to the aeronautical experience for instrument time to be “. . . instrument flight time, in actual or simulated instrument conditions . . .” So it is irrelevant whether the instrument flight time is logged as “actual instrument time” or “simulated instrument time.” Part 61 only refers to “actual instrument conditions” or “simulated instrument conditions.”

 

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.

 

So, now to answer your other question “What about the requirement for a safety pilot under these conditions? Your question is answered by §91.109((1) and it states:

 

“( No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.”

 

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 thinking about this question from a common sense approach, 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 or is in meteorological weather conditions that are less than the that were less than the VFR weather minimums defined in § 91.155 and is flying solely by reference to instruments. So, in answer to your question, the FAA’s policy about logging instrument flight time in VMC requires that the pilot be utilizing a view limiting device (i.e., hood) and be operating the aircraft solely by reference to instruments. Or, be in instrument meteorological conditions and be flying the aircraft solely by reference to instruments.

 

 

This was a new change as of 22 July, 2005. It would appear that in order to log this, it would be considered Simulated and 91.109( applies. That is the one that requires a Safety Pilot.

 

Such are the lives of us who live under the FAR system. Subject to change without notice.

 

It has taken me 20 years to log 200 hour "actual time, and it meets the requirements of "in the clouds". I can defend these hours without explanation. Others cannot defend their time so easily, but they might be legal in their interpretation.

 

I still have reservations of the civilian training programs, and have had several poor pilot candidates who could not handle the aircraft in the clouds, or under the hood at night. Why? Because most civil trained pilots do simulated training flights with no blackout of the chin bubble, so they actually have reference to a horizon (the view of the ground).

[heligirl03]

Hmm, good digging skidkid. There is always a difference between writing the time in your logbook and proving the skill in the sky. You can interpret the regs however suits you best now but if you can't live up to it, well...nothing is worse than someone penciling it in and learning later the hard way.

 

Intentional IMC is hard to come by in the RW training environment. Seems to me we all might benefit from a little stuck-wing time in the soup?

[BlackHwk27]

Thanks all for the input, and a great post Skidkid.

 

It's basically as I suspected, where it's still a bit of a gray area. I'm starting to get some actual IMC flying now, and trying to figure out just what time I can log as actual instrument. For example, my first flight was departing with 500' overcast and 1/2 mile vis, and climbing out of the clouds at my cruise altitude of 4000', going into the tops of some of the clouds along the way, overcast layer above and below. At my destination descended back into the clouds for the ILS and popping out of the clouds around 700' agl.

 

Army regs state "weather time" as Actual weather conditions that do not permit visual contact with the natural horizon or the earth's surface. Aircraft attitude must be determined and controlled using aircraft instruments.

 

Any IP I've asked is also very vague and doesn't really give a very definitive answer.

 

I feel after all the discussion and research, that it makes most sense to log just that time I'm actually in the "the soup". Once on top of an overcast layer, I could still keep the aircraft level, it's much the same as flying a magnetic heading as you do for private/commercial rating's cross-country flights.

[Gomer Pylot]

IMC and IFR are not the same thing, of course, and neither are VFR and VMC. And if you can't control the aircraft without using the instruments, you can't legally fly VFR, because you're not in VMC. You have to be under IFR in IMC, but you can be IFR in VMC. Only a small percentage of GOM flights are actually IFR. Most are VFR, although the weather may be well below standard VFR minima, because helicopters can legally fly VFR with less than 1000'/3. I have a lot of IFR time, but much less IMC time, and the IMC time is all that I log as instrument time. It's the same with the airlines, and while those pilots fly IFR on every flight, they don't get that much actual instrument time. I suspect I used to get a higher percentage of instrument time in the GOM, because I was down in the weather instead of up at FL350.

Edited October 21, 2009 by Gomer Pylot

[RotorheadS92]

The 1984 FAA interpretation letter to Carr is still valid and has not been changed. A few months ago I wrote the FAA seeking clarification and they sent me the 1984 interpretation.

[avbug]

The FAA has changed the definition of instrument time in the last couple of years. You now have to be in the 'soup' or under a hood to log instrument time. In the past, if you were between layers you could log it as instrument time. No longer.

 

 

Don't confuse being in IFR conditions with being in instrument conditions. The regulation is clear that one may log instrument time when operating the aircraft by sole reference to instruments in actual or simulated instrument conditions. See 14 CFR 61.51(g)(1).

 

When people make up terms like "actual IMC" or "actual IFR," it confuses the subject. Both are imaginary terms. The FAA does not define actual instrument conditions as "actual IMC," or actual instrument meteorological conditions. Actual instrument conditions are those which require flight by reference to instruments, and could include flight between layers, white out, a dark moonless night over featureless terrain, etc. All can and often do require flight by reference to instruments. Those are conditions which require flight by reference to instruments. Those are actual instrument conditions.

 

Simulated conditions exist when something is done to simulate instrument flight, which could be a view limiting device. One may be in actual instrument conditions, but when wearing a view limiting device which occludes one's view outside the aircraft, one in in simulated conditions in the cockpit; one could fly in and out of actual conditions and never know it, if one's view is limited by the device.

 

The issue of the safety pilot is another matter entirely, and is tied to the requirement to see and avoid.

 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/walker%20-%20(2011)%20legal%20interpretation.pdf

[Gomer Pylot]

Necromancy.

[avbug]

Dead horses will rise.