Logging actual under part 121

Mav4840h

New Member
So if youre flying part 121 under can you log the entire flight as actual Instrument? Part 61 defines it as any time using only the Instruments (which you do flying an RJ or anything big, at least abv FL180). But the P/C glossery only defines IMC as vis and ceiling and IFR as referring to procedures for conduncting instrument flight. But the 61 reg only refers to instrument FLIGHT conditions for which there is no definition which to me means by reference to only the instruments. Lawyer talk and loops holes! What do you other 121 guys do?
 
$61.51 (g) {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.

IFR Conditions means weather conditions below the minimum for flight under visual flight rules (per FAR1.1)

So no, you may only log that time when you are in IFR conditions. The question is though whether the entire time you spend in class A counted because by definition you could not be VFR there, though you could be in VMC.

When I was flying the Hondo however, I just wrote in about 10% of the flight time because most days I know I spent more than that in the clouds, and it was easier than trying to calculate that I had spent about 20 percent of this leg imc then only 5 percent of the next leg imc.
 
$61.51 (g) {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.

IFR Conditions means weather conditions below the minimum for flight under visual flight rules (per FAR1.1)

So no, you may only log that time when you are in IFR conditions. The question is though whether the entire time you spend in class A counted because by definition you could not be VFR there, though you could be in VMC..
But that's not the rule.

==============================
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.
==============================

"Less tha VFR" is the definition of IMC but it is not the definition of "actual".

From an FAA Chief Counsel opinion:
==============================
"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.
==============================

You are not in actual when flying above 10,000 msl 900' below an overcast with 100 miles visibility even though it's IMC.
 
But that's not the rule.

==============================
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.
==============================

"Less tha VFR" is the definition of IMC but it is not the definition of "actual".

From an FAA Chief Counsel opinion:
==============================
"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.
==============================


You are not in actual when flying above 10,000 msl 900' below an overcast with 100 miles visibility even though it's IMC.

Get me a reference for this. By this logic, I could log instrument time in SVFR or at night.

You are correct on the second point.
 
So if youre flying part 121 under can you log the entire flight as actual Instrument? Part 61 defines it as any time using only the Instruments (which you do flying an RJ or anything big, at least abv FL180). But the P/C glossery only defines IMC as vis and ceiling and IFR as referring to procedures for conduncting instrument flight. But the 61 reg only refers to instrument FLIGHT conditions for which there is no definition which to me means by reference to only the instruments. Lawyer talk and loops holes! What do you other 121 guys do?


Well, I log approaches then IFR for the flight. So, I don't log all the IFR flights. If I shoot an approach in IMC then I log IFR. But, If I fly in IMC at altitude but shoot the app in VMC. I don't log anything.

I was talking with my rommmate the other day, I was flying at night and lost the stars after looking down for a minute. I turned on the lights and notice we were in the clouds. My roommate asked why I did that, "So you know how to log it?" took me a minute and I started laughing. He logs all night as IFR and altitude IFR.

Personally I have never found a publication by the FAA about how to perfectly keep your logbook.
 
Part 61 defines it as any time using only the Instruments (which you do flying an RJ or anything big, at least abv FL180).
You use the instruments to keep have precise control to keep the pax happy. You do not really have to use them to maintain basic belly-down control.
 
You could technically log "actual" instrument flight time as a non-instrument rated pilot in VMC conditions.

The classic example is the moonless night taking off over the ocean where no visual cues to the horizon exist even though the ceilings are high and the visibility unrestricted.
 
Get me a reference for this. By this logic, I could log instrument time in SVFR or at night.
Indeed you could. Here's the fuller reference (it's kinda famous):

==============================
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.

[unrelated portion snipped]

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.

[unrelated portion snipped]

Sincerely,
/s/
John H. Cassady
Assistant Chief counsel
Regulations and Enforcement Division
==============================
 
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MidlifeFlyer:
""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."
================================

Ok so following the FAAs wisdom define adequate control. Realistically you cant "maintain adequate control" at FL320, fly safely at cruise mach, and navigate a 121 flt with out using your IFR panel.

Moreover:

==============================================
MidlifeFlyer
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.
==============================================

by this explaination a pilot can "use sound judgment" to fly by reference to the instruments and log actual. Im just sayin there should be more than logging actual under part 121 or in Class A than just you can see the horizon and keep the pointy end up.

PS Im not arguing with anyone so dont anyone get all defensive. Im not brave enough to go against the FAA, save the headache: if youre not actual dont log it. Thanks for the help! Im just saying IF someone was REALLY really bored they could go crazy arguing with the Feds on this one, and just about any other reg. :buck: Like 4 people logging PIC at once (or was it 5? and that was told to me BY A FED!)
 
I only log actual if I am the pilot flying, and I only log an approach if I am the Pilot flying as well.
 
What I do:
In the blue = no instrument
In the goo= instrument

I've been told by more than one person that the rule of thumb is that instrument time should be approximately 10% of total time.

After you meet part 61 and 135 requirements, the only thing left is hiring or insurance requirements, and the most I have seen is 200 hrs.

I asked some high time captains, and some of those guys just log monthly block time, and dont worry about instrument time.

Not trying to make a statement on the regs either way.
 
Ok so following the FAAs wisdom define adequate control. Realistically you cant "maintain adequate control" at FL320, fly safely at cruise mach, and navigate a 121 flt with out using your IFR panel.
Best I can come up with is that if conditions outside the cockpit make it necessary for you to use the instruments to keep the shiny side up, it's "actual."

And ultimately the pilot judgment part is going to come down to a "reasonable" standard. For example:

Inspector: I see here that you logged actual on March 1. Wasn't it pretty clear that day?

Pilot: Well, yes, but I was flying 3000' above a stratus cloud deck. In my judgment I couldn't maintain adequate control of the airplane without the instruments. Um... what are you doing?

Inspector: Checking my calendar. When will you be available for a 709 ride?​

You can make it very complicated and come up with all sorts of "buts" and "ifs" and "I don't like its" but I personally don't think it's any more complicated than that.
 
I only log actual if I am the pilot flying, and I only log an approach if I am the Pilot flying as well.

You must fly one of those single pilot airliners then because every other one I know the SIC is operating the aircraft even when he or she is not manipulating the flight controls or flight guidence controller.
 
You must fly one of those single pilot airliners then because every other one I know the SIC is operating the aircraft even when he or she is not manipulating the flight controls or flight guidence controller.
True for logging actual, but as we discussed in another thread, FAA Legal has said the non-flying SIC can't log the approach.
 
I only log actual if I am the pilot flying, and I only log an approach if I am the Pilot flying as well.

You must fly one of those single pilot airliners then because every other one I know the SIC is operating the aircraft even when he or she is not manipulating the flight controls or flight guidence controller.

pwned.gif
 
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