Logging actual instrument time over water at night

[Murdoughnut]

I've heard this discussed on other message boards but I wanted to know what people here thought.

The situation is this, I'm departing VFR from a coastal city at night and fly straight out towards the ocean. I have no ground reference in front of me or 90-degrees to the side and am completely reliant upon my instruments.

Does the time spent on climeout qualify as instrument actual? According the FARs, it would seem to count, but I've heard some say they wouldn't log it if they weren't instrument rated.

Just wondering what you guys thought.

 

[mtsu_av8er]

I've heard this discussed on other message boards but I wanted to know what people here thought.

I'll just say this - the FARs are perfectly clear on this issue!

§ 61.51 . . . . "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."

 

[tgrayson]

Does the time spent on climeout qualify as instrument actual? According the FARs, it would seem to count, but I've heard some say they wouldn't log it if they weren't instrument rated.

There is at least one letter of interpretation endorsing the idea if, for any reason, you my fly by reference to instruments, you can log it as actual.

Don't really see that it matters whether you are instrument-rated or not. You can log actual when you fly in the clouds with an instructor, without being instrument-rated.

Based on the letter of interp, I'd log it. Nobody is really looking over your shoulder on this stuff.

 

[falconvalley]

Wha? What about IMC? If you consider that IMC, is that legal?

 

[nosehair]

Wha? What about IMC? If you consider that IMC, is that legal?

Where does it say you have to be IMC to log instruments. The definition is plain: "Controlling the airplane soley by reference to instruments." Period. No added "when you are in IMC".

 

[falconvalley]

If I were looking in your logbook and saw actual instrument time logged when I knew you didn't have the rating, I wouldn't care where or when you logged it.

 

[falconvalley]

Don't get me wrong. I'm all about reading the FARs for more than just what you can't do, but I don't think that's the greatest idea.

 

[tgrayson]

Wha? What about IMC? If you consider that IMC, is that legal?

What I consider it to be doesn't matter. Another poster quoted the regulation. Notice that it says "instrument flight conditions". Arguably, flying at night over water, or flying into the sun, or other scenarios where you can't use visual references are, by definition, instrument flight conditions, even though you technically have VFR minimums.

Since it is possible to experience spatial disorientation under these conditions, the pilot truly must use his instruments, so it certainly seems as good as being in a cloud. Apparently the FAA has taken the same position. I'll post the interpretation when I get home this evening.

 

[falconvalley]

What I consider it to be doesn't matter. Another poster quoted the regulation. Notice that it says "instrument flight conditions". Arguably, flying at night over water, or flying into the sun, or other scenarios where you can't use visual references are, by definition, instrument flight conditions, even though you technically have VFR minimums.

Since it is possible to experience spatial disorientation under these conditions, the pilot truly must use his instruments, so it certainly seems as good as being in a cloud. Apparently the FAA has taken the same position. I'll post the interpretation when I get home this evening.

I know what your interpretation is. I don't think you need to spell it out for anybody. The question at hand is whether they'd appreciate people out there logging actual time without an instrument rating. What you need to do is define IMC.

That's one case where the pilot will say what they thought the visibility was and give themself VFR minimums. But be careful with that reasoning. The idea of basic VFR minimums is to give you the ability to see and avoid things. If you're truly solely on reference to instruments you can't see and avoid things. There's no reg that says you can't do that outside of controlled airspace, though.

 

[tgrayson]

The question at hand is whether they'd appreciate people out there logging actual time without an instrument rating.

There is no requirement to hold an instrument rating to log instrument time. Why overburden yourself with a greater number of regulations than the FAA has created?

What you need to do is define IMC.

No I don't. The regulation does not refer to IMC.

The FAA's General Counsel's Office has said you can do this, so why debate the issue? It just isn't that big of a deal.

 

[TFaudree_ERAU]

The FAA's General Counsel's Office has said you can do this, so why debate the issue? It just isn't that big of a deal.

Well damn, I need to make some major amendments to my logbook. I can't even begin to count the number of times I've flown across the Chesapeake Bay or west of Richmond, VA at night. There's a reason the military uses those 2 places for training.

 

[mikecweb]

So let me get this right...
Your going to log PIC actual instrument time while not on an IFR flight plan and not having an instrument rating.
I think you guys have to focus on the fact that if you are logging actual instrument or flying by sole reference of instruments you should be on an IFR flight plan. Then again since "Nobody is really looking over your shoulder on this stuff" why don't you just go ahead and file that IFR flight plan or better yet just go through the clouds when not on a flight plan while your at it.
All this so you can log an hour at the most of actual time.
There is a diffence between pilots and flyers.

 

[falconvalley]

Mike~
"if you are logging actual instrument or flying by sole reference of instruments you should be on an IFR flight plan."

Exactly. The definition of IMC refers to the operation by sole reference to instruments. It doesn't specify which instuments. It doesn't have to. It means only by instruments and not using the outside references. If you see and avoid another aircraft while flying you're not operating by sole reference to instruments. There's a difference between needing the primary flight instruments and operating by sole reference. If you're operating by sole reference to instruments, you're in IMC. You can need the primary flight instruments to operate safely and still not be in IMC.

The definition of IMC does not say how the visibility is lowered. The visibility is based on what you can see, not what is causing you to be able to see or not. If you can't see and avoid you're in IMC and you need to be on an IFR flight plan if you are operating in IMC in controlled airspace.

 

[ColMustard]

Hate to bring it up, but lets not forget the JFK Jr. crash.

Legal? Yes.

Safe? Well, I think we all know the answer to that.

The logbook is mainly for currency (BFR, Inst, Pax, etc.), aircraft qualification (high perf, complex, etc.), and the pilot's own record keeping.

I would log it, but I probably would not have attempted the flight until I had an Instrument rating.

 

[tgrayson]

There is a diffence between pilots and flyers

A pilot, like any other professional, should research the facts before forming conclusions. Moreover, he should be willing to give up erroneous beliefs when presented with the evidence they are incorrect. A flyer, I suppose, is just someone who can fly an airplane.

The point about "no one looking over your shoulder" is that you should follow the rules and not worry about whose going to second guess you. In this case, no one will.

The rules about logging various types of flight time are bureaucratic in nature, and none of them correspond to what we think that they should. The FAA has drawn a non-intuitive distinction between logging PIC and acting PIC, and they have also said that you can log actual instrument time when flying in VMC, under certain conditions. Either log it or not, as you choose, but it's plain silly to attempt to make this a moral issue.

 

[falconvalley]

If you can refer me to where it says that, I will stand corrected. But as far as I can see, if you log whatever you do in that case, you're saying that you where in IMC and most people that know me know where I stand on logging flight time. Log what you did, period.

My argument is about logging actual instrument time and the definition of it. For shizzle, you can put a column in your logbook of "flying over water at night with no horizon" time. Nobody's gonna hurt you for that. But to log actual, by definition, you're stating that you had no way to see and avoid. And to operate that way in controlled airspace, you need to be on an IFR flight plan...

 

[jtrain609]

A pilot, like any other professional, should research the facts before forming conclusions. Moreover, he should be willing to give up erroneous beliefs when presented with the evidence they are incorrect. A flyer, I suppose, is just someone who can fly an airplane.

The point about "no one looking over your shoulder" is that you should follow the rules and not worry about whose going to second guess you. In this case, no one will.

The rules about logging various types of flight time are bureaucratic in nature, and none of them correspond to what we think that they should. The FAA has drawn a non-intuitive distinction between logging PIC and acting PIC, and they have also said that you can log actual instrument time when flying in VMC, under certain conditions. Either log it or not, as you choose, but it's plain silly to attempt to make this a moral issue.

The more you post, the more I think you're just a troll.

 

[mastermags]

It seems to me, if you are VFR, then it is not legal to rely solely on the instruments, because you have to see and avoid. If you long actual instrument in VFR conditions, then you are basically admitting you are not seeing and avoiding.... so why even bother?

 

[tgrayson]

If you can refer me to where it says that, I will stand corrected.

Here's a portion of the Letter I googled on the newsgroups. I didn't pull it from my Summit CD, so I can vouch for the exact authenticity, but it does match in content the letter that I have duplicated many times:


November 07, 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.

Second, you ask for an interpretation of Section 61.57(e)(2) of
the FAR, noting that Advisory Circular 61-65A, Certification:
Pilots and Flight Instructors, seems to contain advice contrary
to your understanding of the rule. [answer not included in this post]

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 (i.m.c.)) 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
judgement 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.

 

[tgrayson]

The more you post, the more I think you're just a troll.

My observation is that those with an extreme knowledge deficit have a real hard time believing that anyone else knows something they don't. That's why the knowledge deficit never goes away.