Logging actual while VFR
- Thread starter E_Dawg
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EatSleepFly
Well-Known Member
I think this is a huge steaming crock:
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Quote:
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OK now say you're a student pilot soloing in the practice area at night over that same body of water. You don't see any horizon but you are able to fly by reference to instruments. Can you log actual?
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Yup. Doesn't make any difference. The issue is whether the flight was in actual instrument conditions, not whether it was technically VFR or IFR. If the only way to remain upright is by using the instruments, it's "actual."
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Buuuuuut, thats just my worthless opinion I guess.
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Quote:
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OK now say you're a student pilot soloing in the practice area at night over that same body of water. You don't see any horizon but you are able to fly by reference to instruments. Can you log actual?
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Yup. Doesn't make any difference. The issue is whether the flight was in actual instrument conditions, not whether it was technically VFR or IFR. If the only way to remain upright is by using the instruments, it's "actual."
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Buuuuuut, thats just my worthless opinion I guess.
EatSleepFly
Well-Known Member
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I'd like to see the look on the examiner's face when you sent a student who's got actual logged on his solo flights!!!
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Man, I'd use some serious "negative reinforcement" (read: ass beating) on any of my students that pulled some crap like that.
Besides, FAR 61.89(a): "A student pilot may not act as pilot in command of an aircraft:
(7): When the flight cannot be made with visual reference to the surface."
Annnnd, besides THAT: As an instructor, you'd have to be nuts to let a student solo at night...in my opinion, of course.
And sorry MidlifeFlyer, but 20-year old FAA opinions don't mean crap to me. Go ask an FAA Inspector what he thinks of that, and you'll see why.
I'd like to see the look on the examiner's face when you sent a student who's got actual logged on his solo flights!!!
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Man, I'd use some serious "negative reinforcement" (read: ass beating) on any of my students that pulled some crap like that.
Besides, FAR 61.89(a): "A student pilot may not act as pilot in command of an aircraft:
(7): When the flight cannot be made with visual reference to the surface."
Annnnd, besides THAT: As an instructor, you'd have to be nuts to let a student solo at night...in my opinion, of course.
And sorry MidlifeFlyer, but 20-year old FAA opinions don't mean crap to me. Go ask an FAA Inspector what he thinks of that, and you'll see why.
MidlifeFlyer
Well-Known Member
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And sorry MidlifeFlyer, but 20-year old FAA opinions don't mean crap to me. Go ask an FAA Inspector what he thinks of that, and you'll see why.
[/ QUOTE ] Ah! So =you're= the reason for those stupid loggging vs acting PIC discussions that rehash things the FAA settled over 20 years ago and that some FSDO personnel still insist on misinterpreting!
And sorry MidlifeFlyer, but 20-year old FAA opinions don't mean crap to me. Go ask an FAA Inspector what he thinks of that, and you'll see why.
[/ QUOTE ] Ah! So =you're= the reason for those stupid loggging vs acting PIC discussions that rehash things the FAA settled over 20 years ago and that some FSDO personnel still insist on misinterpreting!
MidlifeFlyer
Well-Known Member
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I think this is a huge steaming crock:
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...and obviously written by a person of culture and intelligence and phrased in a way that is sure to result in the opinion being given the credit it deserves.
I think this is a huge steaming crock:
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...and obviously written by a person of culture and intelligence and phrased in a way that is sure to result in the opinion being given the credit it deserves.
EatSleepFly
Well-Known Member
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Ah! So =you're= the reason for those stupid loggging vs acting PIC discussions that rehash things the FAA settled over 20 years ago and that some FSDO personnel still insist on misinterpreting!
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First of all, no I'm not. Second- how did this go from a thread regarding logging instrument time, to a conversation about logging vs. acting PIC? Read the whole thread. In any case, what I said earlier was: I challenge you to go ask a FSDO about a student pilot logging actual while flying solo in VFR conditions at night. They would laugh in your face, and take action against the instructor. I would bet my next three paychecks on it.
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...and obviously written by a person of culture and intelligence and phrased in a way that is sure to result in the opinion being given the credit it deserves.
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Geez, almost sounds like you work for the FAA. But alas, you do not. How do I know? Because if you did, you would have put up a worthwhile post on the thread...not 20 year old opinions.
If you all want to log actual in VFR conditions, or at night, or whatever fine. Go for it. But like I said in another post, have fun explaining in an interview or to the feds how you got 300 hrs. of actual instrument time flying freight over the desert night after night.
Ah! So =you're= the reason for those stupid loggging vs acting PIC discussions that rehash things the FAA settled over 20 years ago and that some FSDO personnel still insist on misinterpreting!
[/ QUOTE ]
First of all, no I'm not. Second- how did this go from a thread regarding logging instrument time, to a conversation about logging vs. acting PIC? Read the whole thread. In any case, what I said earlier was: I challenge you to go ask a FSDO about a student pilot logging actual while flying solo in VFR conditions at night. They would laugh in your face, and take action against the instructor. I would bet my next three paychecks on it.
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...and obviously written by a person of culture and intelligence and phrased in a way that is sure to result in the opinion being given the credit it deserves.
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Geez, almost sounds like you work for the FAA. But alas, you do not. How do I know? Because if you did, you would have put up a worthwhile post on the thread...not 20 year old opinions.
If you all want to log actual in VFR conditions, or at night, or whatever fine. Go for it. But like I said in another post, have fun explaining in an interview or to the feds how you got 300 hrs. of actual instrument time flying freight over the desert night after night.
sbav8r
New Member
This has been covered many times. If you don't want the hours then don't log it but you are legal to do so. Furhtermore, the FSDO is nothing more than the beat cop for the FAA. They have no authority over the interpretation of the regulations. You could go to three different FSDO's and end up with three different answers. If you want the FAA interpretation of the regs write a letter to the Cheif Counsel and they will respond in about 30 days. What the examiner or the FSDO says is irrelevant. They are tasked with the enforcement of what the Cheif Counsel puts in the regs. The Regulations and Enforcement Division are the final authority over these matters.
Attached is a post from a similar question a few months back.
14 CFR 61.51(g). One may log instrument time only when operating the aircraft by reference to instruments under actual or simulated instrument flight conditions. Also, a flight instructor may log instrument time when instructing under instrument conditions.
Part 1.1 defines "IFR Conditions" as conditions less than VFR. The reg that discusses logging instrument time is 61.51(g)(1) and does not say "IFR conditions," but rather "instrument conditions." The two are very different.
"IFR conditions" is instrument flight rules, while "instrument conditions" is the actual conditions of flight. IFR conditions are indeed conditions less than VFR, while instrument conditions occur any time that the aircraft must be flown by reference to instruments.
A person does not need to be flying under instrument flight rules to be in instrument conditions and a person flying under instrument flight rules does not always log it as "actual" instrument conditions.
Situations such as flight between layers or "on top" do not get logged as instrument conditions, while flying above minimums under VFR rules can be logged as instrument conditions. For example, flying on a moonless night over the desert when your only reference to a horizon is your instruments, even if you are in unlimited visibility with no clouds, while flying below minimums while skimming the bottom of a layer (not within VFR cloud spacing) may not be instrument conditions because you have reference of a horizon.
Any conditions which require flight soley by reference to instruments are instrument conditions, and flight time spent in these conditions is loggable as instrument flight time.
This may sound like BS to many of you, as some of you have questioned this sort of thing in the past, so I will give reference to the FAA legal interpretation by the Chief Counsel (Cassady, Nov., 1984)
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.
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.
Sincerely,
/s/
John H. Cassady
Assistant Chief counsel
Regulations and Enforcement Division
Attached is a post from a similar question a few months back.
14 CFR 61.51(g). One may log instrument time only when operating the aircraft by reference to instruments under actual or simulated instrument flight conditions. Also, a flight instructor may log instrument time when instructing under instrument conditions.
Part 1.1 defines "IFR Conditions" as conditions less than VFR. The reg that discusses logging instrument time is 61.51(g)(1) and does not say "IFR conditions," but rather "instrument conditions." The two are very different.
"IFR conditions" is instrument flight rules, while "instrument conditions" is the actual conditions of flight. IFR conditions are indeed conditions less than VFR, while instrument conditions occur any time that the aircraft must be flown by reference to instruments.
A person does not need to be flying under instrument flight rules to be in instrument conditions and a person flying under instrument flight rules does not always log it as "actual" instrument conditions.
Situations such as flight between layers or "on top" do not get logged as instrument conditions, while flying above minimums under VFR rules can be logged as instrument conditions. For example, flying on a moonless night over the desert when your only reference to a horizon is your instruments, even if you are in unlimited visibility with no clouds, while flying below minimums while skimming the bottom of a layer (not within VFR cloud spacing) may not be instrument conditions because you have reference of a horizon.
Any conditions which require flight soley by reference to instruments are instrument conditions, and flight time spent in these conditions is loggable as instrument flight time.
This may sound like BS to many of you, as some of you have questioned this sort of thing in the past, so I will give reference to the FAA legal interpretation by the Chief Counsel (Cassady, Nov., 1984)
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.
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.
Sincerely,
/s/
John H. Cassady
Assistant Chief counsel
Regulations and Enforcement Division
EatSleepFly
Well-Known Member
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If you don't want the hours then don't log it but you are legal to do so. Furhtermore, enough with the FSDO crap. The FSDO is nothing more than the beat cop for the FAA. They have no authority over the interpretation of the regulations. You could go to three different FSDO's and end up with three different answers.
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First of all, scroll up. You just reposted the same 20-year old FAA opinion crap the other guy did.
Secondly, the FSDO may be the FAA's beat cop, but guess what- the cronies at the FSDO are the ones that will ramp you. Their opinion counts enough for me. I've been there done that (ramped)...twice (once as the PIC, once just along for the ride). I'll take their opinion over some guy that wrote the above letter almost 20 years ago when I was probably still in diapers. God I'm sick of this thread...I'm out.
If you don't want the hours then don't log it but you are legal to do so. Furhtermore, enough with the FSDO crap. The FSDO is nothing more than the beat cop for the FAA. They have no authority over the interpretation of the regulations. You could go to three different FSDO's and end up with three different answers.
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First of all, scroll up. You just reposted the same 20-year old FAA opinion crap the other guy did.
Secondly, the FSDO may be the FAA's beat cop, but guess what- the cronies at the FSDO are the ones that will ramp you. Their opinion counts enough for me. I've been there done that (ramped)...twice (once as the PIC, once just along for the ride). I'll take their opinion over some guy that wrote the above letter almost 20 years ago when I was probably still in diapers. God I'm sick of this thread...I'm out.
sbav8r
New Member
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You just reposted the same 20-year old FAA opinion crap the other guy did.
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That crap is the FAA opinion and the final authority over the issue. If you don't like it don't log it, but don't come on here acting like the final authority over the regs and tell people they are wrong in logging "actual" time. As you said the FAA wrote this and has continued to uphold this since you were in diapers. If you or anyone else for that matter don't trust the FAA in their 20 year old "crappy" interpretation of the regs then write a letter or email the Chief Counsel.
You just reposted the same 20-year old FAA opinion crap the other guy did.
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That crap is the FAA opinion and the final authority over the issue. If you don't like it don't log it, but don't come on here acting like the final authority over the regs and tell people they are wrong in logging "actual" time. As you said the FAA wrote this and has continued to uphold this since you were in diapers. If you or anyone else for that matter don't trust the FAA in their 20 year old "crappy" interpretation of the regs then write a letter or email the Chief Counsel.
EatSleepFly
Well-Known Member
Post deleted by EatSleepFly 'cause he realized his fuse is too short sometimes.
sbav8r
New Member
Believe it or not, I'm not trying to piss you off. To be honest I read this
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While I agree that the pilot may be flying solely by reference to instruments due to lack of a defined horizon, if he is not in actual instrument flight conditions (IN THE CLOUDS)- he cannot log actual.
"Solely by reference to instruments" doesn't mean squat by itself. You have to be in ACTUAL or SIMULATED instrument meteorological conditions, and then log it as the appropriate one. I encourage you to reread and look closely at 61.51(g)(1).
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and then skimmed the rest of the posts. Then when you called it 20 year old crap I took that as though you were disregarding the FAA opinion.
You are right that you promptly admitted when you were wrong and never did tell anyone what they should or should not do. I apologize for my harsh use of words and sincerely hope that you can overlook that mistake on my part. I do not mean any disrespect to you. In the past you have been very helpful and informative and I have no desire to create any animosity between us when you see my posts.
I shall now go screw off.
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While I agree that the pilot may be flying solely by reference to instruments due to lack of a defined horizon, if he is not in actual instrument flight conditions (IN THE CLOUDS)- he cannot log actual.
"Solely by reference to instruments" doesn't mean squat by itself. You have to be in ACTUAL or SIMULATED instrument meteorological conditions, and then log it as the appropriate one. I encourage you to reread and look closely at 61.51(g)(1).
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and then skimmed the rest of the posts. Then when you called it 20 year old crap I took that as though you were disregarding the FAA opinion.
You are right that you promptly admitted when you were wrong and never did tell anyone what they should or should not do. I apologize for my harsh use of words and sincerely hope that you can overlook that mistake on my part. I do not mean any disrespect to you. In the past you have been very helpful and informative and I have no desire to create any animosity between us when you see my posts.
I shall now go screw off.
EatSleepFly
Well-Known Member
OK then, thats fair. And also I apologize for being a dick, and retract my request for you to screw off.
Its not that I disregard FAA opinion, its that I tend to listen to what the local inspectors have to say. It just seemed to me like that letter and line of thinking is a little outdated, thats all.
Again, I apologize for being less than professional in arguing my case.
Its not that I disregard FAA opinion, its that I tend to listen to what the local inspectors have to say. It just seemed to me like that letter and line of thinking is a little outdated, thats all.
Again, I apologize for being less than professional in arguing my case.
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