Regulation Foggles?

I've heard tale of examiners just saying, "tip your ballcap down." Tales only, of course, never happened to me...

Well in all honesty if your seat isn't jacked way up you can tip down a ball cap and it will block your view out of the front fairly well. I tell you where its hard to find a VLD that works is in a helicopter. Those pesky chin bubble window give you a nice look at the ground.
 
I thought this thread was going to be about pilots that have a skewed perception of the regulations, ala "beer goggles".
 
I've heard tale of examiners just saying, "tip your ballcap down." Tales only, of course, never happened to me...
I've seen it and it was pretty common in bizjets. Realistically, I don't think it makes any difference when you get into that level of aircraft. But, so far, nobody has ever asked my opinion before they write rules or set policies.

The policy is that ball caps are not acceptable view-limiting devices and I stick with the policies whether I agree with them or not. I just don't want there to be a day where something goes wrong and I have to stand on my reputation and there are people who can tell tales of how I bent rules. So, I'm pretty much an old stick in the mud when it comes to the rules.

Incidentally, I think I've inadvertently supplied at least a dozen people with foggles over the years just from the ones I've accidentally left in airplanes.
 
I've seen it and it was pretty common in bizjets. Realistically, I don't think it makes any difference when you get into that level of aircraft. But, so far, nobody has ever asked my opinion before they write rules or set policies.

The policy is that ball caps are not acceptable view-limiting devices and I stick with the policies whether I agree with them or not. I just don't want there to be a day where something goes wrong and I have to stand on my reputation and there are people who can tell tales of how I bent rules. So, I'm pretty much an old stick in the mud when it comes to the rules.

Incidentally, I think I've inadvertently supplied at least a dozen people with foggles over the years just from the ones I've accidentally left in airplanes.


Any idea where that policy is written? I looked at the DPE Handbook (8710-3E) and it states:

B. View Limiting Device. During the practical test for an instrument rating or other certificates/ratings requiring a demonstration of instrument proficiency, the applicant must
provide equipment, satisfactory to the examiner, which prevents flight by visual reference.

I was unable to locate any specific mention of hats.
 
Any idea where that policy is written? I looked at the DPE Handbook (8710-3E) and it states:

B. View Limiting Device. During the practical test for an instrument rating or other certificates/ratings requiring a demonstration of instrument proficiency, the applicant must
provide equipment, satisfactory to the examiner, which prevents flight by visual reference.

I was unable to locate any specific mention of hats.
FAA Order 8710.3E has been cancelled, although, ironically, it is still referred to as reference material in a lot of FAA work. The new order is 8900.2. However, you won't find it there either.

I can't remember where I read it. It might have been in a SAFO, but I can't lay my hands on it right now. It seems like it floated past me about six months ago.

However, here is a snippet from the old John Lynch FAQs. It is basically the same information as the newer guidance. Just to save someone the time of writing, yes, I know the FAA said that all opinions had to come from their lawyers instead of John Lynch.

QUESTION: The question continues to surface among the flight instructors as to what is acceptable “vision restriction”. Some instructors are saying that no vision restriction is required if the instructor or examiner determines that no vision restriction is necessary even though the training is accomplished as “simulated instrument conditions”. The other condition is the use of a “ball cap” or “the agreement by the student that he will not look outside”, with the obvious question being, is either of these methods considered to be suitable “restriction to outside references”? I was told today that Flight Safety does not use any vision restriction device in Jets even though simulated instrument conditions are required by the PTS.

ANSWER: Ref: §§ 61.45(d)(2) and 61.51(g); FAA Order 8700.1, vol. 2, page 1-12; FAA Order 8400.10, vol. III, page 3-270 and vol. V, page, 5-88; The only specific rule reference to what constitutes what is acceptable “vision restriction” is addressed in § 61.45(d)(2) [i.e., “(2) A device that prevents the applicant from having visual reference outside the aircraft, but does not prevent the examiner from having visual reference outside the aircraft, and is otherwise acceptable to the Administrator.]. Emphasis added “. . . A device that prevents the applicant from having visual reference outside the aircraft.” And per FAA Order 8700.1, vol. 2, page 1-12, paragraph 15.B. it states “During the practical test for an instrument rating or other ratings requiring a demonstration of instrument proficiency, the applicant must provide equipment, satisfactory to the inspector, which prevents flight by visual reference.”

Now in reference to your question/statement “. . . does not use any vision restriction device . . .” Per § 61.51(g)(1), it states “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.” So, in order to log instrument flight time the pilot must be utilizing a view-limiting device. Except for when a pilot is operating an aircraft solely by reference to instruments in instrument meteorological conditions (IMC), how else could a pilot comply with § 61.51(g)(1) for logging instrument flight time [i.e., “. . . when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.”] unless the pilot was utilizing a view limiting device! So the answer is, in order to log instrument flight time for simulated instrument flight a person must be utilizing a view-limiting device. A promise by the applicant to not look outside the aircraft is not acceptable. And neither is the use of an ordinary ball cap, unless there is view limiting attachments to the bill of the cap that prevents the applicant from having visual reference outside the aircraft.

However, as per § 61.51(g)(2), an authorized instructor may log instrument time when conducting instrument flight instruction in actual instrument flight conditions.

Per FAA Order 8400.10, vol. III, page 3-270 and vol. V, page, 5-88 address the policy requirement for use of a view limiting device when training and evaluating a pilot to control an aircraft on instruments and to navigate without reference to outside cues under 14 CFR parts 121 and 135. And under FAA Order 8400.10, the policy requires the use of a view limiting device when performing “. . . training and evaluating a pilot to control an aircraft on instruments and to navigate without reference to outside cues.”
Incidentally, the FAA Order 8400.10 John referred to has been replaced by FAA Order 8900.1.
 
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