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.”