Question about logging instrument time while flying VFR

[TripleSticks]

I don't have my FAR/AIM with me and I thought of a question.

I'm a surveying pilot and I do a lot of VFR flying at night in areas where it's completely pitch black. There's definitely no horizon and a lot of the time there's no moon and no ground lights. For example... Long stretches of flying slow in the Everglades, over the ocean and in areas in the country where it's not populated.

Can I log this time as actual instrument time in my log book even though I'm surveying on a VFR flight or do I have to be on an IFR flight plan.

And..... I am instrument rated and current and I'm always flying single pilot.

Thanks,
John

[aloft]

If you have no outside visual references, whether due to clouds or absence of light, you're in actual instrument conditions (and should probably be on an IFR flight plan, or at least flying as if you were).

[Cessnaflyer]

Yeah it is fine to log it as instrument if you are using them solely to fly the aircraft with no outside references.

§ 61.51

(g) Logging instrument flight time. (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.

[SteveC]

Originally Posted by Cessnaflyer

Yeah it is fine to log it as instrument if you are using them solely to fly the aircraft with no outside references.

§ 61.51

(g) Logging instrument flight time. (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.

Doesn't it depend on what the definition of "actual instrument flight conditions" is?

[dc3flyer]

I only log actual when I am in IFR conditions.... ie, less than VFR visibility and cloud clearance. But, I understand that you are flying by sole reference to instruments in this situation so I would say it is pilot's discretion. You are the one that has to sign the page and say all entries are true.

[aloft]

Originally Posted by SteveC

Doesn't it depend on what the definition of "actual instrument flight conditions" is?

First, note that it say "instrument flight conditions", not "instrument meteorological conditions". The FAA is generally very specific in its choice of words.

I don't know what the legal definition of "instrument flight conditions" is, but I'm willing to bet that it's when flight by visual reference isn't possible.

[TripleSticks]

I'm definitely flying by reference to the instruments in these cases. But it's just in good weather. So if there's a plane in the area, I can spot it. Or if a car or some ground lights come then I could too. But recently I've been laser mapping the Everglades. There's nothing out there so I've been flying long stretches in the pitch black.

I never used to log actual instrument time without being on an IFR flight plan either but I've been doing this so much that I thought the question was pretty valid. It seems so far the general consensus is that I can log it as Actual.

[ctab5060X]

Read this...

http://forums.jetcareers.com/technic...while-vfr.html (Logging actual while VFR)

and the latter part of this...

http://forums.jetcareers.com/general...s-serious.html (Are these guys serious?)

Hope it helps...especially the first link.

[MidlifeFlyer]

Originally Posted by SteveC

Doesn't it depend on what the definition of "actual instrument flight conditions" is?

It does. Here's the FAA Legal Counsel's answer (note that some of the paragraph numbers within the reg have changed):

==============================
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
==============================

[DE727UPS]

"under actual (instrument meteorological conditions (imc))"

uh oh, did he just imply that "actual" and "IMC" are the same thing here in this FAA legal counsel answer?

Do you think he would say you are "actual" if you are 400 feet below the clouds with 100 mile vis?

[MidlifeFlyer]

Originally Posted by DE727UPS

"under actual (instrument meteorological conditions (imc))"

uh oh, did he just imply that "actual" and "IMC" are the same thing here in this FAA legal counsel answer?

Do you think he would say you are "actual" if you are 400 feet below the clouds with 100 mile vis?

No. "Actual IMC" means "in the clouds" as opposed to "IMC" which just means conditions less than VFR requirements. It's the word "actual" that makes the difference.