Letter to the FAA re Digital Clock for IFR

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machkhatib

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Mach
I wrote to the FAA in an attempt to clarify whether a digital clock must display a clock at all times in order to qualify as a clock for the purpose of meeting IFR equipment requirements. I made the argument that a digital clock should NOT have to display a clock at all times and I urged the FAA to adopt a pragmatic interpretation.



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I would have liked to have seen some argument that your proposed interpretation is more consistent with the rule's intent than the present interpretation. Why does the current interpretation require the clock be visible at all times? Is that consistent with the purpose of the rule? Why is your interpretation better? The fact that the current interpretation excludes some devices that exist isn't really a reason to change it.

And FWIW, the FAA Letter to uAvionix states that the FAA accepted "without further review" uAvionx's statement that the clock function meets the regulations. It was not a finding or statement by the FAA that it actually does. I would call your citation, especially eliding the important context, disingenuous. ETA: I found that in a February 13, 2023 letter to uAvionix. You cited a February 1, 2021 letter, which I couldn't find, but maybe it says something different.
 
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Lindberg said:
I would have liked to have seen some argument that your proposed interpretation is more consistent with the rule's intent than the present interpretation.
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I made that argument at the end of the second page. The intent of the rule, IMO, is to ensure accurate time keeping is available during IFR flight.

“Pilots are getting the time keeping information they need, when they need it, in the format they want it, from their GPS, PFD, MFD, and/or other appliances. If the FAA wants to ensure that pilots have accurate time keeping available to them during IFR flight, it does not make sense to disqualify an appliance as a clock for IFR flight just because the appliance's basic clock is a couple of taps or knob-twists away on a page that is not displayed at all times.”

Lindberg said:
And FWIW, the FAA Letter to uAvionix states that the FAA accepted "without further review" uAvionx's statement that the clock function meets the regulations. It was not a finding or statement by the FAA that it actually does. I would call your citation, especially eliding the important context, disingenuous.
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Not quite. The FAA didn’t merely accept uAvionix’s statement; it went further and said that any digital clock which meets AC 20-94A automatically meets 14 CFR 91.205(d)(6).

“In addition to the above, we accept your statement, without further review, that both the AV-20 and AV-20-S meet the requirements for a Digital Clock as defined by AC 20-94A. Clocks which meet the requirements of AC 20-94A also meet the requirements of 14 CFR 91.205(a) and 14 CFR 91.205(d)(6).”
 
hindsight2020 said:
that's a placeholder, homeboi didn't actually use [Name "callsign" Last] format in actual correspondence to civilians..... right, Right?!

Allied striped RVs and now this ish....
:biggrin:
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It’s my nickname people have called me since I was 9 years old, not a call sign, but thanks for whatever that was.

Anyone want to talk about clocks for IFR?
 
midlifeflyer said:
The response should be interesting.
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There are two possibilities:

1. The Office of the Chief Counsel deems the matter posed by my letter neither significant nor novel, and sends me a letter that it will decline to take up the issue.

Or

2. The Office of the Chief Counsel decides to take up the issue. If so, it will probably be months before they actually provide me with their answer and/or interpretation.
 
machkhatib said:
I made that argument at the end of the second page. The intent of the rule, IMO, is to ensure accurate time keeping is available during IFR flight.

“Pilots are getting the time keeping information they need, when they need it, in the format they want it, from their GPS, PFD, MFD, and/or other appliances. If the FAA wants to ensure that pilots have accurate time keeping available to them during IFR flight, it does not make sense to disqualify an appliance as a clock for IFR flight just because the appliance's basic clock is a couple of taps or knob-twists away on a page that is not displayed at all times.”



Not quite. The FAA didn’t merely accept uAvionix’s statement; it went further and said that any digital clock which meets AC 20-94A automatically meets 14 CFR 91.205(d)(6).

“In addition to the above, we accept your statement, without further review, that both the AV-20 and AV-20-S meet the requirements for a Digital Clock as defined by AC 20-94A. Clocks which meet the requirements of AC 20-94A also meet the requirements of 14 CFR 91.205(a) and 14 CFR 91.205(d)(6).”
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I'm still not seeing the part about the intent of the rule.
 
machkhatib said:
There are two possibilities:

1. The Office of the Chief Counsel deems the matter posed by my letter neither significant nor novel, and sends me a letter that it will decline to take up the issue.

Or

2. The Office of the Chief Counsel decides to take up the issue. If so, it will probably be months before they actually provide me with their answer and/or interpretation.
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3. The Office of the Chief Counsel deems the matter posed by my letter neither significant nor novel, and punts to another FAA group. That doesn't seem particularly likely on a question like this one.
 
machkhatib said:
Anyone want to talk about clocks for IFR?
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This thread, starting from about post #34:
www.pilotsofamerica.com

Bad tach...should I go GI 275 EIS?

My A&P just declared my tach junk. I've got a steam gauge 172S. Looks like the a direct replacement SLI model is about $800 plus another $120 or so if I want to set the tach number to match the old one. I've been toying with the idea of putting in an EIS of some sort for a while. The GI 275...
www.pilotsofamerica.com www.pilotsofamerica.com

Post #39 points out that the Davtron M803 has a "page" the pilot may navigate to somewhere on the appliance (the pages being "UT", "LT", "FT", "ET") and does not have a "permanent" clock display yet it is generally accepted as an IFR clock. @Ryan F. goes on to explain why.
 
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asicer said:
This thread, starting from about post #34:
www.pilotsofamerica.com

Bad tach...should I go GI 275 EIS?

My A&P just declared my tach junk. I've got a steam gauge 172S. Looks like the a direct replacement SLI model is about $800 plus another $120 or so if I want to set the tach number to match the old one. I've been toying with the idea of putting in an EIS of some sort for a while. The GI 275...
www.pilotsofamerica.com www.pilotsofamerica.com

Post #39 points out that the Davtron M803 has a "page" the pilot may navigate to somewhere on the appliance (the pages being "UT", "LT", "FT", "ET") and does not have a "permanent" clock display yet it is generally accepted as an IFR clock. @Ryan F. goes on to explain why.
Click to expand...

He explains that even though the Davtron doesn’t always display a clock, the page is always accessible: In the case of an installed clock such as the Davtron models, you cannot turn the clock "off."

Using that definition, there are many, many devices that would qualify as IFR clocks. My GNX-375 has a clock page. I cannot disable it. I can always navigate to the clock page if I wish.

That’s what I’m trying to get the FAA to clarify - that a clock doesn’t need to always be displayed to be considered “permanent.” But the FAA put “permanent clock display” and “permanent clock presentation” in writing in the Nkugba letter. Those are their words, not mine.
 
RyanShort1 said:
Writing to the GC is a sign of insecurity and, potentially, malice towards other pilots
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What’s the punch line?

I’m trying to get clarity and I argued to relax the rules, not tighten them. The “permanent clock display” interpretation in the Nkugba letter is absurd if taken to mean (as some pilots and examiners believe) that the clock must always be displayed.
 
Lindberg said:
There's a rule when questioning witnesses on the stand, and it applies to chief council letters as well: Never ask a question you don't want to hear the answer to.
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DING DING DING! Winner!

I'd elaborate a bit, though - Never ask a question if there's any possible answer you will find detrimental.
 
Mostly, in the current environment, it's unwise to presume that the letter will be answered as favorably as possible.

With regards to my previous post, it's a form of extreme insecurity to "need" a letter to clarify something that exists on multiple panels of certified aircraft.

Trying to force the FAA to look at it more closely doesn't mean that the outcome will be favorable, and presumes a "government knows best" attitude, when in reality they are humans just like yourself, and likely even less knowledgeable about specific avionics and aviation situations than those that build them and use them regularly. Their specialty, is regulation, and they tend to fear the public more than desire to make pilots lives easier, so the presumption is that a significant portion of the time, their interpretation will be "conservative" and tend towards more, rather than less restrictive.
 
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Government regulator conservatism comes from there being legal disincentive to making a decision of non-zero risk. There’s just no payback to being helpful, especially when counsel is involved. Counsel is there to protect the entity, not you.

Now, that being said, it sure feels like you’re being beat up by keyboards a little on here. Might have been better to wait to hear from FAA and THEN post the results. Then we could be mad at FAA, lol!
 
So, you wrote not one, but two letters to a federal agency, about a clock, with footnotes, and suggested that you understand the regulations about clocks better than they do, to the point of suggesting what their interpretation of the "clock issue" should be.

If ANY of that sounds like a good idea in retrospect, then in the kindest possible way I don't think you should be flying an airplane. It's a half step away from wanting to put up warning signs in the middle of the Pacific ocean to warn boaters not go accidentally go over the edge. Edit - maybe that's too harsh. maybe writing a letter to chief council of the FAA about a clock makes sense. It really doesn't to me, though.
 
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Albany Tom said:
So, you wrote not one, but two letters to a federal agency, about a clock, with footnotes, and suggested that you understand the regulations about clocks better than they do, to the point of suggesting what their interpretation of the "clock issue" should be.

If ANY of that sounds like a good idea in retrospect, then in the kindest possible way I don't think you should be flying an airplane. It's a half step away from wanting to put up warning signs in the middle of the Pacific ocean to warn boaters not go accidentally go over the edge.
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Oh, haven't you heard? The edge is beyond the Antarctic ice wall, and any airplane that tries to fly down there to get a look at it will be shot down! :rofl:
 
I may be in the minority here, but I like CC letters. It clears up ambiguity. Perhaps they seem incorrect, but at at least you have a standard of which to abide.

Note: when I was in the GA world, things were much simpler. No internet to discuss how to log, etc…

In the 121 world, I don’t give a crap. I’m covered by abiding to our SOP’s, and published procedures.
 
There are GPSs and Nav/Comms that display course direction on them but I don’t think one will be able to successfully say that can replace an independent indicator.

Clocks buried even a page down in an AI defeat the purpose of the AI, even if it’s a backup AI. If a clock is considered an essential instrument for IFR, then I personally don’t think it makes sense to allow a choice between two required instruments, even if one can say they can be toggled between.

Now, using the clock function on a transponder where it’s replacing something nonessential like pressure altitude, seems reasonable. And putting the clock as a field on the AI or GPS screen would work too.

But IF the clock is deemed important in the way a course indicator is, then similar requirements should seem to apply.
 
I think we should keep the clock and timer function separate.
If you need a timer for an approach, you’re going to have plenty of time to navigate any menus.
I’ve never needed a clock at moments notice either, I think I only needed it on the ground when getting IFR clearance. Holds, mandatory reporting points are something I haven’t done.
Can someone point out how you would need either function at a moments notice?
 
MooneyDriver78 said:
I think we should keep the clock and timer function separate.
If you need a timer for an approach, you’re going to have plenty of time to navigate any menus.
I’ve never needed a clock at moments notice either, I think I only needed it on the ground when getting IFR clearance. Holds, mandatory reporting points are something I haven’t done.
Can someone point out how you would need either function at a moments notice?
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I don’t think it’s about having a clock displayed at a moment’s notice. Nor really about your void time clearance. It’s about having a clock which shows hours, minutes, and seconds displayed at the same time as you are using other functions - while you are flying a timed localizer approach with no GPS availability to identify the missed. While you are holding and need to keep track of both those 1-minute legs and your EFC time.

Bear in mind this is a requirement which was created at a time when the time was essential for navigation and position reporting. At least part of the issue here is a recurring one - regulations created for a non-radar, limited-communication environment where the height of navigation was NDB, being applied in a modern world.
 
machkhatib said:
He explains that even though the Davtron doesn’t always display a clock, the page is always accessible: In the case of an installed clock such as the Davtron models, you cannot turn the clock "off."

Using that definition, there are many, many devices that would qualify as IFR clocks. My GNX-375 has a clock page. I cannot disable it. I can always navigate to the clock page if I wish.

That’s what I’m trying to get the FAA to clarify - that a clock doesn’t need to always be displayed to be considered “permanent.” But the FAA put “permanent clock display” and “permanent clock presentation” in writing in the Nkugba letter. Those are their words, not mine.
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This is a genuine question. Why do you need their clarification?
 
Tarheelpilot said:
This is a genuine question. Why do you need their clarification?
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That's a good question. History has shown multiple times that there have been things pilots have done for decades that appeared compliant - until someone decided to ask the Chief Counsel a question that was not needed. Too often, the answer is the one you don't want.

I can think of situations where an answer might be needed.
 
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Here's a bit of a twist: it seems like a lot of digital clocks that claim to be approved for IFR flight do not display seconds.
They have HH:MM and a standalone MM:SS timer mode. How is that ok?
 
AV8R_87 said:
Here's a bit of a twist: it seems like a lot of digital clocks that claim to be approved for IFR flight do not display seconds.
They have HH:MM and a standalone MM:SS timer mode. How is that ok?
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Post #44 attempts to answer this:
www.pilotsofamerica.com

Bad tach...should I go GI 275 EIS?

No. Clearly so, as it's what provides the clock for every steam gauge, IFR-ready 172S. But...why? The logic doesn't make sense...why is it OK for Davtron but not OK for other avionics?
www.pilotsofamerica.com www.pilotsofamerica.com
 
midlifeflyer said:
I don’t think it’s about having a clock displayed at a moment’s notice. Nor really about your void time clearance. It’s about having a clock which shows hours, minutes, and seconds displayed at the same time as you are using other functions - while you are flying a timed localizer approach with no GPS availability to identify the missed. While you are holding and need to keep track of both those 1-minute legs and your EFC time.

Bear in mind this is a requirement which was created at a time when the time was essential for navigation and position reporting. At least part of the issue here is a recurring one - regulations created for a non-radar, limited-communication environment where the height of navigation was NDB, being applied in a modern world.
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This, plus the "and, so, therefore . . ." part, is what's missing from the OP's letter.
 
Zeldman said:
Put the clock the FAA wants in your plane, in your plane.

Put what clock you want to use on your wrist.
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Probably less now with high tech equipment, but digital timers like this velcroed to the panel were common with the old analog panel clock just sitting there unused. I used one for years.

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^^^ Looks similar to the one I used when I was an instrument student learner...
 
My first question when I see people doing things like sending this letter to the FAA: What problem does it solve?

My second thought:

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jimhorner said:
My first question when I see people doing things like sending this letter to the FAA: What problem does it solve?

My second thought:

c1f3f2341319ef7ea63aad4892bce12f.jpg
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How about the beatdown from the other campers for poking the bear? Is complaining about that permissible?

Perhaps a letter to the Chief Counsel for the National Parks Service may be in order for clarification on that point...
 
Always think down the road for the consequences of writing to the Chief Counsel. Not just for yourself, but are you going to screw your fellow aviators over?
 
machkhatib said:
...I argued to relax the rules, not tighten them....
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A distinction without a difference. I've spent a career working for the government... (admittedly not the FAA) ... several different government bodies. One thing I've learned: it is always easier for those in charge to say "no" than "yes", or rule more restrictive than less. It's just the way government works. Another thing I've learned: don't poke the bear! Things with vague or nonspecific rules give you wiggle room. Asking for clarification almost always results in a tightening of the rules.
 
Country Flier said:
A distinction without a difference. I've spent a career working for the government... (admittedly not the FAA) ... several different government bodies. One thing I've learned: it is always easier for those in charge to say "no" than "yes", or rule more restrictive than less. It's just the way government works. Another thing I've learned: don't poke the bear! Things with vague or nonspecific rules give you wiggle room. Asking for clarification almost always results in a tightening of the rules.
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"Thank you for pointing out the loophole in our rules. We'll correct that immediately.
Love,
Office of the Chief Counsel"
 
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