Can I file and fly IFR without the rating?

Discussion in 'Flight Following' started by VWGhiaBob, Oct 7, 2017.

  1. iamtheari

    iamtheari Cleared for Takeoff

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    What I was saying is that, unless a person can cite to a specific section and subsection in part 91 that requires an unrated pilot in addition to the PIC when operating under IFR, the rule about both pilots logging the time does not apply. Nobody can cite to such a section because there isn't one. Thus these two hypothetical pilots can't both log the time.

    I'm sure someone will come along and try to explain it in yet another way in the hope of being clear enough to prove you wrong about the futility of the matter. That's how I got involved. Oops.
     
  2. Greg Bockelman

    Greg Bockelman Administrator Management Council Member

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    You don't have to be INSTRUMENT rated to log PIC in the clouds, just rated for the airplane you are flying. That has been beaten to death.

    Having said that, in this scenario the only way two pilots can log PIC in actual conditions is if the flying pilot is "under the hood." Which pretty much defeats the purpose.
     
  3. dmspilot

    dmspilot En-Route

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    He didn't say that or anything like that :confused:
     
  4. Greg Bockelman

    Greg Bockelman Administrator Management Council Member

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    He made a comment about an unrated pilot. I was just clarifying the difference in the two "ratings".
     
  5. iamtheari

    iamtheari Cleared for Takeoff

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    This is a somewhat funny situation in that the only person who can log the PIC time is the one whose presence is not necessary to make the flight. That might be why it is possible to conjure up some confusion on this topic.
     
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  6. Palmpilot

    Palmpilot Touchdown! Greaser!

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    With Part 1 and Part 61 ascribing different meanings to the phrase "pilot-in-command," confusion is inevitable.
     
  7. MauleSkinner

    MauleSkinner En-Route

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    The regs weren't written to help people build time, but they're read with that goal in mind.
     
  8. apr911

    apr911 Pre-takeoff checklist

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    They're written to ensure people dont do stupid s**t and are an attempt to ensure they have the experience ascribed by a certain amount of hours. Which is what makes the OPs original question and the issue of PIC in Actual Instrument conditions so interesting.

    The OP wants to gain valuable experience working the IR system and has a rated safety pilot willing to help him do just that but the FAA says its not allowed (at least to the extent of logging and receiving credit for the time though whether he can actually do it is part of this debate) . Similarly an IR rated pilot in their "grace" period is not eligible to work the IR system without a "current" IFR pilot.

    It's generally agreed that actual IMC is a greater experience than simulating instrument conditions with a hood, yet the regs offer no way to obtain actual instrument time for students or IR rated pilots who's currency has lapsed without a CFII, which unless you happen to be friends with a CFII, costs money. Yet a VFR-only pilot can legally log instrument time any they fly into a cloud or experience a loss of visual horizon.

    The question raises one of the many glaring problems in the FAR/AIM; Multiple definitions of night, PIC, XC, CFI logging, endorsement logging and a slew of other contradictions, exceptions and interpretations raises the question of just what the FAA's end-goal is. I'd argue that many of the regulations create a less competent and safe pilot than we might otherwise be able to achieve without the current iteration of the FAR.
     
    Last edited: Oct 30, 2017
  9. MauleSkinner

    MauleSkinner En-Route

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    Regulations don't create pilots.

    The inability to log something does not detract from a pilot's knowlege, experience, or competence.
     
  10. dmspilot

    dmspilot En-Route

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    What is not allowed?

    What?
     
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  11. apr911

    apr911 Pre-takeoff checklist

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    True however, the FAA and potential employers don't care about how much knowledge, experience and competence you purport to have, they care about how much you can show in the form of time logged in accordance with the regulations.
     
  12. MauleSkinner

    MauleSkinner En-Route

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    Yup, but again, the regs aren't there to help you build time. The goal of the FAA isn't to get you the most time in your logbook in the shortest time span. That's the (IMO somewhat misguided) goal of pilots.
     
  13. apr911

    apr911 Pre-takeoff checklist

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    I dont disagree with it being a misguided pursuit but the goal or bar isnt generally set by them and I feel like most pilots (and people in general) chase the hours in order to fulfill FAA, insurance or Employer requirements. I dont think anyone would really care what they log if it werent for that... I know plenty of people who have stopped logging complex, high performance, tailwheel and other endorsement type times except for currency because they have surpassed the number of hours required to no longer be hassled by the insurance or FAA or employers. Same goes for other "logged" activities I participate in such as skydiving and scuba diving.

    Its not just a pilot issue either as I experience it regularly in IT too. Arguably, we've developed knowledge based certifications to help vet and gauge experience but when an employer requires an employee to obtain a certificate they wouldnt have sought on their own by tying it to a promotion or raise, the employee will obtain the certificate in the quickest, cheapest and easiest manner possible and as a result there are a huge number of paper tigers out there without the experience or knowledge the certificate is supposed to represent so we're stuck again using a measure of time. Still when I conduct technical hiring interviews Im always struck by how much people play up their time in a role... I would hire someone with 3 years of clearly varied experience over a person person with 10 years of experience in the same job (i.e. 1 year of experience 10 times over) any day.

    Similarly, I would feel more comfortable getting in the plane with a pilot who went that extra mile to practice flying actual IFR with a rated co-pilot to be legal and help them stay safe than I would with a pilot with an equal amount of actual instrument time done entirely solo or with non-pilots. Or perhaps as a starker contrast someone with 30 hours of xc time going to 25 different locations or using 25 different routes vs someone with 50 hours xc time going to the same 5 places using the same 5 routes.

    The FAA's goal is to create skilled and competent pilots with the experience and decision making ability necessary to not put the rest of us at risk. Unfortunately, as flawed as it is, nobody has come up with a better way of measuring experience except by "time" and while FAA wants Pilots to show good ADM it stacks the deck in favor of the pilot who practices in the less safe environment of single pilot IFR, is more willing to blur the lines and log time that might have been more questionable or just stick to the letter of the law and do it all simulated vs the pilot who gains the best actual real world experience in a completely safe manner but sticks to the letter of the law when it comes to logging and thus cant receive credit for it. The FAA's rules often throw the pilot out with the bathwater thus contributing to the pursuit of hours and not experience as a goal.

    I take similar issue with the long XC required for commercial. I feel its unrealistic that a pilot is going to fly 250+NM with just themselves and believe it would be consistent with the intent of the regulation to get you out of your comfort zone and the real world to allow passengers; particularly a fellow pilot who, knowing the purpose of the flight, could refuse to assist the pilot and even act as a purposeful distraction during the flight. It would then make the regulation more consistent with other cross countries that arent required to be solo and can be conducted as a single loop as one pilot could fly the 250nm between 2 of 3 points/300 nm total distance between all 3 points on an outbound leg and let the other pilot fly the return leg instead of forcing one pilot to fly and shoulder the cost of a 500+nm roundtrip which might cause said pilot to make some questionable decisions thinking with their wallet instead of their head. The second pilot could then act as a check & balance against such a decision when both pilots encounter and weigh an inflight go/no-go situation 100+nm from the home airport.

    In the end the FAR's are what they are and there's not much that can be done about it. Unfortunately that's what happens when you have a bunch of bereaucrats trying to write legalese in an effort to protect the general public by regulating and removing stupidity from the cockpit due to the continual demise of what used to be called common sense, though its not so "common" anymore.
     
    Last edited: Nov 3, 2017
  14. MauleSkinner

    MauleSkinner En-Route

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    My experience differs from yours when I compare pilots who fly by themselves with those who only fly with other pilots.
     
  15. Checkout_my_Six

    Checkout_my_Six Final Approach

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    well....the 1,500 hr rule kinda reads a little differently. o_O
     
  16. MauleSkinner

    MauleSkinner En-Route

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    You're saying the 1500 hour rule helps people build time?
     
  17. Checkout_my_Six

    Checkout_my_Six Final Approach

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    "help"?.....are there any rules that actually help with that?
     
  18. mtuomi

    mtuomi En-Route

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    Unrealistic? I had like 20 flights like that before I did my commercial. 250 is not that far when you are flying an airplane.
     
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  19. MauleSkinner

    MauleSkinner En-Route

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    No...but it appeared you disagreed with my statement that they didn't help build time.
     
  20. azure

    azure Final Approach

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    Not sure I understand your analogy between practicing solo in actual IMC and flying the same cross country over and over again. What difference does it make whether someone practices solo vs with a co-pilot (I am assuming you meant a non-CFII)? It seems to me a better analogy would be someone whose instrument practice consists of shooting the same 2 or 3 familiar approaches, say at home base or a nearby field.

    I can see an advantage to practicing with a co-pilot or safety pilot in the sense that a second person in the plane can provide distractions. And of course practice (training) with a qualified instructor (CFII) is the best way of all to maintain currency and proficiency. I just don't see the two situations you are comparing as analogous in any way.