Should actual IMC be a requirment for IFR training?

[mscard88]

My understanding was always that if you must fly with reference to instruments to maintain control, it's IMC and can be logged as such... Even in the absence of clouds or fog.

Nope, only when you're in actual IMC may one log actual IMC. Under the hood is logged as simulated IMC.

 

[Bob Noel]

So, if you want to make it real, every pilot should have an ILS to cat 1 mins.

Think about the aircraft being used by the lowly ASEL pilot for instrument training.

The likelihood of getting actual Cat I minimums and not having conditions go lower (or having airports above minimums within range) is pretty low.

And ultimately, what is the value of requiring an ILS to Cat I mins? What problem is being solved that can only be done in actual IMC?

 

[EdFred]

Nope, only when you're in actual IMC may one log actual IMC. Under the hood is logged as simulated IMC.

That is incorrect. Chief counsel has said when you are flying in conditions that are VFR but you need flight by references to instruments (hazy day over Lake Michigan and can't make out the difference between the lake, the sky and there is no horizon, overcast night over the desert - or again Lake Michigan/Gulf of Mexico, wherever - with no ground lighting or stars) you may log it as actual instrument time. Not simulated, actual.

As a CFII you should know this.

Shamlessly stolen from another forum and posted by our own midlifeflyer:

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

 

[midlifeflyer]

There's no doubt at least some actual cloud time is an extremely good idea and should be done if feasible. I got an enormous benefit from the 6 hours of actual (including a real missed approach off an ILS) I received during my training.

But, as a number have pointed out, it can be unrealistic for folks who live in some parts of the country. In Colorado, I recall CFIIs grabbing their students (and former students) to go flying during the 3 weeks in June when there is flyable IMC.

The poll I'd be interest in as a follow-up is: How many of those who voted "Yes" to make it a requirement would themselves be willing to pay for transportation and a few days lodging in order to meet it?

 

[midlifeflyer]

That is incorrect. Chief counsel has said when you are flying in conditions that are VFR but you need flight by references to instruments (hazy day over Lake Michigan and can't make out the difference between the lake, the sky and there is no horizon, overcast night over the desert - or again Lake Michigan/Gulf of Mexico, wherever - with no ground lighting or stars) you may log it as actual instrument time. Not simulated, actual.

As a CFII you should know this.

Not every CFII can be expected to know some of the more esoteric and obscure issues, like the "moonless night" Chief Counsel opinion.

Come to think of it, I wonder how many "actual" hours have been logged in the more than 30 years since that letter was written.

 

[Henning]

I think if possible and the opportunity presents itself, then advantage should be taken. The problem with requiring it for a rating is that the regions where most of the big training operations are like Arizona and Florida, rarely is IMC safe to enter because it's typically bad assed thunderstorms.

 

[EdFred]

The poll I'd be interest in as a follow-up is: How many of those who voted "Yes" to make it a requirement would themselves be willing to pay for transportation and a few days lodging in order to meet it?

I voted yes, and I paid for my transportation to get actual.

Of course it was only a 20-25 minute drive worth of transportation cost and it was where I was doing my training anyway.

 

[flyingron]

I agree it is not practical. Frankly, other than for the psychological assurance that you've "done it" I don't even think it's essential. In actuality, actual is easier to many people than flying with the view limiting device.

 

[EdFred]

Not every CFII can be expected to know some of the more esoteric and obscure issues, like the "moonless night" Chief Counsel opinion.

Come to think of it, I wonder how many "actual" hours have been logged in the more than 30 years since that letter was written.

Well, they should.

And, I have. Then again I have Lake Michigan just to the west of me and routinely cross it. I have logged instrument time on at least 2 (maybe 3) occasions in the past few years - daytime and night time - even though it was VFR. I always try and take my students out over LM on days like that. Gives them a real sense of what happens when you go into a cloud, without actually going into clouds.

 

[Gubbins]

I find flying in real IMC to be much easier than simulated and experienced the same during training. With simulated IMC approaches you're always going down to rock bottom minimums, with real that is rarely the case. So I personally don't think it makes a difference doing it all with simulated during training.

I think it is a good idea to get some of course, along with getting some experience with icing too. I had a decent amount of real IMC during my training and one ice encounter and it was a whole lot better experiencing it for the first time with an instructor rather than by myself. Should it be a requirement though? Not in my opinion, I think that's going too far. Like others have said that could seriously impact your ability to get the rating in certain parts of the country.

 

[Bob Noel]

I find flying in real IMC to be much easier than simulated and experienced the same during training.

I looked forward to actual IMC. I always felt encumbered by the hood and foggles (plus, the CFII was always throwing tasks at me - after all it was a lesson). In actual IMC, it was more relaxing. Caveat: I'm talking about easy benign IMC.

 

[Sundancer]

No; not even a serious proposal. Outside the usually clumsy and ham-handed regs, and within the bounds of common sense, it'd be great to get some actual in training. If convenient IMC doesn't come-up, maybe some night time, no moon, under the hood, to simulate it a bit better.

I went shopping for some IMC after getting the rating; benign stuff, punching through layers, or through light cumulus, asking for an altitude that would keep me at least in-and-out, but with plenty of clear below and above. Just getting comfortable with "real". . .that may be the way to go, or something similar.

 

[EdFred]

The problem with foggles, and most hoods for that matter, is you can cheat. Check the compass for DG precession? Oh look, horizon (and the airport), or you can see the ground out the corner of the window. You want to really simulate instrument conditions? Get a safety pilot for the back seat to look out the pilot side windows and your CFII in the right seat like normal, and throw a sheet or blanket over your head and instrument panel so you can't get any visual cues at all.

 

[Henning]

The problem with foggles, and most hoods for that matter, is you can cheat. Check the compass for DG precession? Oh look, horizon (and the airport), or you can see the ground out the corner of the window. You want to really simulate instrument conditions? Get a safety pilot for the back seat to look out the pilot side windows and your CFII in the right seat like normal, and throw a sheet or blanket over your head and instrument panel so you can't get any visual cues at all.

This is so stupid. Why the **** would anyone cheat? You're learning to keep yourself alive in conditions and circumstances that will brook little error; this is the real world, not grade school. You can actually practice instrument flying quite well with no view limiting device at all just through focus and intent. If your intent is to focus on the panel and ignore outside reference, that is exactly what you will do.

 

[PPC1052]

I agree that actual is a really nice thing to experience during training. But I'm always reluctant to add more restrictions (read: cost) to an industry that's already struggling. I mean, are we having a lot of new instrument pilots crash when they enter IMC for the first time?

Where would we draw the line? How about a certain number of takeoffs and landings at high density altitudes? Takeoffs at max gross? Takeoffs and landings in crosswinds higher than xx knots? Spin training for everyone? All of these requirements would make for a better prepared pilot. But at what cost?

I hear ya'. But the whole point of the IFR rating is to fly in IMC. It's weird to me that you can get the rating to fly in IMC never having done it.

Remember, we aren't talking about adding cost to the private (although Tim would), we are talking about adding cost to the IFR add on.

 

[jordane93]

The problem with foggles, and most hoods for that matter, is you can cheat. Check the compass for DG precession? Oh look, horizon (and the airport), or you can see the ground out the corner of the window. You want to really simulate instrument conditions? Get a safety pilot for the back seat to look out the pilot side windows and your CFII in the right seat like normal, and throw a sheet or blanket over your head and instrument panel so you can't get any visual cues at all.

One of my private students would always look outside with the foggles so I took out my sectional and covered the windshield

 

[jordane93]

I hear ya'. But the whole point of the IFR rating is to fly in IMC. It's weird to me that you can get the rating to fly in IMC never having done it.

Remember, we aren't talking about adding cost to the private (although Tim would), we are talking about adding cost to the IFR add on.

But for people in some parts of the country it's nearly impossible to get actual during their training. It's a good idea but not practical.

 

[fiveoboy01]

Nope, only when you're in actual IMC may one log actual IMC. Under the hood is logged as simulated IMC.

I wasn't talking about under the hood, reread my post.

Night, no outside lights, or anytime you cannot discern a horizon and need to use the instruments to keep the shiny side up... can be logged as actual. Clouds or not.

 

[fiveoboy01]

As for the rest of the replies, yes it is definitely totally impractical to require it where some areas of the country might only get a few days of IMC conditions a year.

I could modify it to say "required where IMC is a somewhat common occurence" but that would be two sets of standards for one ticket. I can see where this would make a mess of everything. Best to leave it as is. I knew that IMC conditions are sparse in some areas, but wasn't aware of the severity of it.

I do agree that if the opportunity presents itself, the student should be taken up in IMC. Foggles are effective for the most part but I don't feel they are quite the same. Actual gives you some real world experience with what you might encounter. And it's a lot more fun

 

[Brad Z]

Who's the PIC for the PPL?

§61.47 will answer your question.

§61.47 Status of an examiner who is authorized by the Administrator to conduct practical tests.
(a) An examiner represents the Administrator for the purpose of conducting practical tests for certificates and ratings issued under this part and to observe an applicant's ability to perform the areas of operation on the practical test.

(b) The examiner is not the pilot in command of the aircraft during the practical test unless the examiner agrees to act in that capacity for the flight or for a portion of the flight by prior arrangement with:

(1) The applicant; or

(2) A person who would otherwise act as pilot in command of the flight or for a portion of the flight.

(c) Notwithstanding the type of aircraft used during the practical test, the applicant and the examiner (and any other occupants authorized to be on board by the examiner) are not subject to the requirements or limitations for the carriage of passengers that are specified in this chapter.

 

[Brad Z]

Funny that while the majority of folks here think the FAA over-regulates GA, the majority voted on this poll for a more burdensome regulation.

 

[Everskyward]

Unless there is a clear trend showing that people are crashing on their first few attempts in IMC after getting their instrument rating, having not received any training in actual during the time they acquired the rating, I don't think we need to consider it. Even then, we would need to compare that set of people with others who had experience in actual while getting their instrument rating. I don't think that anyone here has shown even one accident which was attributed to this, just the general feeling that it would be better if...

That said, I think getting experience in actual with an instructor is a good idea, I'm just not in favor of making it mandatory.

 

[Henning]

As for the rest of the replies, yes it is definitely totally impractical to require it where some areas of the country might only get a few days of IMC conditions a year.

I could modify it to say "required where IMC is a somewhat common occurence" but that would be two sets of standards for one ticket. I can see where this would make a mess of everything. Best to leave it as is. I knew that IMC conditions are sparse in some areas, but wasn't aware of the severity of it.

I do agree that if the opportunity presents itself, the student should be taken up in IMC. Foggles are effective for the most part but I don't feel they are quite the same. Actual gives you some real world experience with what you might encounter. And it's a lot more fun

Exactly, leave it as it is, people will get it when they can and it's safe, it already happens.

We have IMC here most days, Embry Riddle will not allow their planes to operate in it, it is not particularly unreasonable. In Florida most days you have about 15 minutes between the point of usable/legal IFR/IMC conditions, and CB building convection cells that will kill you. Otherwise the cloud layer is not dense enough to count as actual. A few weeks in the winter is when we get fly-able IMC, that's about it.

Most CFIIs will try to have you in the scattered layer popping in and out, but you can't count it as actual.

 

[Jaybird180]

I voted yes, but on second thought, maybe not a requirement for IR, but a DEFINITE requirement for CFII. Can't have the blind leading the blind.

I like this idea.

SPIFR 20hrs minimum. Or create an addendum rating, like "Master CFII" with a boatload of requirements.

 

[Brad Z]

I like this idea.

SPIFR 20hrs minimum. Or create an addendum rating, like "Master CFII" with a boatload of requirements.

Or a perspective instrument student can simply ask the CFII before hiring him, "say, have you ever actually flown inside a cloud?"

If they lie, well, they could lie about logging flight conditions too.

 

[PPC1052]

This is so stupid. Why the **** would anyone cheat? .

Sometimes its not intentional. When you check the compass for DG procession, sometimes you can't help but see. If there is a sliver of light from the corner of your eye, it might catch your attention, so you look to see what it is, then you realize its the ground.

 

[Henning]

I like this idea.

SPIFR 20hrs minimum. Or create an addendum rating, like "Master CFII" with a boatload of requirements.

The entire instruction industry for the most part is the blind leading the blind. Either it's good enough for any rating, or it's good enough for no ratings. I always thought CFI ratings should be 1500hr ratings like ATP.

 

[PPC1052]

But for people in some parts of the country it's nearly impossible to get actual during their training. It's a good idea but not practical.

Hey, there has to be some benefit to living in the Midwest. It's expensive to live where there is good weather year round. This is just another cost of your life choice.

 

[Jaybird180]

And where would you draw the line?? A little poof through a few clouds?? The real challenge is actual to cat 1 mins. Ceiling 0, 1800 rvr. A hood cannot duplicate that. It may duplicate a 200' breakout and clear below, but that's a far, far, far cry from 0 and 1800 rvr.

So, if you want to make it real, every pilot should have an ILS to cat 1 mins.

That's too much for the guy going to get pancakes on Saturday.

 

[Jaybird180]

This is so stupid. Why the **** would anyone cheat? You're learning to keep yourself alive in conditions and circumstances that will brook little error; this is the real world, not grade school. You can actually practice instrument flying quite well with no view limiting device at all just through focus and intent. If your intent is to focus on the panel and ignore outside reference, that is exactly what you will do.

It is natural to be unable to resist the urge to break a natural habit, like using your eyes for spatial orientation. View limiting devices are necessary and focus counts for very little. Remember that the objective is to allow the student to become immersed in the sensory deprivation experience sufficient for their brain to make the transition to flying solely by reference to the airplane instrument panel, become one with the airplane.

My first flight in actual, we punched through a couple thousand foot layer and when I got on top, I found having a cloud under me distracting so I put the hood back on. It wasn't rational.

 

[Kritchlow]

Well, if you're trying to stop cheating (inadvertent or intentional) , than ALL of the training should be actual.

 

[Palmpilot]

Here are the main differences I have noticed between hood training and actual:

1. The first time I was about to descend into a solid cloud deck on an approach after getting the rating, I felt a little fear. I handled it by pretending I was in a simulator, and making sure I flew as I was trained.

2. Especially on a non-precision approach, when I start to break out under a fairly low ceiling without having the airport in sight, I have noticed that this is the time when I am most in danger of busting minimums, not because of any desire to "duck under," but because the view of the ground distracts me from the instruments.

3. Turbulence is more likely.

4. When icing is possible, I have to keep an eye out for that.

 

[Henning]

Sometimes its not intentional. When you check the compass for DG procession, sometimes you can't help but see. If there is a sliver of light from the corner of your eye, it might catch your attention, so you look to see what it is, then you realize its the ground.

It doesn't matter if you see if you are not acting on the information. You can choose to ignore correcting until you get your eyes back on the instruments, and the actual effect in training hand eye remains the same.

 

[MAKG1]

Well, if you're trying to stop cheating (inadvertent or intentional) , than ALL of the training should be actual.

Even one flight at night makes the inadvertent cheating much more obvious. BTDT. After that, it's much, MUCH easier to avoid doing it again, even with foggles.

 

[Palmpilot]

Intentional cheating would be stupid, as it works against one's survival interest. I've never worried about inadvertently picking up outside cues, because for me, it doesn't seem to happen enough to be significant.

As for getting outside cues when checking the compass, I would worry about that if I was discovering that I had departed level flight when I looked up, but I haven't had that problem.

Except for summers in Alaska, I think a requirement to do some of the instrument training at night would be feasible, and might even be more beneficial than a requirement for instrument weather conditions.

 

[Henning]

Well, if you're trying to stop cheating (inadvertent or intentional) , than ALL of the training should be actual.

If you're cheating, you're only cheating yourself and not getting the training you're paying for. If you just want a rating to be able to say you have a rating, you have a pretty expensive ego monkey on your back.

 

[Palmpilot]

This would be an interesting experiment to test the significance of inadvertent outside cues:

Go up with an instructor, and put on a pair of foggles that have the clear part taped over, and see if you're able to maintain level flight.

 

[Henning]

This would be an interesting experiment to test the significance of inadvertent outside cues:

Go up with an instructor, and put on a pair of foggles that have the clear part taped over, and see if you're able to maintain level flight.

I trained with goggles and never got outside cues without looking for them, even on short final with a close, high contrast scene forward.

 

[Henning]

Actually, especially early on, it's good to be able to pop your head up so you can form mental corollaries between the panel and the world outside to help form your foundation spacial interpretation abilities. There is a reason this is a 40 hour process to learn.

 

[FlySince9]

I voted yes because I, personally, would like to have the experience during my IR training, but I'm not in support of more regulations... Not long ago I was talking to a guy who went to some 2 week, IR speed-course, somewhere... He was about to set off on his first flight in real clouds... I could tell he was really nervous about it... I don't want that to be me...