Training for IFR in non-IFR aircraft

Ed Haywood said:
You guys are dancing around the remaining issue I need help with to decide if this is a cost effective path. Let's narrow it down by restating the question.

What percentage of a typical IFR training course can I accomplish effectively in my aircraft, versus how much would I need to obtain another aircraft for?

Let's say it's 50/50, or 75/25. I can do the math from there to see if the rental cost savings pays for the equipment
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On the equipment side (I'm an in a similar situation), I was looking at the VAL 429 nav+ILS radio. Small form factor, less than $2k when I last looked. Gives you precision approach capability. Not sure if they are still being manufactured. I have a VFR equipped RV now, and would like to brush the dust off of my instrument rating with some training but would prefer not add $10k+ avionics to the RV, especially since I might be trading for a larger plane in the near future.
 
Salty said:
Having the equipment installed will raise your resale a bit also, plus you'll have it available to stay proficient and possibly save your butt some day.
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Absolutely, and that second part is a big reason why I'm interested in doing it this way.

I've got plenty of dough to go rent a glass panel 172 and knock out the rating. But then what? My plane is my plane, and I'm not going to buy or rent another plane for trips.

Heck, I'd rather do 75% of the training, skip the rating, but feel like I could handle any situation I bumbled into.

The question is whether I can have my cake and eat it too. Do 75% in my plane, switch to a more suitable aircraft at the end to prep for the checkride and get some actual IMC, then go back to mine with improved equipment and greater confidence for whatever adventures await.
 
Ed Haywood said:
I assume they have flight instruments, though? Decathlon just has a leather seat back. :)

I could rig up the hood from hell in a tandem plane. Fasten cloth to a hat and then velcro it to the glare shield and side panels, so zero chance of peeking. Might as well be in real IMC.
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But the seats are closer together. People teach in tandem aircraft similar to Decathlon all the time. No VFR instruments back there either.

Look at the "hood" for a T-38. It fully encloses the rear cockpit. Student sits in the rear seat for instrument flights.
 
MauleSkinner said:
My argument is based on the regs and the 8900, which are valid and say nothing about violating someone for not being able to comply with a vector for
either safety or regulatory compliance.
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Hmmm... Interesting question. My reply would have been 8900 is only part of it and you cannot exclude Legal Interpretations. But... They rescinded the LI that said you could get violated if you refused an ATC instruction. So is ALL of the LI rescinded or only the part on the training.

But to clarify, don't assume that just because 8900 says anything on any subject that that is the ONLY thing you need to follow. The FAA will go to various documents you need to be aware of. A lot of people say the AIM is not regulatory, yet I've seen people pull up cases where the AIM is what busted someone. Yes they used a Reg to get them, but specifically said that not following the AIM then broke that Reg. Don't think it was Careless and Reckless, but that would be an easy umbrella Reg to use.

It will take months and I don't know if they will even reply. But I am writing in to the Chief Council to confirm you can indeed file IFR in a VFR only aircraft. I think just like they overturned the under council for the Theriault interp on the training because that is what they were asked about. Had they also asked about filing, it wouldn't shock me that they would have said no on that too. But they didn't, so it is still a gray area.... By rescinding Theriault, did they rescind everything include where it says you can file?
 
Ed Haywood said:
You guys are dancing around the remaining issue I need help with to decide if this is a cost effective path. Let's narrow it down by restating the question.
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If you said, I missed it. Where are you located?

I'd *guess* that at least 50%, maybe more, would have been cancelled if I had to stay VMC. Now were all of those flights in solid IMC, not even close. But there were always those low clouds or even some puffy slightly high clouds that you go through on legal VFR days. But if ATC said turn right, you turned right. Especially in the NYC area.
 
M20K said:
If you said, I missed it. Where are you located?

I'd *guess* that at least 50%, maybe more, would have been cancelled if I had to stay VMC. Now were all of those flights in solid IMC, not even close. But there were always those low clouds or even some puffy slightly high clouds that you go through on legal VFR days. But if ATC said turn right, you turned right. Especially in the NYC area.
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Tampa, FL. Most days Nov-March are CAVU. Most days Jun-Sept start out few/scattered clouds with 3K bases in the morning, and progress to massive thunderstorms by late afternoon.
 
Ed Haywood said:
Most days Jun-Sept start out few/scattered clouds with 3K bases in the morning
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Looking at the Approaches at Tampa Exec (KVDF) most of them start below 2,000 ft. So, in theory, you'd be good to go. But the RNAV (GPS) RWY 18 starts at 3000 ft., so you always will run the risk that there is a cloud sitting along the final or the way ATC is going to vector you to get to that Approach if it is in use.

Biggest + or - is going to be the CFII. If they're willing to be flexible to take a flight on short notice when the Wx is CAVU, no problem. If they are heavily scheduled and are not going to be a happy camper because you're cancelling because of a few clouds right along the Approach course, that could be a problem. And if all the flights are VFR doing Practice Approaches, you won't have to worry about ATC giving you a heading into a cloud. Or at least they won't care when you tell them you're "unable" due to the clouds.
 
Ed Haywood said:
Tampa, FL. Most days Nov-March are CAVU. Most days Jun-Sept start out few/scattered clouds with 3K bases in the morning, and progress to massive thunderstorms by late afternoon.
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I’m also in Tampa and as Ed stated most of the IMC weather in the Central Florida area isn’t conducive to IFR flight as it tends to be cumulus in nature and more often than not convective. Even when it’s overcast there’s a high probability of embedded T-Storms—bad, bad, bad. We try to depart on X/Cs in the morning if possible pretty much year round. I’ve stated this in other threads but I gave up trying to use a combination of actual and safety pilots to stay current and proficient and bought a BATD.
 
tsts4 said:
I’m also in Tampa and as Ed stated most of the IMC weather in the Central Florida area isn’t conducive to IFR flight as it tends to be cumulus in nature and more often than not convective. Even when it’s overcast there’s a high probability of embedded T-Storms—bad, bad, bad. We try to depart on X/Cs in the morning if possible pretty much year round. I’ve stated this in other threads but I gave up trying to use a combination of actual and safety pilots to stay current and proficient and bought a BATD.
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Yeah, I agree Tampa is a bad place for IFR training. I almost pulled the trigger on a redbird at sun n fun. Probably would have if they'd had a show special.
 
Pinecone said:
But the seats are closer together. People teach in tandem aircraft similar to Decathlon all the time. No VFR instruments back there either.

Look at the "hood" for a T-38. It fully encloses the rear cockpit. Student sits in the rear seat for instrument flights.
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Don't gotta persuade me. Now I just need to find a like-minded CFII. My buddy who taught me formation flying was a reserve T-38 instructor. He would have been all over this. Unfortunately he passed away suddenly last fall. RIP Jason.
 
The more I look at that GPS 175, the more I like it. Price was deterring me, but then I realized I could skip the Aera 760. Marginal cost over my planned VFR upgrade would be around $4K, but it would be future proof, unlike an obsolete GPS and an old NavCom.
 
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M20K said:
You still haven't shown me anything that contradicts what I said and I *believe* to be true. (But if you can find it, I'm open to it.)
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I don't really care what you believe. It's what the FAA says is true that matters. And I've given you that - If written English from the FAA doesn't do it for you, nothing that is said here on PoA will ever convince you. :dunno:
M20K said:
I have continually stated you cannot file/accept and IFR Clearance in a VFR only aircraft. Your quote says what I've been saying. "...Any aircraft that meets the equipment requirements..." There's no one from column A and one from B. If the plane is not IFR capable, or can not "meet the equipment requirements" you may not file/accept and IFR Clearance. You can fly under the hood all you want in VFR conditions
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"Meets the equipment requirements" does not mean the same thing as "Is IFR certified."

Going back to an example already used in this thread: The Diamond DA20. It is not IFR certified because it's a composite aircraft with no lightning protection. The DA40 has a metal mesh under the skin for that reason. You can put the EXACT SAME instruments in both and the DA40 will still be IFR certified and the DA20 won't be.

But, if you have all of the instruments from 91.205(d) in a VFR only aircraft like the DA20, the FAA allows you to file and fly IFR. You just can't go in IMC. Hope that makes more sense now.
M20K said:
Perfect example... A couple of years ago we did a X-US flight in October. I filed IFR on all legs and as it turned out on 99.9999% of the days we were flying for the entire trip in the the big loop around the US was not only VMC, but CAVU!! But I did end up Logging 0.1 Actual. Leaving KAWO if I had gone N, E or S, I would have been in VMC. But ATC had me turn West, so I climbed for a few minutes through some clouds along the coast. If you are on an IFR Flight Plan, ATC does not ask you if you can accept a turn to the right or left, you are expected to turn even if it is into IMC. (Granted there may be some reasons you may say "unable") They don't want to hear "sorry that will put me in IMC and this plane isn't IFR Certified. In fact, I'm sure you'd get a call or a visit from the FSDO.
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"Unable, weather. We can turn North, East, or South."

M20K said:
Well... If you're going to quote a Legal Interpretation, make sure you have the latest. Pratt in 2022 rescinded the Theriault interpretation.
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Pratt caught my eye mostly because I know Mike Pratt. :rofl: But yes, I read that, and no, it does not change things because 8900.1 5-439 still exists. Pratt also doesn't say anything about the VFR aircraft being operated in IFR portion of Thierault.

M20K said:
There is a very important legalize in there "...However, we caution that the pilot in command must ensure compliance with the flight rules and not to expect special handling from Air Traffic Control..." So even though the lawyer appeared to have ignored the Regs (91.205, 91.215, 91.411 and I'm sure others), if you did file, you could still be violated if you're not IFR capable.
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And an aviation lawyer fresh out of law school should be able to successfully defend you on that one given the documentation that has been provided here.

No, you can't "expect" special handling. If you can't do what ATC says, you need to be willing to cancel. Simple as that.

farmrjohn said:
A slight tangent question: In the sub paragraph quoted above does the pilot in command (PIC) need to be properly certificated and current to be operated on and IFR flight plan under IFR in VMC or would the instrument rating alone be sufficient to file and accept an IFR clearance?
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Yes. Nothing about any of this changes the necessity of the PIC being certificated and current to operate under IFR.

Salty said:
is it legit to say unable to atc instructions that would put you in imc when you are on an ifr clearance? doesn’t seem to me like it would be.
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Absolutely. Just like if you were going to be put into ice, thunderstorms, terrain, or anything else. I've said "unable" on an IFR clearance far more often than when VFR...

Ed Haywood said:
What percentage of a typical IFR training course can I accomplish effectively in my aircraft, versus how much would I need to obtain another aircraft for?

Let's say it's 50/50, or 75/25. I can do the math from there to see if the rental cost savings pays for the equipment expense.
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I think it largely depends on your instructor, so you really need to talk with them instead of us.

Ed Haywood said:
The more I look at that GPS 175, the more I like it. Price was deterring me, but then I realized I could skip the Aera 760. Marginal cost over my planned VFR upgrade would be around $4K, but it would be future proof, unlike an obsolete GPS and an old NavCom.
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Garmin's entry into the low end of the market was a very welcome surprise, and they've got some good stuff for relatively reasonable prices.
 
flyingcheesehead said:
"Meets the equipment requirements" does not mean the same thing as "Is IFR certified."
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Not relevant to this discussion as equipment is what is relevant to the OP's plane to make it "IFR" or not.

flyingcheesehead said:
"Unable, weather. We can turn North, East, or South."
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Per the Thierault LI, you could be held accountable for refusing a valid ATC instruction. "Unable" would not be due to safety but because you filed IFR in a VFR aircraft.

flyingcheesehead said:
Pratt caught my eye mostly because I know Mike Pratt. :rofl: But yes, I read that, and no, it does not change things because 8900.1 5-439 still exists. Pratt also doesn't say anything about the VFR aircraft being operated in IFR portion of Thierault.
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Yes, as I've stated a couple of times. It is not clear if all or part of the Thierault LI was rescinded.

flyingcheesehead said:
Absolutely. Just like if you were going to be put into ice, thunderstorms, terrain, or anything else. I've said "unable" on an IFR clearance far more often than when VFR...
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Incorrect as specifically stated in the Thierault LI. "...However, we caution that the pilot in command must ensure compliance with the flight rules and not to expect special handling from Air Traffic Control..."
Just trying to stay VMC would be special handling, it has nothing to do with Ice, T-storms, etc. Now if they tried to turn you towards a Cumulonimbus vs a Cumulus clouds, that would be a different story.
 
M20K said:
Not relevant to this discussion as equipment is what is relevant to the OP's plane to make it "IFR" or not.
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And even if the OP puts all of the 91.205(d) required equipment in his plane, it will NOT be IFR certified.

But he can fly it IFR in VMC.

M20K said:
Per the Thierault LI, you could be held accountable for refusing a valid ATC instruction. "Unable" would not be due to safety but because you filed IFR in a VFR aircraft.
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And if ATC can't give you something different, then you would be expected to cancel. That doesn't mean you're going to be violated.

M20K said:
Yes, as I've stated a couple of times. It is not clear if all or part of the Thierault LI was rescinded.
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Doesn't matter. Ignore Thierault, it's effectively irrelevant anyway.

It's in the FAA's Dynamic Regulatory System: FAAO 8900.1 5-439.

M20K said:
Incorrect as specifically stated in the Thierault LI. "...However, we caution that the pilot in command must ensure compliance with the flight rules and not to expect special handling from Air Traffic Control..."
Just trying to stay VMC would be special handling, it has nothing to do with Ice, T-storms, etc. Now if they tried to turn you towards a Cumulonimbus vs a Cumulus clouds, that would be a different story.
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You're grasping at straws. Nowhere is "special handling" defined, and the fact that the FAA allows it means that simply staying VMC would NOT be special handling.

What it means is "Don't be a pain in the ass and we'll leave you alone."
 
M20K said:
I have continually stated you cannot file/accept and IFR Clearance in a VFR only aircraft. Your quote says what I've been saying. "...Any aircraft that meets the equipment requirements..." There's no one from column A and one from B. If the plane is not IFR capable, or can not "meet the equipment requirements" you may not file/accept and IFR Clearance. You can fly under the hood all you want in VFR conditions
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You're oversimplifying it—there are operating requirements in Part 91, and type certification requirements, e.g. Part 23. FAA policy allows IFR operation of aircraft not type certified, but that comply with Part 91, if they remain in VMC.

We often refer to the 24-month transponder and static checks as "IFR certification" but those are Part 91 requirements.
 
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dmspilot said:
You're oversimplifying it—there are operating requirements in Part 91, and type certification requirements, e.g. Part 23. FAA policy allows IFR operation of aircraft not type certified, but that comply with Part 91, if they remain in VMC.

We often refer o the 24-month transponder and static checks as "IFR certification" but those are Part 91 requirements.
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But he “continually stated” it, so it must be true.
 
I hate to hijack OP's thread, but how would this discussion apply to E/AB aircraft? There is no TC; its up to the builder what limitations are placed on the airframe. Does the analysis change if the aircraft is an RV-10 installed with the full 91.205 complement?
 
DJTorrente said:
I hate to hijack OP's thread, but how would this discussion apply to E/AB aircraft? There is no TC; its up to the builder what limitations are placed on the airframe. Does the analysis change if the aircraft is an RV-10 installed with the full 91.205 complement?
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The aircraft OPLIMS will stipulate that an E-AB aircraft can fly at night and/or IFR if equipped IAW 91.205. Of course you also have to adhere to other applicable part 91 requirements like 411 & 413.
 
tsts4 said:
The aircraft OPLIMS will stipulate that an E-AB aircraft can fly at night and/or IFR if equipped IAW 91.205. Of course you also have to adhere to other applicable part 91 requirements like 411 & 413.
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Are there additional flight testing requirements to get the IFR OPLIM?
 
Ed Haywood said:
Are there additional flight testing requirements to get the IFR OPLIM?
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Not in most cases. In fact, you can get your AWC with VFR only equipment and add the night/IFR stuff later as long as the OPLIMS has the right wording to allow it. No additional testing is legally needed unless adding the required equipment somehow involved a major alteration in which case you’d have to put the plane back into a 5-hour Phase 1 test period. That said I’d highly recommend flight testing any new equipment in VFR conditions before using it for real.
 
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flyingcheesehead said:
And if ATC can't give you something different, then you would be expected to cancel. That doesn't mean you're going to be violated.
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Someone else mentioned that it can take some time to be cancelled, so you're under their control until that happens. Personally, I'm not sure if I just say cancel is all it takes. Separate from the IFR/VFR issue, I could see them coming after you for cancelling because you didn't like an ATC instruction. There probably was a reason for the instruction and so it is another gray area. Also vaguely remember someone in a Flight Following discussion quoting something that you can't just cancel FF after an instruction from ATC. If you're in the system you're in the system until ATC says you're not was the gest of it. I don't remember/have a Reg that substantiates this, but I agree with the premise.
 
M20K said:
Someone else mentioned that it can take some time to be cancelled, so you're under their control until that happens.
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In the sort of situation where ATC can't work with you for VMC, it's going to be because they've got too much IFR traffic that would be in your way if you maneuvered towards more VMC. If you cancel, they're no longer responsible for maintaining IFR separation with you, so you're making their life easier and they're going to be all too happy for your cancellation.

In the situation where they want to keep you (which is VERY unusual), it's likely because they know you're going to be in a situation where not communicating with you may cause them bigger headaches. In most instances, having you cancel IFR but remain on flight following is the best of both worlds for them - They can let you get closer to other IFR aircraft, but they don't lose the ability to communicate with you for traffic alerts and to get updates on your plans.

M20K said:
Personally, I'm not sure if I just say cancel is all it takes. Separate from the IFR/VFR issue, I could see them coming after you for cancelling because you didn't like an ATC instruction. There probably was a reason for the instruction and so it is another gray area. Also vaguely remember someone in a Flight Following discussion quoting something that you can't just cancel FF after an instruction from ATC. If you're in the system you're in the system until ATC says you're not was the gest of it. I don't remember/have a Reg that substantiates this, but I agree with the premise.
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So yes, I would agree that if, for example, Chicago Approach told you not to overfly the Bravo and you cancelled and did it anyway, you're gonna be in trouble. 91.13 careless/reckless if nothing else, though I'm pretty sure I've seen case law about the "cancel, then disobey" technique and that one does go against the pilot. However, in this case, you wouldn't be canceling and then making their life difficult, you'd be canceling to make their life easier. This isn't "canceling because you didn't like an instruction" this is canceling because you can't legally remain IFR.
 
flyingcheesehead said:
So yes, I would agree that if, for example, Chicago Approach told you not to overfly the Bravo and you cancelled and did it anyway, you're gonna be in trouble. 91.13 careless/reckless if nothing else, though I'm pretty sure I've seen case law about the "cancel, then disobey" technique and that one does go against the pilot. However, in this case, you wouldn't be canceling and then making their life difficult, you'd be canceling to make their life easier. This isn't "canceling because you didn't like an instruction" this is canceling because you can't legally remain IFR.
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So you're agreeing with me that it would be a bad thing to cancel IFR because you couldn't turn right and maintain VMC... :cool::p
 
Wow…somehow over the top of Chicago Class B suddenly became the only place that isn’t IMC. I blame Daley.
 
M20K said:
So you're agreeing with me that it would be a bad thing to cancel IFR because you couldn't turn right and maintain VMC... :cool::p
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Nope.

"Bugsmasher 123, turn right heading 240."
"Unable, weather, bugsmasher 123. We can take any heading between 030 and 210."

At this point, ATC is going to come up with a plan B. If they needed to vector you for traffic, maybe they'll give you a new altitude, or a different heading, or give the other guy a heading. If they were vectoring you for an approach, they'll give you a different vector and/or ask a question about the weather limitation so that they can get you onto the approach in a way that doesn't put you into weather. If they were vectoring you for spacing, they have a ton of options based on what you told them.

We do this ALL THE TIME in the real world with IFR certified aircraft when we get vectored towards thunderstorms, given an altitude that will keep us in heavy icing conditions, etc... So I'm not sure why you think this can't be done.

It's quite different from being told to remain clear of busy airspace, canceling and then flying right into the busy airspace. That's just a blatant disregard for safety and the authority of ATC. If they told you to remain clear and you said you needed to get in for a photo mission or some other reason, they'd work with you. Hell, I've had Chicago put me through their airspace because going around would have put me uncomfortably low on fuel at my destination.
 
Ed Haywood said:
Seems pretty clear to me that I can train IFR in my Decathlon, to include filing IFR plans, just as long as I stay in VMC.

So next question: apart from the comfort level of gaining actual experience in the soup, how much does staying VMC constrain the training? If I'm on foggles and not peeking out the corners, do I care if it is CAVU?
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Go for it. Train at night with a hood and fly basic attitude instrument maneuver drills over the green swamp, and when you shoot approaches, challenge yourself like your life depends on it to only focus on the instruments. When the wind favors RWY 23 at Z-hills, at night it is usually nothing but black out the corners if you're peeking.
 
Ed Haywood said:
You guys are dancing around the remaining issue I need help with to decide if this is a cost effective path. Let's narrow it down by restating the question.

What percentage of a typical IFR training course can I accomplish effectively in my aircraft, versus how much would I need to obtain another aircraft for?

Let's say it's 50/50, or 75/25. I can do the math from there to see if the rental cost savings pays for the equipment expense.
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Ask the DPEs you plan to use if they are OK with using your plane for the checkride. Describe the equipment. If they are cool with your plane for the check ride, just do all the training in your plane.
 
Ed Haywood said:
Don't gotta persuade me. Now I just need to find a like-minded CFII. My buddy who taught me formation flying was a reserve T-38 instructor. He would have been all over this. Unfortunately he passed away suddenly last fall. RIP Jason.
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I live in Gib-town, CFII with tail wheel. More than happy to help you out.
 
I concluded the tech is not quite there yet. For my scheme to work, I need the uAvionix AV-HSI adapter to drive my AV-30 as a CDI. The experimental version is on the streets, but the certified gadget is "coming this summer." The FAA can tends to get kicked down the road, so I'll relook it in a year.
farangutan said:
When the wind favors RWY 23 at Z-hills, at night it is usually nothing but black out the corners if you're peeking.
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Headed there today to pick up my chute.
 
tsts4 said:
Of topic, but do you give tailwheel instruction?
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Unfortunately, although I have my tail wheel endorsement, I don't have enough experience to recommend myself to others for tailwheel instruction.
 
farangutan said:
I share a plane at ZPH with a CFI friend that teaches out of FD77 but I've only been there a couple times. Really nice and not super far away.
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If you are ever in the mood to look at cool planes, give me a heads up and we'll meet there. I'm there most afternoons late in the day.
 
farangutan said:
Sounds great, PM sent.
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I'm in Apollo Beach and have been frequenting the ShowTown bar there in Gibtown of late (pretty good wings on Wed's). Anyway, if you guys need a tiebreaker to settle differing points of view or just a quorum to look at/talk planes, give me a shout.
 
tsts4 said:
I'm in Apollo Beach and have been frequenting the ShowTown bar there in Gibtown of late (pretty good wings on Wed's). Anyway, if you guys need a tiebreaker to settle differing points of view or just a quorum to look at/talk planes, give me a shout.
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Right up the road from me, I've been meaning to take the bike and check it out.
 
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