Maybe It's Time for an Instrument Rating comments

[Mike M]

Those of us who've been aviating a long time know many truths which aren't always actually completely true. A couple popped out of Mac's article on IFR flying.


His listing of required IFR equipment for example. American certification rules aren't static but they do have some grandparenting and exempting provisions. CAR 3 vs FAR 23 vs E/AB aircraft, for example.


Recently a DPE and his “I-can-reach-him-on-Saturday” FAA oversight contact went into hyperdrive about the airworthiness (perceived lack thereof)of an applicant's aircraft for an IFR practical exam. There was no Form 337 for replacement of the vacuum gyros with electric gyros. The IA who installed them was contacted and patiently explained why none was needed and that the W&B had been updated. Oh, the shock! The venturis (venturus? my Latin class was decades ago) had been removed? But the T&B is electric! No backup generating system! Terror in the skies!


Contact with an FAA maintenance rep on Monday assuaged and clarified that.


The aircraft in question is certificated under CAR 3, manufactured only two years after gyros were required for IFR. Yep, until 1956, one could launch IMC with a turn needle and a wet compass. The gyro requirement is in Pt 91.205, not aircraft certification regs. Backup systems? Only FAR 23 aircraft require backup systems, as best I can find. FAR23 doesn’t apply to aircraft certificated under other FAR rules unless specifically noted. CAR 3 aircraft normally have a backup, but not required by regulation. At least, that's what the copy of CAR 3 I found and the weekday FAA maintenance rep confirmed.


Nor are backup systems specified for E/AB aircraft. Functionality to work in the IFR system doing what the items Mac listed do (basically,the Pt 91.205 list). Not full FAR 23.


NONE OF WHICH MEANS IT'S SMART TO USE AN INTERCONTINENTAL FLYING CARPET WITHOUT A BACKUP SYSTEM. But a simple IFR trainer for personal use in VMC or occasional puffy-little-white-cloud penetration while building experience as cheaply as possible is safe and legal under the rules which apply to your aircraft certification standard. “Simulated electrical fire!” Master switch went off as per the emergency checklist. “OH SxxT!” I think the owner realizes why backup systems are now specified, and the exact limits of his decision.


Another half-truth in Mac's article is how to fly IFR practice in the system. FAA-H-8083-15B says an aviator requires an instrument rating and currency to operate on an IFR flight plan only in conditions less than VFR or in Class A. Not quite true. Mac wrote that one can build IFR experience if the safety pilot is IFR rated,which is true, but very subject to misinterpretation in light of what that FAA handbook says.


Pt61.3e says to be PIC using IFR one must hold an instrument rating. Pt91.173 says to operate IFR in controlled airspace one must file an IFR flight plan and get an ATC clearance.Note both of those regs say IFR, not IMC, so they apply even when VMC. Close,but not exactly what the handbook says, is it? To use an IFR flight plan the PIC must have an instrument rating and get ATC clearance.Without an instrument rating, one can't fly on an ATC clearance. So how do you get IFR experience toward a rating, without a rating, using a safety pilot? Two ways I think are safe and legal:


1. Stay VMC. File VFR, take flight following, request approaches maintaining VMC so you're not on an ATC clearance under IFR. STAY VMC.


2. If the safety pilot is IFR rated, have the safety pilot file IFR as PIC.


Your mileage may vary.

[Frank Giger]

I go a bit glassy-eyed when reading stuff about flying IFR, so bear with me if I'm asking a dumb question or two.

Most of the IFR guys I know fly IFR (file a plan, etc) regardless of weather. I never really asked, but just assumed it was to remain proficient (as opposed to the legal meaning of "proficiency") so that when the weather turns crap they won't be attempting to apply mental WD-40 on their skills.

This kind of confuses me:

If the safety pilot is IFR rated, have the safety pilot file IFR as PIC.

If there are two people in an aircraft and both are pilots, control (command) can and will switch between the two. If I'm in the air with a more experienced pilot and things get squirrelly to the point that it's past my personal minimums, I'll defer the controls to him, as I have zero pride when it comes to piloting an aircraft.

So let's say I'm instrument rated, but my usual aircraft isn't - and therefore I'm not up to snuff. In the right seat is Mac in my new gizmo plane, and so I file IFR to keep him from making wry grins. Visibility gets a bit iffy at our destination, so what do I do? Bah, easy. "Mac, you have the controls," I say as we get closer. "I have the controls," he responds and expertly comes out of the soup to land right on the numbers.

Who's the PIC? Forget the legalities, in reality we both are - I had command for most of the flight, but Mac was for part of it, too. What goes in the logbooks only really matters if there's a wreck or we're bucking for a commercial rating, to be brutally honest about it.

[FastEddie]

In this case, Mac is PIC to be legal, because he is the only one in the cockpit who can legally file and fly IFR. Perhaps someone who flies for the airlines can explain how "pilot flying" and PIC differ from a logbook perspective.

In reality, you are both crazy for getting into a "new gizmo plane" that Mac is not familiar with and expecting him to fly in IMC from the right seat.

[Frank Giger]

Maybe it's a Baron? My Southern is showing - when one buys a 1946 Champ, it's "new" to the owner if he's never had it before. Yankees would probably use the term "latest" but we use the word "new."

My point is that there's qualification and there's currency. If one is already instrument rated but not current, why wouldn't one file and fly it with a current pilot?* Otherwise, how would one ever get current? I doubt anyone's checking to see if the pilot filing IFR is current; heck, how would they know?

* This is key - I'm not even remotely suggesting that one should fly IFR if they're not current by themselves or with folks who aren't rated or current themselves.

[Bob Dingley]

Mike, Mac's discussion was timely and I re- read it a couple of times. He didn't say all that much about backups. Well, maybe a little. My take on your points are like this: Consider that the vacuum gauges back up the DC elec T&B and vice versa. The battery backs up the generator. For a while anyway. When you loose a generator, Emergency checklist always tell you to get to VMC conditions and reduce electric loads.

[Mike M]

....Consider that the vacuum gauges back up the DC elec T&B and vice versa. The battery backs up the generator. For a while anyway....

Yep, that's right. In the aircraft I mentioned, the owner had the vacuum system removed (it was optional in '58) completely. Which left the electric T&B whirring just fine. Then brand-new electric directional and attitude gyros installed. Which work great. His logic was the same as yours, the battery will back up the generator. Which isn't IAW the regs for an aircraft certificated under Pt 23. Pt 23.1331 requires more for IFR cert, a second power source for the instruments or a second display with an independent power source. But as a CAR 3 aircraft, that's not required in this aircraft. Nor in an E/AB. However. As we proved, the logic that the battery backs up the generator may break down when the problem isn't a generator failure, leaving one out of options. One might consider an aircraft so equipped to be legal for IFR but unsafe for IMC.

P.S. I'm going by the books I've found. Open to correction. Just list the ref.

[Mike M]

In this case, Mac is PIC to be legal, because he is the only one in the cockpit who can legally file and fly IFR. Perhaps someone who flies for the airlines can explain how "pilot flying" and PIC differ from a logbook perspective.

There can be only one PIC for a flight (FAR Pt 1.1) but either or both aviators may log PIC time during a flight (FAR 61.51). Same for pt 91, 135, 121, 141 operations as far as I know.

[Bob Dingley]

Yep, that's right. In the aircraft I mentioned, the owner had the vacuum system removed (it was optional in '58) completely. Which left the electric T&B whirring just fine. Then brand-new electric directional and attitude gyros installed. Which work great. His logic was the same as yours, the battery will back up the generator. Which isn't IAW the regs for an aircraft certificated under Pt 23. Pt 23.1331 requires more for IFR cert, a second power source for the instruments or a second display with an independent power source. But as a CAR 3 aircraft, that's not required in this aircraft. Nor in an E/AB. However. As we proved, the logic that the battery backs up the generator may break down when the problem isn't a generator failure, leaving one out of options. One might consider an aircraft so equipped to be legal for IFR but unsafe for IMC.

P.S. I'm going by the books I've found. Open to correction. Just list the ref.

I hope I don't get too far into the weeds. I used to fly a twin turb certified under trans cat rules (part 29). This from the Flt manual: "The 24 V 40 amp battery provides power for engine starting and also acts as a standby power source in flight for systems on the bat and DC essential busses."

[Bob Dingley]

Just dug out my Emerg CL. on this bird. Single DC gen failure: has four steps: #3, says to transition to VMC as soon as PRACTICABLE and continue flight."

For a DUAL generator failure, there are 8 steps. #4 says "transition to VMC" #7 says " land as soon as PRACTICABLE." Also reduce electrical load.

In this aircraft under these conditions, the only volts left are in the standby att indicator and maybe from the AC generator. The mlg is hydraulic, but the landing gear control is DC elect. You will have to blow the wheels down.

[Mark van Wyk]

What about this on page 19:
"...Most of your training flights will be conducted under VFR rules [sic], even though you are wearing a view-limiting hood or other device and flying published IFR procedures. Under those conditions, a GPS navigator does not need to be IFR certified in the airplane..."
GPS navigator does not need to be IFR certified??? Really?
Does this mean I could comply with 14 CFR 61.57 in my certified C-150, i.e.: log GPS approaches wearing a hood, with a safety pilot in the right seat, and only my iPad/ForeFlight on my knee -- and NO IFR GPS with current database installed in the plane? That's not what I've been told. Maybe I've been operating under false pretenses all these years, but I'm just saying.
I only log approaches for currency for which my airplane is legal, which in my case are usually VOR, LOC/DME, and ILS approaches. I don't log GPS approaches -- simulated or actual -- because I don't have IFR GPS in the plane. Practice? Yes, maybe. But, log? No. At least that's what I've been led to believe.

As for the portion of the article that talks about minimal IFR equipment requirements, that seems pretty bare bones to me. Where I live (south SFO Bay Area) a VOR/GS navcom without DME is virtually worthless because most approaches and procedures have a big "DME required" stamped on the plate, so the plane at minimum also pretty much needs DME or IFR GPS in lieu of DME. And, most of the time I have found that controllers increasingly assume the plane has IFR GPS. I have to specify that I have only VFR GPS, and wish to make the VOR, or VOR/DME, or LOC, or ILS approach.

And, let's not forget the looming ADS-B Out mandate, which is going to further complicate things and require even more expensive equipment.