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.