Recording of flight time - Instrument Flight Time

Robert Gottwald • 10 August 2023

in community General Aviation

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Hi,

I am trying to gain a better understanding of the differences in how the rules on recording of flight time are currently being interpreted and applied under the different competent authorities in the various member states.
In particular my question is with regards to "instrument flight time" as part of training course requirements (e.g. as per Part-FCL Appendices 3 and 6).

Per FCL.010 Definitions "Instrument Flight Time" is defined as the time during which a pilot is controlling an aircraft in flight solely by reference to instruments (where the pilots fly the aircraft without any external visual references, in simulated or actual instrument meteorological conditions (IMC)).

This means that those portions of flight time where the airplane is controlled (at least in parts) using outside visual reference(s), cannot be considered instrument flight time (such as taxi, takeoff, visual segment of the final approach and landing).

However, some competent authorities seem to interpret "Instrument flight time" synonymous with "Flight time under Instrument Flight Rules" (IFR), despite the clear delineation in FCL.010, and allow ATOs under their oversight the recording of the entire flight time as instrument flight time for all flights. Some authorities apparently allow such recording of the entire flight time as instrument flight time for flights conducted as Student Pilot Under Supervision (SPIC), but not for flights conducted as dual instruction (where the instructor is acting as PIC). The logic behind this to me is unclear.

For an ATO in a MS where the CA allows the recording of the entire flight time as instrument flight time, compared to an ATO in a MS where the CA requires the taxi, takeoff, final approach and landing not to be logged as instrument flight time, this creates a disadvantages of approx. 20% additional flight time required to meet the minimum course requirements for the one ATO to the other ATO (considering 1.5 hour training sessions and 18 minutes for T,T,FA,L). For an ATP(A) Integrated Course, for example, considering the associated costs for flight time in the actual aircraft, this easily results in a cost difference of several thousand euros per student between the two ATOs.

What is your experience with and your opinion on this?

Comments (7)

Fabrice SEGURA • 8 months ago

There is always an incompetent authorities that will try to interpret the texts in the worst possible ways to limit privileges as much as they can and/or to increase the costs of everything, since they don't pay anything for it, and they know that "flights safety" minus "flights" equals "safety". Tell them to f*** **f , that they no longer make the rules, EASA does, and that their job is to apply FCL010. And make sure you do, as our freedoms and rights worns out when we don't use them. As far as I know, even on the ground when you start your flight IFR, you start dealing with the IFR clearance. Why shouldn't this count as IFR flight time ?

Fabrice SEGURA • 8 months ago

The EASA on the other hand should revisit the proceedings of the said ATO delivering integrated ATP(A) courses, when all the students "make it" in the 150 hours in the contract. Some are ready at 150hours. Most are not. 150 hours is a minimum, not a contractual comittment to be fulfilled by the ATO. If more hours are required, that should be on this base (training standards not met by the student), nor for an obscure administrative reason. Personally, as a FI, I thing that the whole "integrated course" thing should be removed from the regulation, and that modular training should be used instead with the time it takes to build real experience (alone on board, not "SPIC"), before you can go to the CPL/IR

Robert Gottwald • 8 months ago

"Instrument Flight Time" and "Flight Time under IFR" are two different things and must be logged separately.

Flight Time under IFR considers the flight rules and is always under IFR but can be in VMC or IMC. It is always the entire flight time (off to on block) unless portions of flight are not operated under VFR.

Instrument flight time can occur under IFR and/or VFR, but must be conducted under actual or simulated IMC (the latter can be under VFR), as in not using visual references to control the airplane in flight.
Usually only a portion of flight time in normal IFR flight operations is actually conducted under IMC and thus can be counted as instrument flight time. Vice versa in initial pilot training a lot of instrument flight time is conducted under VFR (in simulated IMC).

For example, per FCL.915.IRI (b) (2) you must have completed at least 500 hours of flight time under IFR, of which at least 250 hours must be instrument flight time in helicopters before you can become an IRI(H).
Differentiating between the two makes perfect sense to me. It is the inconsistent interpretation between MSs/CAs that is the issue I mainly see.

Luca Vanzan • 8 months ago

In US, an integrated course aloud a credit of reduced minimum (I say MINIMUM) flight ours to be eligible for your CPL/IR just because the flight experience has a specific pattern, not just “staying in the air” time. Specific missions give the assurance that all the required EXPERIENCE has been covered during your preparation phase. The EASA integrated ATPL course pretend that inexperienced people do handle with complex commercial tasks (at least in theory), like TO PERF, COLD WEATHER OPS, FLIGHT ATTENDANTS REQUIREMENTS, etc. even before their first solo flight. I think its a distortion of a wise training pattern. See FAA 141 rules…

Juergen Jurisch • 8 months ago

As flight instructor and IFR pilot, we define the entire Instrument Flight time according FCL.010 after start up clearance and the Flight plan acceptance. If in VMC we use some time a special glas for the student. Flight time considers the the flight rules and the entire flight time off and on blocks.
Jurgen

Robert Gottwald • 8 months ago

Thank you for sharing this. This is exactly what I mean, this interpretation of "instrument flight time" is still very prevalent.
Some competent authorities consider this acceptable, others do not, which creates a disparity between pilots and ATOs that are supposed to be held up to the same requirements.
The FCL.010 definition of "instrument flight time" is closely adapted from ICAO Annex 1: "Time during which a pilot is piloting an aircraft solely by reference to instruments and without external reference points".
With adding the definitions for "Flown solely by reference to instruments" and "Flight time under Instrument Flight Rules" to FCL.010 EASA meant to further clarify this, but clearly that has not been achieved yet.
CASA created some very good guidance (see attached screenshot), that EASA in my opinion should consider to adopt at least as GM for FCL.010:

Julian Scarfe • 8 months ago

ICAO Annex 1 only deals with Instrument Flight Time. Under JAR-FCL1, some pre-requisites based on Flight Time under IFR was introduced. In some states this caused issues, because there had never been a requirement to record Flight Time under IFR. The UK addressed this by adopting a conversion rate of 4 hours Flight Time under IFR for every 1 hour of Instrument Flight Time, which was acceptable in JAR-FCL days, but was not deemed to be an acceptable means of compliance under Part-FCL. Since Part-FCL has been applicable, logging of flight time under IFR is required.

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