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Instrument training in aircraft not certified for IFR flight.

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FAA Regulations, Flight Instructor, Instrument Rating

In an FAA clarification document 89001 Vol. 5-439 it states, "Instrument flight training may be conducted during VMC in any aircraft that meets the equipment requirements of part 91, §§ 91.109, 91.205, and, for an airplane operated in controlled airspace under the IFR system, §§ 91.411 and 91.413."  Does this also mean that if the aircraft does not meet any of these qualifications that instrument flight training cannot be legal in that aircraft?  For example, the clock stops working, or the pitot static not checked in over 24 months, etc.

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3 Answers

  1. Bill Trussell on Apr 25, 2012

    Instrument training can be conducted in nearly any aircraft, depending on the maneuvers planned to be conducted during the training activity.  The rules cited in your question cover a variety of requirements, some which may apply to the flight regardless of whether instrument instruction is being given our not.  Category II operations are covered by these rules but seems to not apply in your question as one example.
    If the clock stops working it disqualifies the aircraft from being used in IMC, not VMC.  Same for the Pitot static system and altitude reporting rules.  These might still be required depending on where the training is being conducted (mode C veil rule).
    Note that your entire question brings up some concerns about the value of the training to be conducted in such an aircraft but again it would depend on what is being presented or practiced.  At the end of the day do not plan on taking this aircraft for a Instrument Practical Test.

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  2. Kris Kortokrax on Apr 25, 2012

    This section of the order deals with conducting training under IFR in an aircraft not certificated for flight under IFR.  Instrument trainiing can be conducted under VFR with the exception of the cross country flight required by 61.65(d)(2)(ii), (e)(2)(ii) and (f)(2)(ii).
    So, if the clock is not working, you could still do instrument training under VFR (i.e. practice approches or maneuvers).  To conduct the above mentioned cross country, all the equipment required by 91.205(d) would need to be installed and operative (inaddition to the VFR equipment).
    91.411 applies to operations under IFR.  91.413 deals with the transponder test which must be done for flight under VFR also.

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  3. Kris Kortokrax on Apr 25, 2012

    There were no answers when I composed my answer.  Apparently we were typing at about the same time.  
    I would take issue with your last statement.  Paragraph 5-439 is titled “Use of Aircraft not approved for IFR operations under it type certificate for Instrument Training and/or Airman Certification Testing”.
    One may certainly plan on taking such an aircraft for an Instrument Practical test.  I performed my Helicopter Instrument, CFII and ATP training and practical tests in a Robinson R-22 helicopter which is not certified for flight in IMC, but is properly equipped for both training and flight under IFR.  Another example would be conducting instrument training and testing in a Light Sport airplane such as the Cessna Skycatcher.  This is allowed by Order 8900.1.

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