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6 Answers

Would there be a distinction between “IMC” time and “Actual” Instrument time?

Asked by: 4847 views Commercial Pilot, FAA Regulations, Instrument Rating

I want to apply for a job that requires "10 hours IMC as PIC."  I have around 15 hours of time in which I flew during IMC conditions.  However, some of those hours were on IMC days when I simply climbed above an overcast layer, was on an IFR flight plan, but had a horizon and was flying in a "VFR on top" fashion.  My understanding according to 61.51 "(g) Logging instrument time. (1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions" is that the time I flew above the clouds would not be considered actual, only the time in the clouds when I was solely using the instruments is actual.  So since its a job app and not the FAA, I am confused about how to interpret this requirement seeing as IMC is a weather distinction, not a category found in logbooks.  Can I use the 15 hours of time conducting flight when the prevailing weather was IMC, or only the time considered "actual"?  Thanks!

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6 Answers



  1. L.Jones on Aug 06, 2012

    I suspect they’re looking for PIC time IN IMC requiring control solely be reference to instruments. When you’re on-top, that time should be logged as day-VFR, not instrument time.
    Their “IMC” = “Actual Instrument”.

    Loren

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  2. CFI Academy on Aug 07, 2012

    I agree with Loren. IMC=Actual. Even for your logbook, if you were not in IMC, you’ll log it as VFR (day or night) and not instrument. For simulated instrument (it’s always either actual or simulated in flight) you’d be needing a qualified safety pilot. If no qualified safety pilot on board, it can not simulated instrument either.

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  3. Bob Watson on Aug 09, 2012

    RE: on top = VMC vs. Flight solely by reference to instruments…

    I realize that in the clear blue sky on top of a cloud deck sure looks like VMC, but:

    How do you keep the plane level (when you can’t know for sure if the cloud tops are level)?
    Instruments.

    How do you know where you are when you can’t see any landmarks (which are all beneath the cloud deck)? Instruments.

    To be fair, you can see and avoid other traffic and you can have a general idea of up from down, neither of which you can do in IMC (i.e. clouds). Although, flying between layers would make both of those difficult to the point that I might consider them IMC, even if I’m not in a cloud.

    That said, if this is for a job interview/application, all that really matters is how THEY define IMC/Actual/Simulated time.

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  4. Josh on Aug 09, 2012

    Thanks for all your responses!
    I guess the thing I dont understand is that in the Midwest where I have done all my flying for 3 years the IMC days either have accessible altitudes above the cloud deck or they are unsafe for an aircraft that lacks deicing equipment and is carbureted. Considering this job is an entry level job flying a 172 it just doesnt seem realistic according to my experiences with IMC conditions to expect actual time in the type of aircraft people train in. That is why I thought maybe the app was asking for IMC condition days rather then actual time. I am going to clarify that before applying.
    The only actual time I have is from climbing and descending through cloud layers. I guess I could have requested altitudes flying through the soup, but is that ever the responsible choice when you have other options?

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  5. G. Met on Jul 29, 2015

    In the interpretation, the FAA defines IMC as Instrument Meteorological Conditions,situations where “outside conditions make it necessary for the pilot to use the aircraft instruments in order to maintain adequate control over the aircraft.” According to that definition, your scenario does not qualify to be logged as instrument time.

    When you’re “above the clouds” with daylight, you have tons of outside cues. While it may not be a ‘true’ horizon (i.e. land meets ground), you can easily relate your sight picture to the horizon created where the cloud tops meet the sky. A pitch black night over the desert may qualify as IMC however.

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  6. G. Met on Jul 29, 2015

    Opps, first sentence was cut off. The FAA addressed this in Legal Interpretation #84-29

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