"Gary Drescher" wrote in message
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Well, it can be loggable as instrument time, but not as IMC--a clear,
moonless night is definitely not IMC.

If you spend any time over a large body of water or undeveloped landscape
on a moonless night, you may arrive at a different opinion about that.
I've done both, and they're definitely IMC.

It's just a matter of terminology. Yes, you're describing conditions that
require flying by instruments; and yes, the time spent in such conditions
is loggable as instrument time. But IMC has a specific meaning under the
FARs.

I've never heard of anyone logging time as "IMC". Though, I suppose that
could be synonymous with "actual instrument conditions". It seems we're all
in agreement that the flight time is loggable as instrument flight time.
But just for fun, let's look a little closer at the regulatory issues around
this situation...

61.51 doesn't refer to "instrument meteorological conditions".

(g) Logging instrument flight 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.

Of course, the FARs fail to define what "instrument flight conditions"
means. But one can make a pretty good inference simply by reading what's
loggable. That is "flight time when the person operates the aircraft solely
by reference to instruments".

The Part 61 FAQ only helps a little in understanding this question. One can
find the relevant passage by searching for the phrase "The question came up
about logging actual instrument". Someone has posted a copy of the relevant
passage on this page: http://cavucompanies.com/CAVU/discuss.htm If you
click on the "What constitutes 'actual' versus 'simulated' instrument time"
link, that will take you straight to the FAQ's answer.

It does little to give us confidence in the answer, when the author uses
phrases like "I agree with" and "it was always my understanding". However,
the core piece of useful information is that the author of the FAQ answer
agrees that flight in VMC when use of the instruments is required for
control of the aircraft is loggable as instrument flight time.

He further describes this situation as "simulated instrument conditions",
justifying that by pointing out that much of what makes VFR conditions VFR
has nothing to do with control of the aircraft, and everything to do with
avoiding obstacles (terrain, buildings, other aircraft, etc.).

In fact, given that there's no prohibition against flying under VFR even
when there are no outside references, and given that all of the various
visibility and cloud clearance requirements are designed for the sole
purpose of avoiding obstacles, one could make a very good argument that
avoiding obstacles is ALL that VFR conditions are about.

The reason I don't believe that it's truly an "either/or" thing is that we
have uncontrolled airspace, in which flight in IMC still requires an
instrument rating. Obviously, no one is concerned about separation, since
an unlimited number of aircraft are permitted in any given area of
uncontrolled airspace. So in that case, the requirement for an instrument
rating must be for the purpose of controlling an aircraft. Likewise, the
requirement for helicopters to be equipped with an autopilot for flight in
IMC (or is that for the helicopter to be certified for instrument flight...I
don't recall the specifics). Obviously (to me) the rules are written to
take into account terrain avoidance, aircraft avoidance, and control of the
aircraft.

The primary abandonment of logic comes with respect to the fact that even
though IFR is primarily (or entirely) about avoiding obstacles, the logging
of flight time that is used for obtaining an instrument rating, maintaining
instrument currency, etc. is based not on avoiding obstacles but rather on
control of the aircraft. Nonetheless, this does appear to be the reading
that the author of the Part 61 FAQ takes, and there's nothing elsewhere in
the FARs that would serve to disagree with this.

I realize that since none of this discussion really disagrees with the heart
of anything that's been written so far, and so everyone may find this really
boring. Oh well...you could've just skipped this post.

Pete