"Judah" wrote in message
...
In this case, it seems to me that there are already two clearly separate
terms used, and all they need to add to the FARs is a definition of
"Instrument Conditions".

Defining two separate terms would be a good start. But for the choice of
terminology to be competent, the words need to be chosen to reflect their
meaning. It is nonsensical for the FAA to use the phrase "instrument
conditions", in reference to meteorological conditions, to mean something
different from the phrase "instrument meteorological conditions". There's
nothing in that wording to suggest that there's even a difference, let alone
suggesting what the difference *is*. In contrast, defining the terms
"Instrument Separation Conditions" and "Instrument Aviation Conditions"
would make the intended distinction immediately obvious.

--Gary

"Gary Drescher" wrote in
news:h%pVb.205324$nt4.976461@attbi_s51:

"Judah" wrote in message
...
The bottom line is that I am still looking for any specific, official
document that supports the case for being able to log instrument
flight time (either in Actual or Simulated instrument conditions)
while solo in VFR conditions under any circumstances. While you have
provided me with some great contact information, you still have not
identified the actual source of your quoted statements, and I just
don't get that.

It's a continuing travesty that the FAA manufactures "interpretations"
of the FARs that supersede the FARs and cannot rationally be derived
from the FARs, yet are not readily accessible to pilots.

On the other hand, although the FAA's FAR FAQs are not officially
binding, I imagine it would be difficult for the FAA to penalize a
pilot for conduct consistent with the FAQs' interpretation (doing so
would arguably constitute entrapment: inducing someone to commit a
violation and then prosecuting them for it). Does anyone know if the
imposition of such a penalty has ever been documented?

The real solution here would be not to publicize the official
interpretation, but rather to rewrite the FARs to make them more
sensible. The problem is that here (as elsewhere), the FAA confusingly
uses a key term to designate two different things: the phrase
"instrument conditions", although it refers to meteorological
conditions, means something different from the phrase "instrument
meteorological conditions"!

The two conflated concepts should be called Instrument Separation
Conditions and Instrument Aviation Conditions. Instrument Separation
Conditions (which the FAA calls "IFR conditions" or "IMC") are
meteorological conditions that don't meet the VFR requirements for
visual separation. Instrument Aviation Conditions (which the FARs
refer to as "instrument conditions" or "instrument flight conditions",
but without ever defining those terms) are meteorological conditions
that require flight by reference to instruments. You can be in ISC
without being in IAC (for instance, flying in unlimited visibility 400'
below a layer) or vice versa (for instance, flying on a clear, dark
night over water).

--Gary