OK. I found what I was looking for...

http://groups.google.com/groups?hl=e...UTF-8&threadm=
32E55577.5B0B%40waid.com&rnum=3&prev=/groups%3Fhl%3Den%26lr%3D%26ie%
3DUTF-8%26oe%3DUTF-8%26q%3D1984%2B61.51%2Bifr%26sa%3DN%26tab%3Dwg

Said post references "Legal Interpretation #84-29" written Nov 7, 1984,
and quotes it in its entirety. Interestingly enough, it does indeed
contradict the FAQ almost directly...

"Simulated" instrument conditions occur when
the pilot's vision outside of the aircraft is intentionally
restricted, such as by a hood or goggles. "Actual" instrument
flight conditions occur when some outside conditions make it
necessary for the pilot to use the aircraft instruments in order
to maintain adequate control over the aircraft. Typically, these
conditions involve adverse weather conditions.

In my hunting, I also found the following thread:

http://groups.google.com/groups?hl=e...UTF-8&oe=UTF-8
&threadm=a6mhrr%249pg%241%40slb3.atl.mindspring.ne t&rnum=28&prev=/groups%
3Fq%3D61.57%26hl%3Den%26lr%3D%26ie%3DUTF-8%26oe%3DUTF-8%26start%3D20%
26sa%3DN

Which references a more recent opinion from January 28, 1992 (and is not
quoted in its entirety, nor does it reference a document number - so I
will be hunting for that later...). While it does not contradict the
above opinion, it reads as follows:

For currency purposes, an instrument approach under Section
61.57(e)(1)(i) may be flown in either actual or simulated IFR
conditions. Further, unless the instrument approach procedure must
be abandoned for safety reasons, we believe the pilot must follow
the instrument approach procedure to minimum descent altitude or
decision height.

The poster in that thread interprets that to mean that the entire
approach down to minimums must be in IFR conditions. I'm not 100% sure I
agree that it must be interpreted this way. But what is interesting is
that the Assistant Chief Counsel who authored this document referred
specifically to "actual or simulated IFR conditions" not "actual or
simulated IMC conditions"...


At the end of the day, I think I'm just gonna make sure to have some
foggle time with a buddy or an instructor every 6 months and be done with
it.

I hate lawyers!



Ron Rosenfeld wrote in
:

On Sun, 08 Feb 2004 06:48:17 GMT, Judah wrote:

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.

It seemed as if you wanted a copy of the original document. I gave you
the government source for that information. Under FOIA, you should be
able to contact them to obtain the document, knowing also that it was
written in 1984.

If you wish to pay for the document, Summit Aviation publishes a fully
searchable database of vital aviation publications, updated bi-weekly,
which should include this legal interpretation. I believe you can
purchase a single CD, but you'd have to check their web site for more
information.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)