Closed ericberman closed 3 years ago
(source for this is here
It appears that it MIGHT be the case that you can’t “double-count” simulated instrument and night for purposes of experience towards a rating. If that’s correct (I’m airborne right now with insanely slow in-flight wi-fi, so I’m going to defer the research until later in the week), then it suggests a third approach that may even be cleaner: go ahead and log simulated instrument + night (after all, it was both of those!). But if you could choose to apply it to night experience towards a rating or to simulated-instrument towards a rating, then I could handle that in ratings progress.
Note, by the way, that the discussion ALSO sounded like this is a double-count prohibition between simulated instrument and night; cross-country didn’t really matter.
If the rating only needs one or the other, then all is good – I can credit all of what I see. And if the rating needs both, then I can credit the unambiguous stuff and create a pool of overlap from which to draw. So, for example, if a rating needs 10 hours of night and 10 hours of simulated instrument and in your flying you have 8 hours of night without simulated instrument, and 7 hours of simulated instrument without night, and 5 hours of overlapped night+simulated instrument, then I’d see the 8 and 7 and credit those directly; I could then at the end ask “are you short on night” or “are you short on simulated instrument” and credit the 5 hours towards one or the other (or both) as needed to maximize your eligibility.
E.g., in this example, you’re 2 hours short on night and 3 on simulated, so I could take 2 and apply it to night and 3 and apply it to the simulated instrument and voila you’re good on both. If you only had 4 hours of overlapped, I could put 3 hours towards simulated and 1 hour towards night, and you’re only short by one hour of night (or the other way around). Gotta think about how to apportion this and how to apply excess, but off the top of my head I suspect my priority list might be: (a) top off whatever has the biggest gap, but only as far as necessary to make it meet the required experience. (b) repeat until you run out of overlapped time or have nothing with gaps to top up. (c) if there’s still some overlapped time left, divide it equally among relevant experience categories.
Anyhow, all of this is dependent on the “it only matters towards ratings experience” interpretation being correct.
I’m tracking all of this on github.
Looks like if you DON'T hold a night rating, you can choose EITHER simulated instrument OR night flight, but not both; sounds like it's your discretion. If you DO hold a rating, you can log both. See email below.
Meantime, I'm going to change this issue to implement progress towards Canadian night rating.
From: Peter Campbell
Hello Eric, Let me try to answer your remaining questions, using your bullets as numbered points from top to bottom:
Peter T Campbell Director External Relations – Directeur, relations externes Canadian Owners and Pilots Association - Association canadienne des propriétaires et pilotes d'aéronefs
To: Peter Campbell
Good day, Peter!
Thank-you – looks like 421.42 is where this applies (for aeroplanes); that’s the reference I wanted.
I think I understand this, but I still have a few clarifying questions.
• If you DO have a night rating and fly at night in IMC (not hood, presumably you have an instrument rating or have an instrument instructor providing instruction?) you CAN log both night and instrument; that seems clear from your answer. • If you DO have a night rating and fly at night in VMC under the hood (presumably with a safety pilot…) you CAN log both night an instrument (simulated instrument) time. Is that correct? • If you DO NOT have a night rating, but fly at night in VMC with a qualified safety pilot (presumably required for hood work) OR fly at night in IMC, you CANNOT count that towards 421.42’s experience requirement. What’s a bit ambiguous to me, though, is whether you can still count it as overall night-instrument experience, or must you log that exclusively as instrument time, with no night time? I.e., is the prohibition against logging it at all, or simply against counting it towards 421.42? E.g., perhaps you have logged 12 hours of night (no IMC or hood work) in your logbook, meeting the requirements of (i)(A) and (i)(B). If you now go for a 2 hour instrument training flight at night under the hood (or even in IMC) with an instructor, could you not log that as both instrument and night time, and credit those 2 hours towards 421.42(1)(a)(ii)/(iii), since it meets (iii)’s requirement of being “in addition” to the night flying requirement? • Anything in a ground-simulator cannot be counted towards 421.42’s night experience (421.42(a)(iii)). Here my question is that it appears from the text that as long as you meet the 10 hours of night without that instrument time, there’s no problem. I.e., if you have, say, 15 hours of visual night experience in an aeroplane, and 13 hours of dual day instrument time in an aeroplane, then you’ve met the “in addition” requirement and there’s no problem adding more to it. No?
From: Peter Campbell
Good day Eric,
The rules are in the 400 and 420 series of Canadian Aeronautical Regulations (CARs) but let me simplify for you. And a word of caution that simple answers with regards to our CARs are rarely a 100% answer.
If you are receiving instruction for a night rating, and particularly the Instrument requirement to log 5 hours of either HOOD or SIMULATOR (described in our orders as “Ground time”) you CANNOT log BOTH NIGHT and INSTRUMENT at the same time for the purpose of attaining the NIGHT RATING.
Once you have achieved the NIGHT RATING AND an Instrument Rating you can log BOTH NIGHT and INSTRUMENT Time at night if the conditions required you to maintain control of the aircraft using inside (instruments) references instead of outside (VFR) references.
If you are using a safety pilot, who is qualified to be a safety pilot at night, most likely an Instructor or is the holder of an Instrument Rating for that type of aircraft (aeroplane versus helicopter), then you CAN log BOTH NIGHT and HOOD time simultaneously.
So, I suspect that the subject pilot was likely in the process of attaining a NIGHT Rating, and as such he couldn’t log both. Typically, most flight schools in my area of Canada will conduct a majority of the required Instrument time during the day and leave the accumulation of NIGHT to nighttime.
Best regards,
Peter T Campbell Director External Relations – Directeur, relations externes Canadian Owners and Pilots Association -
Primarily affects the Canadian print layout. So if you fly for an hour and 30 minutes is at night, but you had 60 minutes of simulated IMC, then it's all "day-xc".