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6 Answers

Army “hood” time as Instrument Flight Time for Helicopter ATP?

Asked by: 6217 views FAA Regulations, Helicopter

So digging into the FARs to see how the new ATP rules would affect my pursuit of a Helicopter ATP, I began to question my understanding of “Instrument flight time”. As an Army pilot of a non-IFR certificated aircraft (Mostly OH-58D), I assumed that my hood time would not apply as instrument time towards and ATP. But rereading the definition, it appears that my 70hrs of PIC hood would count.

  • 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.
  • 61.161 (4) 75 hours of instrument flight time in actual or simulated instrument meteorological conditions, of which at least 50 hours are obtained in flight with at least 25 hours in helicopters as a pilot in command, or as second in command performing the duties of a pilot in command under the supervision of a pilot in command, or any combination thereof.

I was flying solely by reference to instruments. Does it matter that my instrument was a non-IFR GPS/INS system? Am I mistaken in my understanding of the regulation?

To add even more confusion; what about my time during military IFR training? I was flying solely by instruments in an IFR certified B206 with my Army flight instructor, but I was not yet rated by the FAA. I had completed my "contact" phase, but I did not complete my MilComp until I was complete with my Instrument phase. So even as the sole manipulator of the flight controls, can I say I was a PIC? SIC doesn’t even exist for the B206 (or 58Ds for that matter).

6 Answers



  1. Sam Dawson on Sep 26, 2014

    1. You are not mistaken in your understanding of the regulation. The hood time in the OH-58D/TH-67 may be logged. For clarification:
    http://fsims.faa.gov/PICDetail.aspx?docId=062E8F923DEFEAE78525734F0076665D

    “5-439 USE OF AIRCRAFT NOT APPROVED FOR IFR OPERATIONS UNDER ITS TYPE CERTIFICATE FOR INSTRUMENT TRAINING AND/OR AIRMAN CERTIFICATION TESTING. The following paragraphs are intended to clarify the use of an aircraft not approved for IFR operations under its type certificate for instrument flight training and/or airman certification testing.

    A. IFR Training in Visual Meteorological Conditions (VMC). Instrument flight training may be conducted during VMC in any aircraft that meets the equipment requirements of part 91, §§ 91.109, 91.205, and, for an airplane operated in controlled airspace under the IFR system, §§ 91.411 and 91.413. An aircraft may be operated on an IFR flight plan under IFR in VMC, provided the PIC is properly certificated to operate the aircraft under IFR. However, if the aircraft is not approved for IFR operations under its type certificate, or if the appropriate instruments and equipment are not installed or are not operative, operations in Instrument Meteorological Conditions (IMC) are prohibited. The PIC of such an aircraft must cancel the IFR flight plan in use and avoid flight into IMC.”

    2. I would say you could not log the time in flight school as PIC time as you were not rated. I know it is different- you finished primary. But I have not seen anything from the FAA saying anything different.
    You still log this as flight time and hood time. It is dual received.

    Since it appears that you wish to get your ATP and perhaps pursue a flight career outside the military it is important to understand the differences between FAA and Army flight time.

    For example, as you already alluded to in the eyes of the FAA you may log PIC time as long as you are rated in the type of aircraft being flown, even if you are not acting PIC. FAA distinguishes between acting and logging PIC.

    Another major difference is that the FAA lets you log multiple modes of flight. For example in the Army if you are flying with a hood at night you are either logging night or hood time, not both. With the FAA you log both.

    Even the definition of flight time is different, though as a skid pilot this should not effect you. Wheeled helicopters that move under their own power are in “flight” under the FAA definition, but not with the Army until it lifts off the ground.

    Feel free to PM me if you have other questions.

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  2. Kris Kortokrax on Sep 26, 2014

    Wes,

    You can log the time, however it is not paragraph 5-439 which allows it. That paragraph allows a flight to be conducted under IFR (while remaining in VMC) even though the aircraft is not certified for flight in Instrument conditions. There is no mention of the word logging in paragraph 5-439.

    What does allow you to log the time is 14 CFR 61.51 (j)(3). That states that flight time may be logged in a military aircraft if it is under the direct control of the U.S. Armed Forces. If you flew by reference to the instruments in any military aircraft, you can log the instrument time.

    Further, 61.41 (a)(1) allows you to log training time conducted by a military instructor toward any Part 61 certificate.

    As far as the PIC question, did the 206 have an autopilot, or were 2 pilots required for the instrument flying? Was all your instrument time simulated or was it in actual?

    Where I’m heading with this is, if the flights were conducted in actual and two pilots might have been required because there was no autopilot, you might make a case for logging PIC or SIC performing duties of a PIC.

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  3. Sam Dawson on Sep 26, 2014

    Kris, his question was two part- he asked about the legality of logging the hood time in a non-IFR aircraft. Yes, the FAR deals with the logging of hood time, but the part about logging the time in non-IFR aircraft has been confusing enough that the question was even asked to the chief counsel (can’t find that opinion). While 5-439 does not discuss “logging” it even states that the paragraph is there to clarify the use of non-IFR rated airframes for instrument training. After all, if you can’t use the airframe for the training you can’t log it.

    The Bell 206 question (TH-67), is a little more complex. He was not a rated military aviator at this point. This was the instrument training phase of US Army flight school (my assumption since he mentioned OH-58D’s and the Army is the only branch that operates them). So he was receiving dual instruction in this airframe without an FAA certificate and without a military “rating”. This time may be logged as dual received, but not as PIC time. The matter of an autopilot or the requirement for two pilots is beside the point. Me may NOT log it as PIC unless you know of something from the FAA that states a military pilot may log PIC time prior to being rated. I don’t know of any such document.

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  4. Kris Kortokrax on Sep 26, 2014

    Here is a link to the legal interpretation.
    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/theriault%20-%20(2010)%20legal%20interpretation.pdf

    It only deals with the ability to fly under IFR in an aircraft not certified for flight in IMC. This is necessary because of the requirement in 61.65(e)(2)(ii). There is a need during training to perform a flight “under instrument flight rules”. Paragraph 5-439 allows us to do this in a 206 or R-44 or EC-120 or any other helicopter not certified for flight under IMC.

    It further states:
    “However, if the aircraft is not approved for IFR operations under its type certificate, or if the appropriate instruments and equipment are not installed or are not operative, operations in Instrument Meteorological Conditions (IMC) are prohibited. The PIC of such an aircraft must cancel the IFR flight plan in use and avoid flight into IMC.”

    It allows me to train without having all required equipment installed if I remain visual. I could put someone under the hood in a J-3 Cub with A/S, Altimeter and a Turn and Bank and log instrument training time because he is controlling the aircraft solely by reference to the instruments. I routinely trained instrument flying in an R-44 with all instruments except the Turn Coordinator. I could not, however, file an instrument flight plan and pick up a clearance without the Turn Coordinator.

    With the PIC issue, if he is hard up for instrument PIC, it might be worth asking for a legal interpretation. If he is close to having the 25 hours, it would be easier to just go fly the extra hours while prepping for the ATP.

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  5. Wes on Sep 26, 2014

    Thanks again guys for the replies.

    I was inclined to lean towards Sam’s interpretation of PIC time while training prior to a rating. I have a little over 70 hours of PIC hood time and 10-15 hours of full motion simulator IMC training that could make up the difference to get me to my 75 hours. Frankly, I would need to dedicate some serious study and flying time to be proficient enough to get passed the practical. The good news is that it is much less of a hurdle than trying to get all of that Instrument time from scratch. I will be taking every opportunity to file/fly/study IFR and prepare to get my ATP done. Who knows, true proficiency may take more than 75 hours for this instrument rated VFR only pilot.

    Kris, any idea if we should expect changes to RW ATP requirements similar to FW?

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  6. Kris Kortokrax on Sep 26, 2014

    They didn’t really change all fixed wing. Just Multi-engine.
    That was because Congress mandated the changes and Congress really screwed things up.
    The idea that you need Sim time prior to taking a written is crazy.

    I don’t see any changes coming for any of the other ATP requirements.

    With the PIC, I was just trying to figure a way for you to log the time. Doesn’t look like you really need it.

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