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3 Answers

IFR Equipped vs IFR Certified

Asked by: 841 views FAA Regulations

A scenario: the TCDS for an airplane (in this case an 8KCAB) is silent on certification for VFR or IFR. The AFM states “VFR-only”. It is equipped iaw 91.205(d) and flown by a current IFR-rated ASE pilot. Can the airplane fly on an IFR clearance? 91.205 implies it can, but does the “VFR-only” in the AFM prohibit IFR flight or only flight in Instrument Meteorological Conditions? If operated in IMC on and IFR-clearance with the AFM VFR-only restriction, what regulation has been violated?
Citations, please.

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3 Answers

  1. Best Answer


    David R on Jan 30, 2025

    CFR 91.9(a) says you may not operate an aircraft except by complying with the operating limitations specified in the AFM. So if it says in the Limitations section of the AFM that the aircraft is VFR only, or VFR only flight is otherwise is considered an operating limitation, then you cannot operate the aircraft under IFR without violating 91.9(a).

    The question you seem to be asking is can you operate IFR when VMC , but it seems the relevant regs do not focus on the conditions but the rules. You are directed to operate only under Visual Flight RULES, not Visual Flight CONDITIONS and implicitly you cannot operate under IFRules, even if in VMConditions.

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  2. Mark Kolber on Jan 31, 2025

    Another piece. 91.205 does *not* “imply it can be operated under IFR.” 91.205 says this is the minimum equipment any aircraft needs to operate under IFR. It does not mean there are not other requirements. For example, a certain degree of static/lightning protection is required for IFR flight. That’s not mentioned in 91.205 but it is a certification requirement for IFR aircraft.

    That’s my main argument with mnemonics like the burning red fruit one. It leads people to thing 91.205 is the universe of required equipment. It is not.

    OTOH, the FAA does permit certain aircraft to be used for IFR training with a VFR limitation, so long as it stays out of the clouds. Whether the airplane you are talking about fits into that group is a question I cannot answer.

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  3. Kris Kortokrax on Jan 31, 2025

    You are allowed to file IFR while operating in VMC for training or certification purposes. Just comply with 91.205, 91.109, 91.311 & 91.413. You are responsible for avoiding any IMC, so don’t let a controller put you in a position where you would not have proper visibility and cloud clearance.

    See Order 8900.1 V5, Ch 2, S 9, Paragraph 5-439:

    5-439 USE OF AIRCRAFT NOT APPROVED FOR IFR OPERATIONS UNDER ITS TYPE CERTIFICATE (TC) 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 TC 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 §§ 91.109 and 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 pilot in command (PIC) is properly certificated to operate the aircraft under IFR. However, if the aircraft is not approved for IFR operations under its TC, or if the appropriate instruments and equipment are not installed or are not operative, operations in IMC are prohibited.

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