Can a pilot log simulated instrument time with these conditions and what regs would justify this:

  1. VMC
  2. Safety pilot on board
  3. View limited device
  4. VFR-only aircraft
  5. Unapproved instrument navigation devices (ie. handheld NAV/COM)
  6. Location USA

Say the pilot had a copy of Foreflight and a handheld NAV/COM with ILS capability. Aircraft is has typical VFR 91.205 equipment.

  • $\begingroup$ You are practicing LOC & VOR approaches? Don't those usually require a 2nd instrument as well to determine location (distance) fixes, such as the IAF? $\endgroup$
    – CrossRoads
    May 4, 2018 at 18:50
  • $\begingroup$ I searched the airports around me at www.airnav.com, which also has links to FAA approach charts for each airport, and all needed two VORs, or VOR/DME, or LOC/VOR or LOC/DME. One VOR alone does not appear to be enough. $\endgroup$
    – CrossRoads
    May 4, 2018 at 18:58
  • $\begingroup$ There seem to be a few radios with that capability sportys.com/pilotshop/avionics-and-radios/aviation-radios.html Reception range might be reduced, or spotty, without an external antenna. You'd have to check on which had Marker Beacon reciever as well so you can tell how far down the approach you are. Have you done any searching at faa.gov/regulations_policies/faa_regulations under the 14 CFR Part 61 or part 91 sections yet for loggability? $\endgroup$
    – CrossRoads
    May 4, 2018 at 19:17
  • $\begingroup$ If you interpret "under simulated conditions" liberally, I think that would satisfy the letter of the regulation, though not the spirit. You wouldn’t even need a radio with ILS capability since you can use Foreflight to fly GPS, Localizer, and VOR approaches. $\endgroup$
    – JScarry
    May 4, 2018 at 19:27
  • 3

1 Answer 1


It is simply a VFR flight, you need to meet normal VFR requirements plus a qualified safety pilot to watch outside for traffic. I assume this aircraft has the minimum IFR flight instruments not including navigation, and is being used to practice basic instrument attitude skills, otherwise I don't know what the point would be. Flight by reference to instruments implicitly requires instruments to reference; a handheld device can not provide gyroscopic data as these inherently need to be fixed to the aircraft frame.

  • $\begingroup$ The question seems to be asking strictly about whether the regulations allow something, not whether something is possible. As to what is possible, I've seen video of a Cessna 140 being flown in IMC with no artificial horizon, turn rate indicator covered up, wet compass as the primary reference instrument, pilot's hands off yoke, actively making course corrections with rudder. A handheld GPS was being used for overall situational awareness to ensure that the aircraft was remaining in the general area where terrain clearance would be adequate. $\endgroup$ Nov 28, 2020 at 9:14
  • $\begingroup$ "What is the optimal heading" for such a maneuver, could be grounds for another ASE question. Most pilots don't know the answer. Of course as per the actual question, one challenge with using the wet compass for simulated instrument flying, is that it is often located up near the windscreen. However a "heading" display on a handheld GPS might serve as a feasible alternative. $\endgroup$ Nov 28, 2020 at 9:15
  • $\begingroup$ Not sure what your comments are about. I answered about what the regulations allow, it is legally a normal VFR flight. A compass is an instrument. Handheld GPS does not provide heading, it provides ground track. Being able to fly with a wet compass if some of the gyros fail in flight is a regulatory requirement in the USA. $\endgroup$
    – Max Power
    Dec 2, 2020 at 0:06
  • $\begingroup$ But the question was not "is it legally a normal VFR flight." The question was, may the pilot, wearing a view limiting device, log simulated instrument time. I took your statement "Flight by reference to instruments implicitly requires instruments to reference" to mean that it would not even be possible to control the aircraft (using a view limiting device) given the equipment list in the original question, and my comments were meant to suggest otherwise. $\endgroup$ Dec 2, 2020 at 19:20
  • $\begingroup$ Re "Being able to fly with a wet compass if some of the gyros fail in flight is a regulatory requirement in the USA" -- since my comments, as well as the original question, referenced a case where no gyro instruments were available to the pilot, I'm not sure what the relevance of this comment is. $\endgroup$ Dec 2, 2020 at 19:20

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