Do I need my old analog clock?

[carusoam]

Welcome aboard, Mike!

I’m a bit late today...

I livened up your link... 

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/Interpretations/data/interps/2016/Nkugba - (2016) Legal Interpretation.pdf

Best regards,

-a-

 

[gsxrpilot]

56 minutes ago, jlunseth said:

I have two legal digital clocks. One is an EI Superclock that presents a digital display of local time or Zulu with a push of a button. It also can present a timer, again with a push of a button. That is all it does.  It does not switch out to a GPS view, or some other view. The second one is my JPI930 which constantly displays Zulu time along the bottom edge, I think the time is derived from the GPS. When I want a clock function though, I just use the Superclock. 

Ok, just playing Devil's Advocate here... 

Your Superclock doesn't display seconds on any of the clock displays. It only displays seconds for the countdown timer. Also how is it anymore "permanent display" than the zulu or local time displayed on my IFD540 GPS? Sure I can turn it off, (not permanent) but I can leave it on in a data block on the edge of the GPS display. 

The regs say it has to have a "permanent display" and display hours, minutes, seconds.

[kortopates]

4 hours ago, gsxrpilot said:

What clock do you have in your panel? Because by that definition, no digital clock that I can find anywhere, would meet the requirements. Including the one installed in my Mooney when I bought it.

Paul, All Mooney's left the factory with a clock. The IPC for our K's lists many different possibilities that range by year of production. Per the IPC was even some options for Mid-Continent and Davtron clocks. When I got my 252, the clock was an Astrotech, a similar digital quartz clock,  which I assume was a replacement clock. 

I now have a Guardian Aero-553 combination clock, CO monitor multi-function unit that fits in my old clock position. https://www.guardianavionics.com/aero-553-panel-digital-display-multi-function-co-detector-tso-certified-aircraft I always felt in Turbo's a CO monitor was vital and wanted the additional reliability of one installed in the panel. It too doesn't show seconds continuously - which is what I assume you are getting at. But the main thing I believe the FAA is trying to enforce is that something is dedicated to displaying time full time.

But like Rich said above, which I agree with, you'd really have to piss off someone at the FAA to be cited for not having a permanent clock. But since the legal enforcement that was cited at the beginning of this thread for flying IFR without one was with a hangar neighbor of mine that was flying for hire I'll have to ask to get the rest of the story.

 

 

[kortopates]

3 hours ago, EricJ said:

FWIW, the IFD lets you put the time, which includes seconds, in the top data field, and it's there all the time regardless of screen/menu selection.

 

I am sure that's acceptable. The GTN's can do the same thing, but to be permanent it has to be an installation without all the options like an integrated Transponder code. But for many of us, myself included, I wouldn't use up a field for Zulu time unless I really needed too. 

[EricJ]

20 minutes ago, kortopates said:

I am sure that's acceptable. The GTN's can do the same thing, but to be permanent it has to be an installation without all the options like an integrated Transponder code. But for many of us, myself included, I wouldn't use up a field for Zulu time unless I really needed too. 

I have a digital clock in the panel that has AZ local time on it.   The zulu on the IFD has been really handy when it's near the top of the hour to tell whether ATIS is fresh or an hour stale, as it's usually a lot quicker than doing it in my head. 

Edited November 5, 2020 by EricJ

[gsxrpilot]

15 minutes ago, kortopates said:

Paul, All Mooney's left the factory with a clock. The IPC for our K's lists many different possibilities that range by year of production. Per the IPC was even some options for Mid-Continent and Davtron clocks. When I got my 252, the clock was an Astrotech, a similar digital quartz clock,  which I assume was a replacement clock. 

I now have a Guardian Aero-553 combination clock, CO monitor multi-function unit that fits in my old clock position. https://www.guardianavionics.com/aero-553-panel-digital-display-multi-function-co-detector-tso-certified-aircraft I always felt in Turbo's a CO monitor was vital and wanted the additional reliability of one installed in the panel. It too doesn't show seconds continuously - which is what I assume you are getting at. But the main thing I believe the FAA is trying to enforce is that something is dedicated to displaying time full time.

But like Rich said above, which I agree with, you'd really have to piss off someone at the FAA to be cited for not having a permanent clock. But since the legal enforcement that was cited at the beginning of this thread for flying IFR without one was with a hangar neighbor of mine that was flying for hire I'll have to ask to get the rest of the story.

Surely this is one of those subjects that can be argued forever. But my point is that there is no need to read so deeply into the FAA's position on this. It seems pretty clear that a wrist watch is not acceptable to the FAA as the only timepiece for IFR flight. But if you follow the FAA's opinion to the "letter" none of the digital or aftermarket clocks comply. 

Another installed appliance with a permanent clock display that meets the requirements of§ 91.205(d)(6) that displays "hours, minutes, and seconds with a sweep-second pointer or digital presentation," is adequate for the purposes of this regulation

a) A clock must display the current time in a specified time zone.
b) Hours, minutes, AND seconds must be displayed
c) The clock display must be permanent.

Reading this to the letter, as many have argued in this thread, (a) eliminates timers, (b) requires seconds be displayed with the hours and minutes of the clock, and (c) means the clock has to be displayed at all times.

None of the Davtron, the EI, the Guardian Aero, or any others meet this requirement.

First of all, none of them display the seconds with the time. If they do display seconds it's only with the timer function. Secondly all of them can be moved off the clock display. Some to Hobbs time, some to timer functions, some to cabin altitude, CO levels, etc. None of them have a "permanent" clock display.

Therefore, I believe it is reasonable to assume that any panel mounted, or installed instrument that can be configured to display the time, will suffice to comply with the regs regarding a clock for IFR flight. And that would include any GPS that can display time.

FWIW I happen to have an EI Superclock, an IFD540, a Guardian Aero-553, and an AV-20s multifunction display, all installed in my panel, all of which can display the current time in either Local or Zulu, but none of which are a "permanent display" of a clock nor have seconds displayed with the time. I personally am comfortable with the belief that any of them suffice to satisfy the regs. Just my $0.02 and really not worth even that much.

[Andy95W]

I can’t believe we’ve revived a nearly 3 year old thread and are now arguing about it again.

[EricJ]

1 hour ago, Andy95W said:

I can’t believe we’ve revived a nearly 3 year old thread and are now arguing about it again.

What's surprising about that? 

 

[jlunseth]

11 hours ago, jlunseth said:

I have two legal digital clocks. One is an EI Superclock that presents a digital display of local time or Zulu with a push of a button. It also can present a timer, again with a push of a button. That is all it does.  It does not switch out to a GPS view, or some other view. The second one is my JPI930 which constantly displays Zulu time along the bottom edge, I think the time is derived from the GPS. When I want a clock function though, I just use the Superclock. 

Probably a little hard to read in this picture, but the fifth number from the left on the bottom of the 930 screen is Zulu time, 20:50:08. Constant display. As you can see from this picture, I am not that great at resetting the EI when I should, when they work on my plane and disconnect the battery (which stops the clock). My only point is that there is such a thing as a permanent digital clock display.

I see this must have been shortly after the JPI was sent in to make it compatible with CiES senders. When it came back the engine designation was wrong (it's an LB, not a GB), among other things, which has since been fixed.

I suppose if you read permanent very literally even the JPI is still an issue because it does not display when the master is off, but I don't think it has to at that point, the aircraft is not being operated.

Edited November 5, 2020 by jlunseth

[flysamo]

we use the clock every flight, we have a Mid Con clock with Dual 5 amp USB ports, our way of using a clock and during ck ride we have been asked for One minute holding pattern, even if we have a gtn 750 showing the pattern

[201Mooniac]

12 hours ago, gsxrpilot said:

Surely this is one of those subjects that can be argued forever. But my point is that there is no need to read so deeply into the FAA's position on this. It seems pretty clear that a wrist watch is not acceptable to the FAA as the only timepiece for IFR flight. But if you follow the FAA's opinion to the "letter" none of the digital or aftermarket clocks comply. 

Another installed appliance with a permanent clock display that meets the requirements of§ 91.205(d)(6) that displays "hours, minutes, and seconds with a sweep-second pointer or digital presentation," is adequate for the purposes of this regulation

a) A clock must display the current time in a specified time zone.
b) Hours, minutes, AND seconds must be displayed
c) The clock display must be permanent.

I would expect https://www.truebluepowerusa.com/products/aviation/usb-charging-ports/md93/ to comply, thoughts?

[Hank]

53 minutes ago, 201Mooniac said:

I would expect https://www.truebluepowerusa.com/products/aviation/usb-charging-ports/md93/ to comply, thoughts?

Three of the five display modes are not "clocks," and because the timers replace the clock [unless I missed the second set of display elements], it is not a permanent clock display and therefore is no closer to complying than any of the other options discussed above . . . . .

That's my 2¢. Apologies if I am overcharging.

[kortopates]

13 hours ago, gsxrpilot said:

Surely this is one of those subjects that can be argued forever. But my point is that there is no need to read so deeply into the FAA's position on this. It seems pretty clear that a wrist watch is not acceptable to the FAA as the only timepiece for IFR flight. But if you follow the FAA's opinion to the "letter" none of the digital or aftermarket clocks comply. 

Another installed appliance with a permanent clock display that meets the requirements of§ 91.205(d)(6) that displays "hours, minutes, and seconds with a sweep-second pointer or digital presentation," is adequate for the purposes of this regulation

a) A clock must display the current time in a specified time zone.
b) Hours, minutes, AND seconds must be displayed
c) The clock display must be permanent.

Reading this to the letter, as many have argued in this thread, (a) eliminates timers, (b) requires seconds be displayed with the hours and minutes of the clock, and (c) means the clock has to be displayed at all times.

None of the Davtron, the EI, the Guardian Aero, or any others meet this requirement.

First of all, none of them display the seconds with the time. If they do display seconds it's only with the timer function. Secondly all of them can be moved off the clock display. Some to Hobbs time, some to timer functions, some to cabin altitude, CO levels, etc. None of them have a "permanent" clock display.

Therefore, I believe it is reasonable to assume that any panel mounted, or installed instrument that can be configured to display the time, will suffice to comply with the regs regarding a clock for IFR flight. And that would include any GPS that can display time.

FWIW I happen to have an EI Superclock, an IFD540, a Guardian Aero-553, and an AV-20s multifunction display, all installed in my panel, all of which can display the current time in either Local or Zulu, but none of which are a "permanent display" of a clock nor have seconds displayed with the time. I personally am comfortable with the belief that any of them suffice to satisfy the regs. Just my $0.02 and really not worth even that much.

Agree with 99% of that Paul and 110% on the practicality of any of those satisfying the regs. Where I diverge a bit is that the letter of interpretation specifically says the appliance doesn't have to entirely dedicated to the clock and than multiple functions are allowed. That's leaves room for a lot of interpretation, but when we include the "permanent display" reference that suggest to me at least that time display should be main display or default which is not the case with many of the GPS examples where you may need to go find the time. 

That leaves seconds display that most of these multi-function clocks don't provide in the clock mode. This is the most glaring example as you well point out that these don't meet. I can't explain that except that its pretty clear the FAA over looks this as well. Maybe we need another letter of interpretation just on the missing seconds display for them to come out an accept that - or not. 

Personally I don't think we'd have this nebulous issue of what meets the clock requirements if there was a true TSO standard for an IFR Clock. But all the clocks that are TSO'd are TSO'd for something other than the clock function like the USB port DC-DC conversion C71. There is no standard for a clock that I am aware.

In terms of practicality in the cockpit, in truth I use my wristwatch for current time, as primary which is accurate to the second since its also GPS based. For all timing functions, I my GTN provides all of those including time between checking tanks, timing flight duration and especially time to waypoint and length of legs in holding pattern. Those things are entirely automated. The egg timer we used as IFR students became obsolete with GPS IMO. 

[kortopates]

24 minutes ago, Hank said:

Three of the five display modes are not "clocks," and because the timers replace the clock [unless I missed the second set of display elements], it is not a permanent clock display and therefore is no closer to complying than any of the other options discussed above . . . . .

That's my 2¢. Apologies if I am overcharging.

 

Yes, but the letter specifically allows that the clock not be the sole function:

For the reasons set out below, the required clock must be an installed appliance, but an installed appliance with a permanent clock presentation which means the requirements of § 91.205(d)(6) will suffice - it is not necessary that the appliance's sole function be time keeping.

As previously mentioned that leaves a lot of interpretation between "Permanent display" and not sole function, but IMO it at least includes something like this of any appliance where the default mode is to display time. But it seems to  leave out a lot of appliances where a clock isn't always being displayed and you have to go searching for it  - but that's only my interpretation.

[0TreeLemur]

1 hour ago, kortopates said:

Yes, but the letter specifically allows that the clock not be the sole function:

For the reasons set out below, the required clock must be an installed appliance, but an installed appliance with a permanent clock presentation which means the requirements of § 91.205(d)(6) will suffice - it is not necessary that the appliance's sole function be time keeping.

Best clock/timer I've found so far, with a really useful secondary function.  Shows seconds in all views.

 

[Hank]

On 11/5/2020 at 2:46 PM, 0TreeLemur said:

Best clock/timer I've found so far, with a really useful secondary function.  Shows seconds in all views.

 

The top view doesn't show time ("expect further clearance by 1725"). The bottom view doesn't show time or seconds . . . A clock that doesn't show the time just ain't much of a clock! 

[0TreeLemur]

11 hours ago, Hank said:

The top view doesn't show time ("expect further clearance by 1725"). The bottom view doesn't show time or seconds . . . A clock that doesn't show the time just ain't much of a clock! 

The AV-20 actually does contain a clock I just didn't show that view.  The iPad always shows the accurate time and date and is easy to read.  I've got a Davtron Zulu, local, & timer in the yoke (see earlier in this thread) that I can use to verify Zulu time.  I can cross check it quickly using the GPS, and the engine monitor.  As shown the timers on the AV-20 indicate seconds.  The automatic flight time I find really helpful for fuel management.  The battery backed-up AI provides a lot of redundancy that I think makes it the most useful thing to put in a 2-1/4" hole.  I'd rather be looking at that when partial panel in the soup than an 8-day clock doing its happy second-hand sweep.

[Hank]

3 minutes ago, 0TreeLemur said:

The AV-20 actually does contain a clock I just didn't show that view.  The iPad always shows the accurate time and date and is easy to read.  I've got a Davtron Zulu, local, & timer in the yoke (see earlier in this thread) that I can use to verify Zulu time.  I can cross check it quickly using the GPS, and the engine monitor.  As shown the timers on the AV-20 indicate seconds.  The automatic flight time I find really helpful for fuel management.  The battery backed-up AI provides a lot of redundancy that I think makes it the most useful thing to put in a 2-1/4" hole.  I'd rather be looking at that when partial panel in the soup than an 8-day clock doing its happy second-hand sweep.

But the regulations say that a clock with hours, minutes and seconds must be visible all of the time. You have several electronic devices that can be set to display a clock or something else; some of the clocks do not have seconds, some of the other things have seconds and elapsed time but not "what time is it right now."

[David Lloyd]

The AV20 is install under NORSEE rules and the instructions state it does not replace any required equipment. I think this is all splitting hairs but if you're getting busted for other things, they might just pile on more for the AV20.  I need a clock and temperature gauge, looked at the AV20 and even though I liked it have chosen to go in a different direction.

[0TreeLemur]

On 11/4/2020 at 10:58 PM, Andy95W said:

I can’t believe we’ve revived a nearly 3 year old thread and are now arguing about it again.

Nothing else going on in the world...

[M20F]

I hate the writing of the ruling.

VFR = Visual Flight Rules

VMC = Visual Meteorological Conditions

You aren’t IFR in VFR, you are IFR in VMC. 

The more interesting question is how did he even get violated in the first place.  

[SukiEgan]

Hi.. for what reason would I need a goliath, curiously large schedule demonstrating me it's "Saturday, November 14". I get this data by floating throughout the time w/my mouse. Furthermore, clearly I can set two extra tickers like GMT, Eastern, Pacific and so forth I know it's a matter of taste however I dont like the Win10 clock.

 

turnkey assembly services

Edited January 8, 2021 by SukiEgan

[Hank]

6 hours ago, SukiEgan said:

Hi.. for what reason would I need a goliath, curiously large schedule demonstrating me it's "Saturday, November 14". I get this data by floating throughout the time w/my mouse. Furthermore, clearly I can set two extra tickers like GMT, Eastern, Pacific and so forth I know it's a matter of taste however I dont like the Win10 clock.

Lots of things in Winders that I really dislike, including most things about 10. If it's only the stupid clock that bothers you, count your blessings! It's hugely bloated, inefficient, wastes my time searching for applications in those stupid icon-things because the Search functionis useless, and I really don't need the Photo icon to scroll linearly or randomly through all of the pictures on my desktop while another tile is scrolling through the daily Dow Jones stock prices, and other tiles are doing other things.

[N201MKTurbo]

16 minutes ago, Hank said:

Lots of things in Winders that I really dislike, including most things about 10. If it's only the stupid clock that bothers you, count your blessings! It's hugely bloated, inefficient, wastes my time searching for applications in those stupid icon-things because the Search functionis useless, and I really don't need the Photo icon to scroll linearly or randomly through all of the pictures on my desktop while another tile is scrolling through the daily Dow Jones stock prices, and other tiles are doing other things.

Windows peaked with XP. It has just been a works project to keep Microsoft developers off the street since then.

It seems like it takes 1000 times the resources to go half as fast!

If you think Windows is bad, you should see what they have done to Visual Studio.

Edited December 16, 2020 by N201MKTurbo

[hammdo]

3 hours ago, N201MKTurbo said:

If you think Windows is bad, you should see what they have done to Visual Studio.

Tell me about it. I live in that mess ~12 hrs out of the day. I have to upgrade my laptops often just to keep it fast...

-Don