Do I need my old analog clock?

[RLCarter]

2 hours ago, gsxrpilot said:

I passed my IFR checkride back in 2009 in a Cherokee with a digital egg timer velcro'd to the panel. It was only a timer and didn't display time. I was wearing a wristwatch at the time which displayed both local and GMT. 

There was no GPS or moving map display in the panel and I used the egg timer to time holds, let-downs, procedure turns, and partial panel turns. The DPE never said anything about it.

Did mine in a 172, there was a clock in the panel that was covered up and placard In-op, DPE said at least it was correct twice a day and laughed. I had a clock/timer that I purchased at Wally World Velcroed to the yoke and he was happy

[jetdriven]

Maybe there’s is difference in passing an IfR checkride in VFR conditions vs having an aircraft properly equipped for IFR flight. I just wanted the clock to keep track of flight time and to monitor OAT and voltage. 

[jlunseth]

Think about this.  The clock is an IFR requirement.  Although position reports are rare as hens teeth these days, we are still required to be able to give one if needed.  What’s the first item in a position report after the aircraft tail number?  Its present Zulu time.  Then you need to give the Zulu arrival time at your next required reporting point.  If you do not have a clock in the panel that provides hours, minutes and seconds in Zulu time, or at least local time that can be translated to Zulu, you don’t have the equipment to provide a position report and don’t comply with 205(d)(6).  You also don’t have the equipment to perform the “lost comm” procedures.  Timers don’t count unless they display Zulu or local time. In fact, 205(d)(6) does not require that there be a timer in the aircraft at all, just a clock.  However, the display can be analog or digital under (d)(6).  On my panel, at the very bottom of the JPI 930 display, there is a constant display of Zulu time in hours, minutes and seconds.  I also have an EI clock with a timer and other functions, but the JPI display does it for the legalities. 

My checkride was all VFR.  We did not request or accept a clearance, therefore it was not IFR. Actually, I found that confusing because I had never flown approaches, etc. while VFR under the hood, the instructions are different, but it worked out.  I had a clock, but one would not technically have been required in that situation, although you might call that out to the DPE ahead of time so they know you know.  Most DPEs don’t want to do checkrides under a clearance, because that makes them PIC.  Your deviation is their responsibility.

Having an aircraft “IFR certified” does not mean the A&P has gone through the equipment in the aircraft to make sure it complies with 205(d)(6), that is the pilot/owner’s job.  It only means that the necessary every-two-year static and altimeter checks have been performed as required by 91.411.  If you were doing a pre-buy you might want to make sure the A&P inspects the aircraft for all necessary equipment for IFR, not just the IFR cert. stuff.

[Yetti]

On 1/3/2018 at 8:26 PM, jetdriven said:

A nice Davtron M803 makes it legal. And more importantly, safer. It displays bus voltage all the time, and since you’re flying an electric airplane, that’s important. 

How does that meet the "sweep hand" requirement?

[jlunseth]

The requirement in 205(d)(6) is for "a sweep-second pointer or digital presentation."  [My italics.]  Someone posted the reg. earlier.

I don't have a Davtron, but if it is a digital clock that displays hours, minutes and seconds, it complies.

[Yetti]

I'll have to look, but my PoH says "sweep hand"   I believe the PoH would take precedent.  So then it would need to be STCed to the airframe to change the Type Certificate.       

[jlunseth]

Not exactly.  Its your Type Certificate that governs, not the POH.  Replacements and additions can be made a number of ways, one being installing a PMA’d clock.  I am not expert on this, but if you go to Davtron’s website you will find a link to the FAA’s letter saying that clock replacement in a non-transport category aircraft is a minor repair, and Davtron’s is PMA’d.  I would have an avionics shop add it.  There are others, EI has a good one that is digital and you can choose Zulu v. Local Time, and it also has timers.  That’s what I have in my aircraft.  

The one thing I would check on a digital clock for your panel is lighting.  You need to have dimmable lighting.  If you don’t, you will find yourself flying along at night with everything on the panel dimmed down to save your night vision, but the clock is blaring light.  You don’t need that.

[Jim Peace]

On 1/5/2018 at 8:04 AM, jlunseth said:

What’s the first item in a position report after the aircraft tail number?  Its present Zulu time.

Correct me if I am wrong but......the first thing in a position report after tail number is your position......present Z time is never in any report that I know of.....

It is PTA, PT, P

Mooney NXYZ, position, timeZ, Altitude.....estimating position at timeZ, then next compulsory point.

You never want to give present Z time in a report.  It is always the time that you crossed the point.  Back in the old days before CPDLC it could take over 30min to get a report in.

 

 

Edited January 6, 2018 by Jim Peace

[jlunseth]

I remember position and time as a unit, i.e. “EON 36” and the crossing time was not the full expression of Zulu time, it was just the minutes after the hour.  I don’t remember ever waiting 30 minutes to do a report, but you are right if you were delayed you would report crossing time, not present time.  It doesn’t change what I was saying though.  The requirement in 205 is for a clock that reads in Zulu or local time, you can’t make the report without that, whether its present time or crossing time.  A timer does not do it.  

The last time I was asked to give a non-radar report in the traditional format was over the Bahamas seven years ago, and the controller stopped me half way through.  A year or so after that I was flying out to the Dakotas and the controller said he either needed me a couple thousand feet higher (into strong headwinds) or he would need non-radar reports.  I chose the couple thousand feet higher, I was not sure I could still spit the reports out correctly it had been so long.  But it is still there in 91.183, and I believe it is also in the ADIZ reporting requirement which is in 99.  However, having crossed to the Bahamas several times and listened to the radio traffic, I have never heard an ADIZ report.  I asked several years ago on another board (the AOPA forum) and all I heard was that no one bothers with them anymore, because you are in radar contact when crossing.  It doesn’t change what is in the regs. you need a clock.

 

[gsxrpilot]

I've never given a position report that included zulu time or any time. There is always a spot over New Mexico on my way to Durango where I'm out of radar coverage. ATC always asks for position reports but it's alway "where are you right now". And it never includes time.

These are probably not the position reports you're referring to.

My CFII told me a wrist watch would suffice and my check ride was in a Cherokee without a clock and I used my wrist watch to give Zulu time. He didn't have an issue with it.

But I'm not trying to argue that it's against the regs, but I doubt it's a huge deal.

[Jim Peace]

1 minute ago, gsxrpilot said:

These are probably not the position reports you're referring to.

No....they are not

[Jim Peace]

Being that I do not really fly IFR in a single, my plane has local time displayed.

My plane is located on the east coast most of the time and it is easy to add 4 or 5 hours.  If I lived on the west coast I would need to have a calculator and a slide ruler or just set it to Z time.

 

 

[ArtVandelay]

My watch has both, my onboard clock has both, I can never remember if I add 4 or 5. Garmin Pilot uses local times for trip, flightplans now, especially helpful if crossing time zones.

[jlunseth]

19 hours ago, Jim Peace said:

Being that I do not really fly IFR in a single, my plane has local time displayed.

My plane is located on the east coast most of the time and it is easy to add 4 or 5 hours.  If I lived on the west coast I would need to have a calculator and a slide ruler or just set it to Z time.

 

 

There is nothing in the reg. that mandates what time zone the clock must be set to.  It just requires a “clock” as opposed to a timer.  You could certainly make a “minutes after the hour” position report (i.e. “EON 36”) using local time, or Zulu.  

And as far as position reports not involving Zulu time are concerned, that was what I was saying, I have not given such a report in a very long time.  Today, ATC usually gives you a point to report in, and that is what you do, you report in (“Mooney 381SP, 35 west of Minot”).  What I was doing, was explaining why 205 requires a clock.  If you do not have a clock you cannot comply with 183, or the ADIZ requirement in sec. 99.  183 reports are for a non-radar environment, which itself is unusual now, and ATC typically does not want them anyway, so it gives you an alternate reporting method.  But 183 and the 99 ADIZ report are still in the books, and therefore 205 reads the way it reads.  I am not saying anything about what is normal, 183 reports are not normal and haven’t been for a long time.

Go read 91.183, you will see what I mean, “time and altitude” at required report points.  Also 99.15(b).

I say again, the requirement is for a panel mounted clock that displays time, whether by sweep second hand or digital display.

[Jim Peace]

On 1/4/2018 at 10:36 AM, PTK said:

When I was looking to replace my OEM clock I wanted one with two time displays. I couldn’t find one and I thought I was being too picky, it’s just a clock after all. Or is it?! But I called Kevin at Davtron and he recommended their M802. I couldn’t be happier! I really like it because it has the two time displays. It permanently displays zulu as well as local time along with the usual timer functions. Davtron makes excellent products. I also have the M655 primarily for an instantaneous display of DA. It has a few other functions incl. OAT. 

 

Where did you find this clock?

On their website it still shows under development.  Also how much is it?

Can it be dimmed from the CDU or only from the ships dimming circuit?

Jim

[Mike Racine]

Here’s the FAAs official answer about clocks...

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/Interpretations/data/interps/2016/Nkugba%20-%20%282016%29%20Legal%20Interpretation.pdf

...and the answer is yes, your GPS will suffice. I really like the timer functions of my GTX330ES transponder. And you can set it up so that using a countdown timer, it’ll announce “Timer expired” in your headset...

[jlunseth]

 I disagree with that opinion a little bit, but not in the Ass't. Chief Counsel's ultimate conclusion. The part I disagree with is her discussion of airworthiness:

"In a 1981 legal interpretation, the FAA stated that a civil aircraft may not be operated IFR without a working clock. Section 91.165 provides in pertinent part that no person may operate a civil aircraft unless it is in an airworthy condition, and that between inspections, defects in the aircraft must be repaired as prescribed in Part 43. Thus, to maintain the validity of the airworthiness certificate without a change to the type certificate, the clock must be operating for all operations, and operations with the clock inoperative would violate Sections 91.165, 135.3, and 135.143(a). A wristwatch would not substitute for the clock.

Section 91.165 has been recodified at § 91.405. The guidance in this 1981 interpretation applies equally here - without a properly installed, working clock, a civil aircraft cannot be operated because it would not be considered airworthy."

The blanket statement that "without a properly installed, working clock, a civil aircraft cannot be operated because it would not be considered airworthy" is not accurate. Not having a clock does not render an aircraft per se unairworthy (unless a clock is in the TC or a Required Equipment list). 91.205(b) ("TOMATO FLAMES") does not require a clock for VFR operations. It is true that the aircraft may not be used for IFR ops under 205(d) without a clock. But 205(a) makes clear that it is not legal to operate the aircraft under certain conditions without specified equipment. I could see the FAA making an argument, in an enforcement action against a pilot who operated an aircraft in IFR without a working clock, that the aircraft was unairworthy for use in IFR, but that is not a per se airworthiness issue. IMHO.

 

[kortopates]

The primary problem with a GPS clock is that for it to meet the requirements stated in the letter it must provide a permanent clock display:  

"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.

So unless GPS clock time is being displaying somewhere "permanently", the GPS clock isn't going to be meet the requirement. With only a few data fields to display on the main GPS screens, typically time is pretty far down on our list compared to the importance of fields like TRK, DTK, GS, ETE, DST, and many others would get higher importance IMO before clock time. "Permanent Clock display" I believe means its not adequate that we can turn to the satellite page and see exact Z time, but I would love to see evidence of the contrary because in practical terms it seems sufficient enough to me.  

[201Mooniac]

2 hours ago, kortopates said:

The primary problem with a GPS clock is that for it to meet the requirements stated in the letter it must provide a permanent clock display:  

"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.

So unless GPS clock time is being displaying somewhere "permanently", the GPS clock isn't going to be meet the requirement. With only a few data fields to display on the main GPS screens, typically time is pretty far down on our list compared to the importance of fields like TRK, DTK, GS, ETE, DST, and many others would get higher importance IMO before clock time. "Permanent Clock display" I believe means its not adequate that we can turn to the satellite page and see exact Z time, but I would love to see evidence of the contrary because in practical terms it seems sufficient enough to me.  

I agree and I got a response once from Garmin (I think it was from Trek) that their devices (I asked about GTNs and G500 TXi) don't meet the IFR requirement for a clock.

[N201MKTurbo]

I love my old analog clock. It is the one with the stopwatch function. I start the timer when I take off. If the minute hand is on the right side of the clock I use the right tank. The left side of the clock I use the left tank.

I find them way easier for flying timed approaches and timed holding patterns. But then again since I went /G who does that? I just fly the magenta line.

[0TreeLemur]

My yoke has one of these.  The select button switches between Zulu, local time, and timer.  A bit retro but works.

 

Edited November 7, 2020 by 0TreeLemur
detail

[gsxrpilot]

4 hours ago, kortopates said:

The primary problem with a GPS clock is that for it to meet the requirements stated in the letter it must provide a permanent clock display:  

"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.

So unless GPS clock time is being displaying somewhere "permanently", the GPS clock isn't going to be meet the requirement. With only a few data fields to display on the main GPS screens, typically time is pretty far down on our list compared to the importance of fields like TRK, DTK, GS, ETE, DST, and many others would get higher importance IMO before clock time. "Permanent Clock display" I believe means its not adequate that we can turn to the satellite page and see exact Z time, but I would love to see evidence of the contrary because in practical terms it seems sufficient enough to me.  

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.

[EricJ]

3 hours ago, 201Mooniac said:

I agree and I got a response once from Garmin (I think it was from Trek) that their devices (I asked about GTNs and G500 TXi) don't meet the IFR requirement for a clock.

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.

 

[jlunseth]

1 hour 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.

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. 

Edited November 5, 2020 by jlunseth

[N201MKTurbo]

FWIW IMHO

You would have to really P O an FAA inspector before he would write you up for a clock violation.