Narrative:

I was flying with an INS student conducting hood work. When it was time to return back to our home airport (pao), it became evident that we needed to conduct an INS approach. I contacted bay approach and reported over the delval reservoir requesting the localizer DME into hwd. I was given vectors to the approach and to maintain VFR. I explained to the controller that I would be unable to maintain VFR, and that, 'I was in and out of the clouds right now.' later, in discussing this with other instructors, I realized that there may very well be a problem with this situation. At the time I entered the clouds, upon receipt of the vector, I was of the belief that I was on an IFR flight plan. It is now apparent to me that I may not have been on an IFR flight plan, since he told me to maintain VFR. (None of this seemed to both the controller--he didn't say anything about this situation.) it is very easy to misinterp what clearance you have received (IFR clearance or VFR), because the controller does not tel you. There are no clear-cut guidelines to provide the pilot from VFR to IFR conditions for the purpose in shooting an approach to the airport you are landing at to what kind of flight plan you are on in these conditions (VFR conditions to IFR conditions).

Google
 

Original NASA ASRS Text

Title: INSTRUCTOR WITH INS STUDENT REQUESTS IFR FLT PLAN FOR LOCALIZER DME APCH. TOLD TO REMAIN VFR. ALREADY IN AND OUT OF CLOUDS.

Narrative: I WAS FLYING WITH AN INS STUDENT CONDUCTING HOOD WORK. WHEN IT WAS TIME TO RETURN BACK TO OUR HOME ARPT (PAO), IT BECAME EVIDENT THAT WE NEEDED TO CONDUCT AN INS APCH. I CONTACTED BAY APCH AND RPTED OVER THE DELVAL RESERVOIR REQUESTING THE LOC DME INTO HWD. I WAS GIVEN VECTORS TO THE APCH AND TO MAINTAIN VFR. I EXPLAINED TO THE CTLR THAT I WOULD BE UNABLE TO MAINTAIN VFR, AND THAT, 'I WAS IN AND OUT OF THE CLOUDS RIGHT NOW.' LATER, IN DISCUSSING THIS WITH OTHER INSTRUCTORS, I REALIZED THAT THERE MAY VERY WELL BE A PROB WITH THIS SITUATION. AT THE TIME I ENTERED THE CLOUDS, UPON RECEIPT OF THE VECTOR, I WAS OF THE BELIEF THAT I WAS ON AN IFR FLT PLAN. IT IS NOW APPARENT TO ME THAT I MAY NOT HAVE BEEN ON AN IFR FLT PLAN, SINCE HE TOLD ME TO MAINTAIN VFR. (NONE OF THIS SEEMED TO BOTH THE CTLR--HE DIDN'T SAY ANYTHING ABOUT THIS SITUATION.) IT IS VERY EASY TO MISINTERP WHAT CLRNC YOU HAVE RECEIVED (IFR CLRNC OR VFR), BECAUSE THE CTLR DOES NOT TEL YOU. THERE ARE NO CLEAR-CUT GUIDELINES TO PROVIDE THE PLT FROM VFR TO IFR CONDITIONS FOR THE PURPOSE IN SHOOTING AN APCH TO THE ARPT YOU ARE LNDG AT TO WHAT KIND OF FLT PLAN YOU ARE ON IN THESE CONDITIONS (VFR CONDITIONS TO IFR CONDITIONS).

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.