"Actual" Conditions

Youre on a straight-in visual. Although theres not a cloud in the sky, you loaded the ILS for situational awareness. Its early evening and the sun is blinding any attempt to look out the window. You transition to the gauges and fly the approach, intercepting the glideslope and keeping the crosshairs centered. You finally see the runway and land. The FAA has said we may log an instrument approach if we are in actual or simulated conditions inside the final approach fix. Were you?

Editorial Staff

Saturday, November 11, 2017 at 12:00 AM ET

Verified

Key Takeaways:

The FAA's "Moonless Night Letter" allows pilots to log "actual instrument flight time" when outside conditions, such as a moonless night without a discernible horizon or blinding sun glare, necessitate using instruments to maintain *adequate aircraft control* (aviating), even if visual flight rules (VFR) conditions technically exist.
This interpretation distinguishes "actual instrument conditions" from Instrument Meteorological Conditions (IMC), emphasizing the requirement to use instruments primarily for maintaining aircraft attitude, not merely for navigation.
Logging actual instrument time or approaches under these subjective conditions is a judgment call for the pilot, who must be prepared to justify their decision and document the specific reasons in their logbook.

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You’re on a straight-in visual. Although there’s not a cloud in the sky, you loaded the ILS for situational awareness. It’s early evening and the sun is blinding any attempt to look out the window. You transition to the gauges and fly the approach, intercepting the glideslope and keeping the crosshairs centered. You finally see the runway and land. The FAA has said we may log an instrument approach if we are in actual or simulated conditions inside the final approach fix. Were you?

The “Moonless Night” Letter

In 1984, Joseph Carr asked FAA Legal some questions about logging instrument flight time. One was whether “a flight over the ocean on a moonless night without a discernible horizon could be logged as actual instrument flight time” even if the conditions qualify for VFR flight. The result was a formal legal interpretation by the FAA Chief Counsel, commonly called the “Moonless Night Letter.”