"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" interprets regulations to allow logging "actual instrument flight time" when outside conditions necessitate using aircraft instruments to maintain adequate control, even if visual flight rules (VFR) conditions technically prevail.
This determination is subjective and relies on pilot judgment, focusing on the need to *aviate* (maintain aircraft attitude) by reference to instruments rather than solely *navigate*.
Scenarios like moonless nights over the ocean, "black hole" approaches, or flying into a blinding sun are discussed as potential instances, requiring pilots to justify their decision to log actual instrument time.

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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.”