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Logging Actual IMC Requires More Than Clouds

From a moonless night to flying into a blinding sun, are you correctly logging 'actual' conditions?

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Gemini Sparkle

Key Takeaways:

  • The FAA's "Moonless Night Letter" allows pilots to log "actual instrument flight conditions" when outside circumstances, like a moonless night or blinding sun, *necessitate* instrument use for aircraft control, even if visual flight rules (VFR) technically apply.
  • "Actual" instrument conditions are distinct from "simulated" (intentional vision restriction) and "instrument meteorological conditions" (IMC), focusing on the need for instruments to maintain adequate aircraft control (aviating) rather than just navigation.
  • Logging instrument time or approaches in such subjective VFR scenarios relies heavily on pilot judgment, with the expectation that the pilot can justify why instrument reliance was essential for safe control of the aircraft.
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It has long been said that the private pilot certificate is a “license to learn” as it is the foundation of a person’s flying career.

The FAA has said we may log an instrument approach if we are in actual or simulated conditions inside the final approach fix [Ref:§ 61.51(g)(3) and §61.57(c)]. But think about whether you were in actual IMC or not. As one example, you’re on a straight-in visual on a clear evening with the setting sun directly in your eyes, making any visual references in front of the aircraft useless. Although there’s not a cloud in the sky, you loaded the precision approach for belt-and-suspender situational awareness. That was a good call because the early evening sun is blinding any attempt to look out the window. You transition to the instruments and fly the approach, intercepting the GPS glide slope and keeping the VDI centered. Sun visors down, you finally see the runway and land. Was that loggable?

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