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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" clarifies that "actual instrument flight conditions" can exist even in VFR weather, distinguishing them from Instrument Meteorological Conditions (IMC) when instruments are necessary for aircraft control.
  • "Actual instrument flight conditions" arise when external factors, such as a moonless night over the ocean or a blinding sun, require a pilot to use instruments for maintaining adequate control (aviating), rather than solely for navigation.
  • Determining if conditions necessitate logging actual instrument time is subjective and relies on the pilot's judgment, who should be prepared to justify the necessity of instrument reference for aircraft control.
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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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