"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 "Moonless Night Letter" from the FAA defines "actual instrument flight conditions" as situations where outside conditions necessitate flying solely by instruments to maintain adequate control of the aircraft, even if VFR visibility exists.
This definition of "actual instrument conditions" is distinct from "Instrument Meteorological Conditions" (IMC) and primarily refers to using instruments for "aviating" (maintaining aircraft attitude) rather than merely "navigating."
Logging actual instrument time in these subjective edge cases requires sound pilot judgment, with the recommendation to document reasons in the logbook to justify the decision if questioned.

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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.”