Although FAR 61.57 stipulates the factual number of approaches needed to keep an FAA IR current,
in actual weather conditions, or under simulated conditions using a view-limiting device that involves having performed the following—
i. Six instrument approaches.
ii. Holding procedures and tasks.
iii. Intercepting and tracking courses through the use of navigational electronic systems.
I find it extraordinary that the terminology “actual weather conditions” or "actual instrument conditions” is not defined anywhere in the regulations some 20 years after the words crept into the FARs. This is especially astonishing as there must be hundreds of FAA IR pilots each year who are renewing their IR who would clearly like to know!
Only last week, on the private US AOPA forum, CFIs and pilots were continuing to argue as to what is actually meant by the words.
One has therefore, bizarrely, to rely on rather obscure and obtuse references in the past for an answer like: Flight training magazine in 2001 or the often quoted Murphy letter .
In a 1998 article “Is currency any easier?” the author of rule 61.57, FAA official John D. Lynch gives his own answer. Within the article there is reference to his own web page where he answered many queries at the time; but this is no longer on line (because he has retired?).
I remember when I first read it I made some notes because he specifically referred to the mandate that he had been given “to make IR currency renewal simpler and easier”.
It also included his definition: ”Simply ask yourself, whether between the initial approach fix and the missed approach point, did you or did you not go through a cloud or conditions without a visible horizon? If so, it can be logged as an approach under 61.57.”
He also made great emphasis – quite rightly – that there is a major difference from “being current” and “being proficient”, and sensible IR pilots never confuse the two.
John Lynch FAQ carry no weight at all. Only the FAA Chief counsel is entitled to interpret FAA regulations for the FAA other than by a court ruling.
Actual instrument conditions verses simulated instrument conditions relates to whether or not the conditions prevent visual control of the aircraft or not. If the aircraft may not be controlled by visual means then it must be controlled solely by reference to the instruments. In visual conditions, an artificial means by using a view blocking device (a hood) is employed to create simulated instrument conditions. On a moonless night in a sparsely populated area making an approach over the water might have great visibility but be actual instrument conditions. IOW it is not VMC/IMC or VFR/IFR that determines actual instrument conditions verses simulated instrument conditions, it is whether or not the pilot must use the instruments or not for complete control of the aircraft. The wording in the Chief Counsel’s opinion is vague as is often the case. The sentence beginning at “Further …” can be read to mean that the procedure must be flown to the MDA or DA and not that the entire approach needs to be conducted in actual instrument conditions. I log the approach if any portion of the procedure is actual instrument conditions and the procedure is flown to the DA/MDA. Some pilots, log it if the conditions are IMC, I don’t as IMC merely means that they were below VMC which could be just cloud separation criteria or under visibility below 3 SM..
In this case I’m actually very happy with the EASA regs. The only thing that matters is IFR time.
If anyone can unravel what this is actually saying…
On my reading, it doesn’t clarify anything as to what weather is required to be present. It does seem to say that you cannot log the approach in CAVOK conditions 
But nobody I know does that anyway.
I think this point is rather clear.
When conducted in an aircraft maneuvering in IMC, and the aircraft transitions from IMC to visual flight conditions on the final approach segment of the IAP prior to or upon reaching MDA or DA/DH.
So: the aircraft must be IMC at the FAF.
For the rest, I don’t like that circular. FAA guidance is usually known to be concise and short. This is long and convoluted. It raises more questions than it answers.
Bosco – that’s not how I read it. Final approach segment is not necessarily the same as FAF or FAP, although I’m sure that’s what they perhaps are trying to allude to. Jeppesens definition: That segment of an instrument approach procedure in which alignment and descent for landing are accomplished. Wordings matter and to me that’s pretty much anywhere after the IAP or IF as long as a descent is part of the printed approach.
In reality, pilots log what they need just like they’ve always done. I say this as someone who’s just done 6 approaches and holds in the simulator, just to be on the sure/safe side.
How is this done in Europe?
I’m not aware of such a requirement (to be in IMC) in Australia. You can get current flying an instrument approach in VMC.
The European IR doesn’t have any rolling currency requirements at all. You just have to pass a prof check every year to renew the rating.
