Favorite "Letter of Interpretation" find(s)?
Posted by trying2lipad@reddit | flying | View on Reddit | 24 comments
This may be a weird/nerdy post, but do you have any FAA letter of legal interpretations that just stuck with you? Whether you found it cool or have since then used it for practical reasons.
As an overthinker, I always have a satisfying feeling when I stumble upon and learn from these (via /fying reddit lol). Especially since it helps ensure I got all bases covered. Anyway I'll start,
Examples:
- Requirements for 100hr inspections: Greenwood (2014) and Lowenstein (2016)
- Private Pilot Compensation incidental to business (second scenario): Mangiamele (2009)
My latest discovery was
- Safety Pilot no legal obligation to pay pro-rata share: Roberts (2012)
Thanks in advance!
Computerized-Cash@reddit
The one I use daily, Levy (2008)
cmmurf@reddit
Instructor can count approaches if conducted in actual conditions because they are considered to have been performed by the instructor as part of oversight responsibility.
SATSewerTube@reddit
All of the Kidd LOIs 🤮
TheAntiRAFO@reddit
I can’t find it, but it was a DPE who complained bc someone said they can’t call themselves “representatives of the FAA”. The LOI basically is a very polite letter to the DPE saying that he is NOT, in fact, a representative of the FAA
jet-setting@reddit
Just FYI this page is in the FAQ.
A collection of FAA legal interpretations and what they address
But one I found super interesting is the Fitzpatrick (Spartan College) 2018 interpretation. Spin training CAN be offered to anyone without parachutes, not just CFI applicants.
trying2lipad@reddit (OP)
Thanks!
Time to annoy my instructors for some spin training haha.
PhilRubdiez@reddit
It was like my fifth or sixth lesson in college. My instructor asked if I had my morning coffee, because this would wake me up better. Even better is if you can find upset recovery training in an aerobatic plane.
cmmurf@reddit
What about additional spin training AFTER having received this endorsement?
jet-setting@reddit
Refresher training? Good question but I’d say it’s fine. Nothing wrong with doing more go around training after you give a solo endorsement and already performed 61.87(d)15.
Not sure if thats the correct way to think about it, but it seems to be in line with the intention of that LOI.
cmmurf@reddit
What? No, spin training.
jet-setting@reddit
Oh I know.
I was just using it as a very simplified example of another maneuver. The actual LOA is pretty clear I think.
Referencing this line in the LOA
flyboy7700@reddit
We’re not required to have a PIC. (Gebhart, 2009)
Jorfogit@reddit
Walker (2011) by a long shot. Game changer if you’re still working on your instrument or know someone who is.
johnisom@reddit
link?
Jorfogit@reddit
It’s in the wiki, but here it is!
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2011/Walker_2011_Legal_Interpretation.pdf
trying2lipad@reddit (OP)
Very helpful to keep this in mind while time-building in instrument training. Thank you!
ItsColdInHere@reddit
Any Canadians know if there is something similar for Canada?
cmmurf@reddit
Officially ACs aren’t regulatory, they even say so. But in an AMA this sub did a few years ago with an aviation attorney, in practice the FAA behaves (argues with lawyers and administrative judges) as if everything FAA says or writes is regulatory.
Chief legal council letters give a window into the opinion of that particular branch of the FAA. Whereas ACs give a window into the opinion of the authoring office. I don’t know if FAA legal reviews some/all ACs.
There are still corner cases though. A big one in my opinion that makes me rather dour, is AC 90-66C, Non-Towered Airport Flight Operations vs FAA approved OpSpecs. It’s (apparently) common in OpSpecs that pilots are required to use final leg pattern entry. Whereas AC 90-66C explicitly recommends against this. The contradiction is annoying. But the lack of mentioning in the AC that OpSpecs can require this means as a community we aren’t aware of this conflict and hazard.
fatmanyolo@reddit
LOIs are the FAA legal counsel’s interpretation of a regulation. They help to answer specific questions of legality when the regulation is a bit ambiguous.
CluelessPilot1971@reddit
Your Roberts link is identical to your Mangiamele link - here's the correct Roberts link.
trying2lipad@reddit (OP)
Whoops. Edited, thanks!
poisonandtheremedy@reddit
The Coleal Interpretation is game changing for aircraft owners.
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Coleal-Bombardier%20Learjet_2009_Legal_Interpretation.pdf
trying2lipad@reddit (OP)
Interesting distinction between preventative maintenance and pre-flight inspection
rFlyingTower@reddit
This is a copy of the original post body for posterity:
This may be a weird/nerdy post, but do you have any FAA letter of legal interpretations that just stuck with you? Whether you found it cool or have since then used it for practical reasons.
As an overthinker, I always have a satisfying feeling when I stumble upon and learn from these (via /fying reddit lol). Especially since it helps ensure I got all bases covered. Anyway I'll start,
Examples:
- Requirements for 100hr inspections: Greenwood (2014) and Lowenstein (2016)
- Private Pilot Compensation incidental to business (second scenario): Mangiamele (2009)
My latest discovery was
- Safety Pilot no legal obligation to pay pro-rata share: Roberts (2012)
Thanks in advance!
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