Legal Interpretations

FAA Legal Interpretations and Opinions

Overview

Like most laws and rules, it is not always clear how the FARs (typically Part 61 and Part 91) apply in particular situations; there is often a lack or detail or clarity. One of the best sources of guidance in such cases are the Legal Interpretations & Chief Counsel's Opinions of the FAA's Regulations Division. Wadding through all of the interpretations over the years would be a significant task. Instead, I highlight some of the more common and relevant interpretations and opinions below. If you know of others that you have found useful please let me know via email. And please make sure to include a link to the relevant letter so that I may add it to the list below. Thank you.

References

• • FAA's Regulations Division

  • Legal Interpretations & Chief Counsel's Opinions

Of interest to all pilots

• • Anticollision lights - Beacon vs Strobes — Daniel Murphy Letter

  • Logging cross-country flight time and flights vs legs — Dwight Zanen Letter

  • Passenger-carrying flights for the benefit of a charitable, nonprofit, or community event — Guy Mangiamele Letter

  • Sharing Aircraft Operating Expenses - FAA Advisory Circular 61-142

  • Reimbursement for flight expenses — Guy Mangiamele Letter

  • Flight Sharing / Air Charter Operations (think Blackbird, Air Pooler, FlyteNow, etc.) (root FAA web page for such information)

    • Important charter guidance for pilots and passengers

    • FAA letter discussing applicable flight sharing regulations

    • FAA legal interpretation on peer-to-peer flight sharing

    • U.S. Court of Appeals decision on FAA's flight-sharing interpretation

Of interest to instrument pilots

• • Counting your flight by reference to instruments time from your private pilot training towards your instrument rating — Scott Rohlfing Letter - Yes, you can count your PPL hood time towards your instrument rating!

  • Operation of an aircraft below decision altitude (DA) or minimum descent altitude (MDA) — Gary B. Thomey Letter

  • Known icing conditions — Leisha Bell, AOPA

Of interest to commercial pilots

• • Aeronautical experience for a commercial pilot certificate — Daniel Murphy Letter