Confusing FAA regulations clarified

Confusing FAA regulations clarified

FAA regulations can sometimes be confusing.  While many people would like regulations to spell out each situation in perfect black and white, often times there are situations which make you scratch your head and ask, “is this actually legal?”.

This is why the FAA allows you to write to them with a request to interpret their regulations for any scenario, which results in them issuing you a “Letter of Interpretation”.  These help clarify regulations that might otherwise be confusing, or cause hours of debate between pilots with different readings of the regulations.

Here is a compilation of some of the FAA Letters of Interpretation that you might find useful as a pilot:

Note: New Letters of Interpretation can be found here.

CategoryQuestionLink + Notes
IFRWhat is "known ice"?Bell (2009)
IFRCan you circle to the right at an airport with a standard traffic pattern?Murphy (2009)
IFRCan you shorten the leg length of a holding pattern below the distance specified on the chart?Young (2011) - 5th question
CFICan a CFII (without MEI, but with commercial multi) instruct in a multi-engine aircraft?Grayson (2010)
CFIDoes a CFI need to be night current in order to instruct?Kortokrax (2006) - applies to CFI instructing rated pilot

Olshock (2007) - applies to CFI instructing student pilot
Flight timeIs it possible to log PIC time in a high-performance or complex aircraft before you have those endorsements?Herman (2009)
Flight timeIs flight time considered compensation? (This could be an issue for private pilots)Lincoln (1990)
Flight timeWhat counts as a cross country? Is it okay if the individual legs of a cross-country flight are less than 50 nautical miles?Sisk (2008)
ATCIf center fails to hand you off to a class C TRACON, are you responsible to avoid entering class C airspace?Granby (2006)
AircraftCan you operate with an inoperative beacon, assuming you still have operative white strobe lights?Letts (2017)
Min altitudesHow does the FAA determine what constitutes a congested area? (91.119)Anderson (2009)

Want to request your own letter of interpretation?

Write a letter to the Office of The Chief Counsel.

Office of the Chief Counsel
800 Independence Avenue SW
Washington, DC 20591

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