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.
|Category||Question||Link + Notes|
|IFR||What is "known ice"?||Bell (2009)|
|IFR||Can you circle to the right at an airport with a standard traffic pattern?||Murphy (2009)|
|IFR||Can you shorten the leg length of a holding pattern below the distance specified on the chart?||Young (2011) - 5th question|
|CFI||Can a CFII (without MEI, but with commercial multi) instruct in a multi-engine aircraft?||Grayson (2010)|
|CFI||Does 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 time||Is it possible to log PIC time in a high-performance or complex aircraft before you have those endorsements?||Herman (2009)|
|Flight time||Is flight time considered compensation? (This could be an issue for private pilots)||Lincoln (1990)|
|Flight time||What 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)|
|ATC||If center fails to hand you off to a class C TRACON, are you responsible to avoid entering class C airspace?||Granby (2006)|
|Aircraft||Can you operate with an inoperative beacon, assuming you still have operative white strobe lights?||Letts (2017)|
|Min altitudes||How 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