midlifeflyer
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Well, on the other hand, the FAQ has been found to be wrong more than once, was removed by the FAA, and people told not to cite it. (That doesn't mean it was wrong on this one, just that it's dangerous to cite it fir much of anything other than an indication of how the FAA =might= approach an issue.)
Source is John Lynch while it isn't a legal interpretation it is an interpretation by the guy who helped write the rules so would consider it sound.