When the FAA legal division gives someone an "interpretation of a reg" because a question was asked because the FAR's are not clear.....its the LAW. Just like when I got an interpretation from the Florida Department of Law Enforcement asking a very "grey" question about carrying a concealed weapon in certain places....they answer it in simple terms so there's no confusion.
We got that back from them as a LEGAL way to log time. We asked it that way and they confirmed it to be legal. DE's agreed with their interpretation. We didn't just wake up one day and make our own regs. Don't be so stupid man.
From your disjointed manner of speech, you come across as a young, inexperienced pretender with very poor communication skills.
You are, of course, referring to the FAA Chief Legal Counsel letters of interpretation...which are decidedly NOT law, any more than the regulation is law.
United States Code is law. The Code of Federal Regulations, of which Title 14 pertains to aviation, is regulation, not law. Letters of interpretation regarding that regulation are not law either, but represent the official position of the FAA Administrator, and are therefore legally defensible in administrative law. However, they are not the be-all and end all when considering the regulation.
The letters of interp at the regional level are equally binding, but superceded by those issued at the national level by the Chief Legal Counsel's office.
In order of precedence, when considering the regulation, one looks to four sources. The first, of course, is the regulation itself. The other three regard the application of the regulation, and in order these are the Federal Register Preambles dealing with that specific regulation, Chief Legal Counsel Letters of Interpretation, and then applicable "case law" and precedence.
You claim to have received such interpretation. Why don't you post the letter to show this to be the case.
The scenarios you've cited are nebulous at best, and highly suspect. I very much doubt they will withstand scrutiny, but if you have evidence to the contrary in the form of a letter of interpretation, then by all means post it in order for us to see. You claim to have received such; let's have a look.
As far as a Designated Pilot Examiner's opinion; it has no value nor bearing in support of the regulation beyond private opinion, and cannot be considered when discussing matters of regulation. It's not defensible, and offers no basis of interpretation past pure conjecture, any more than the authority granted an inspector at the FSDO level (who also lacks the authority to interpret the regulation, incidentally).
Fugged up things about pilots which makes me sick.....if YOU don't know it for sure, or YOU didn't come up with the idea, or YOU weren't the one who brought it everyones attention.....whoever did is just wrong! Stop perpetuating why pilots are disliked.
And about your bullsh1t and others saying....I wouldn't fly with you. Thats the dumbest crap to ever come out fo someones mouth, you will never know who these thousands of pilots are, and you can bet your azz you've flown with many creative pilots before, and you will again. Probably all of which will fly circles around you, including me. So live with it.
The above quote is how a 14 year old talks. How would you present yourself if you wished to sound like an adult?
Its being done everywhere.
No, not everywhere. Not even close. You claim to have a letter of interpretation specifically citing it as an acceptable and approved practice. Prove it by posting the letter. Then cite ten locations where it's being done as a matter of practice. As you state it's done everywhere, this shouldn't present a problem for you.
