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Regulations

FAA Legal Interpretations

FAA attorneys have issued hundreds of formal legal interpretations on aviation regulations — and they're all publicly available. Here's how to use them.

By Parrish AviationOctober 16, 2024

The FAA has released many legal interpretations from their Office of the Chief Counsel to the public over the years. While the FAA has since revised the process and delegated responses to local FSDOs, the interpretations issued previously remain on the FAA's website and carry significant weight in regulatory compliance questions.

Where to Find Them

FAA Legal Interpretations Index:

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations

Categories and Topics

The interpretations cover a wide range of regulatory areas. Key categories include:

Instructor-Related

CFI renewal, authorized instructor endorsements, logging instruction time, acting as PIC while instructing.

Currency & Experience Requirements

Night landing currency, instrument currency, recent flight experience requirements under 14 CFR 61.57.

Airspace & Operations

Class A airspace entry, IFR operations, special use airspace, ATC clearance requirements.

Equipment & Maintenance

TBO compliance, airworthiness directives, inoperative equipment under 91.213, required inspections.

Flight Logging & Record-Keeping

PIC logging definitions, what constitutes flight time, logbook format requirements, endorsement records.

Medical & Certification

BasicMed requirements and limitations, medical certificate classes, special issuance procedures.

Regulations & Legal Matters

Statutory interpretation, enforcement procedures, deviation authority, pilot rights during investigations.

Miscellaneous

A variety of one-off regulatory questions that don't fit neatly into another category.

How to Use Legal Interpretations

When a regulation is ambiguous or has conflicting interpretations, an FAA legal interpretation can provide clarity. These documents are not rulemaking — they don't have the force of law — but they represent the FAA's official position on how a regulation applies to a specific set of facts.

The key caveat: an interpretation applies to the specific facts presented. If your situation differs in material ways, the interpretation may not directly apply. When in serious doubt about compliance, consult an aviation attorney or contact your local FSDO.

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