FAA Legal Interpretations Highlights
- Dan George
- Apr 25, 2023
- 1 min read
Updated: Aug 7, 2025
The FAA Office of General Counsel issues interpretations in response to requests for clarification of the Federal Aviation Regulations. These interpretations carry almost as much weight as the regs they reference, so pilots should become aware of them and how to research them. Here are some highlights which apply to us as general aviation pilots.
Ability to fly shorter than published leg lengths on some holding patterns
A pilot and their safety pilot cannot both log cross country flight time even though they are both logging PIC time while the pilot is flying in simulated instrument conditions.
A pilot who builds flight time while someone else pays for the aircraft may be receiving compensation.
A parachute is not required for spin training for a CFI initial applicant.
Confirms that Part 91 operations are not required to adhere to published takeoff minimums, even when being assigned and accepting a SID with specific minimums.
A pilot flying in Class E airspace, which is controlled airspace, is not required to communicate with ATC; however, if a pilot is communicating with ATC they must comply with any instructions issued.
Precision Approach Radar (PAR) can be considered an acceptable navigation system to meet the requirements on the IFR cross country flight in 61.65(d) to shoot "three different kinds of approaches with the use of navigation systems."