A focused interpretation of FAA Gordon (2006) on whether instrument training time and PIC cross-country time may be credited concurrently toward an instrument rating.
Answer: The FAA interprets that the aeronautical experience requirements of §61.65(d)(1) and §61.65(d)(2) may be accumulated concurrently, provided each flight independently satisfies the requirements of both provisions.
Can instrument training time also count as cross-country PIC?Can I log instrument training and cross-country time on the same flight?
A practical interpretation of FAA legal opinion on how private pilot instrument training applies toward instrument rating requirements.
Answer: Private pilot instrument training can count toward total instrument time, but cannot count toward required instrument instruction hours unless given by a qualified CFII.
Does private pilot instrument training count toward the instrument rating?Can previous instrument training be credited toward an instrument rating?
A structured reading of FAA Murphy (2008) addressing multiple independent regulatory questions without collapsing them into a single rule.
Answer: This LOI addresses multiple independent issues. Each conclusion applies only to its specific regulatory context and should not be generalized into a unified rule.
If I lost my medical can I log PIC?Can a CFI instruct without a medical?
A practical interpretation of FAA legal opinion on whether newly certified ground instructors must meet recent experience requirements before instructing.
Answer: A newly certified ground instructor cannot instruct immediately unless they meet the recent experience requirements of §61.217.
Does a new BGI need recent experience before teaching?Can a newly certified ground instructor provide ground training?
A practical interpretation of FAA legal opinion on when parachutes are required during spin training under §91.307.
Answer: Parachutes are not required for spin training when conducted by a certificated flight instructor, even if the training is not required for the specific certificate being pursued.
Do I need a parachute for spin training?When are parachutes required during spins?
A practical interpretation of FAA legal opinion on the meaning of 'required crewmember seat' and its regulatory implications.
Answer: The definition of “required crewmember seat” depends on interpretation, and creates a regulatory tension between Part 61 and Part 142 medical requirements.
Who is a required crewmember?Does an instructor count as a required crewmember?
