[pa42]

My FSDO is too understaffed to return phone calls, and local DPE's consulted give differing interpretations of regs, so I'm wondering if there is a master source of FAQ's or fine interpretations of the meaning of words in the FAR's.

Immediate-concern examples:

1. aircraft equipment requirements for logging the 10 hrs IR time for the Commercial certificate. The reg says "instruments" but does not say "IFR certified." Thus, I contend, an old aircraft with ONLY a TI/TC (and airspeed, altimeter, mag compass), which can thus be flown solely by reference to the instruments without outside reference, should be legal. Not the greatest, but acceptable. A local examiner says no, there must be an AI and airway-capable navigation (VOR/GPS). ??? how did those get into the mix??? Where do I go to enable my student to take the practical test with training that meets the regulation but not the examiner's invention?

2. Commercial pilot pre-requisites include holding a Private Certificate (61.123), I accept that. I take it to mean IN ANY CATEGORY, a Private Certificate is a Private Certificate, regardless. But now (when did it change?) the Helicopter Commercial PTS says very clearly that the (civilian) applicant must hold a Private HELICOPTER Certificate. ??? That's not in the regs, 61.123 doesn't specify what category the certificate must itemize, is this a carelessly-phrased PTS (perish the thought!), or is there some way of interpreting 61.123 to mean "in the same category?" (It does say "under this part," which, if one does not live in Oklahoma City, might mean under CFR 49, or FAR 61, or FAR 61.123, or variations on that, but that sort of second-guessing gets very difficult.) Help?

In short, where, at the national level, do we go to figure out where the fine lines in the regulation are drawn? Have these questions already been answered somewhere?

Why do I care? I'm the Chief Instructor, my guys expect me to KNOW these things. And to walk on water (I never should have let them watch the last time I did that . . .)