where to go for hair-splitting FAR interpretations?

[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 . . .)

[Denny of Oakland]

I just happen to have a copy of Frequently Asked Questions 14 CFR, PART 61 Arranged by Section in a word document I would be will to e-mail you. It’s the next best thing without going to the FSDO. I am pretty sure the FSDO isn’t too busy to answer your questions it our job.

I you want to contact me through my personal web site just click on the hyper link to me e-mail and I can send you the document as an attachment. You will find I am pretty user friendly. Welcome to StacheAir

[pa42]

The 2003 version of FAR 61 FAQ reveals the following surprising interpretation:

"Situation 2: A person is undergoing training for an additional helicopter category and class rating at the commercial pilot certification level. The helicopter the person will be receiving training in is a non‑IFR certified Robinson R‑22.

"Question. What are the minimum flight instruments and equipment requirements for this Robinson R‑22 that are used for the instrument training for the add‑on helicopter category and class rating at the commercial pilot certification level that is addressed in § 61.129(c)(3)(i)? Meaning the kind of instrument training where it does not require the filing of an IFR flight plan and flight is going to occur during daytime conditions.

"Answer: Ref. § 61.129(c)(3)(i)and § 91.205(b); The instruments and equipment for the kind of instrument training required for § 61.129(c)(3)(i) during daytime conditions may be as minimal as the instruments requirements of § 91.205(b) with a portable communication receiver, and a portable VOR navigation receiver or some other kind of navigation receiver in the aircraft. As an example, if the training was given in a helicopter, the instrument and equipment requirements may be as a minimum: an airspeed indicator, altimeter, magnetic compass, a portable communication receiver, and a portable navigation receiver.

{Q&A-170e}"

. . . but now I find that the above puzzles me: how are they going to keep the helicopter right side up if they don't have even a TI/
TC for a gyro? Ah, well, perhaps supernatural aid. Whatever--I think we'll probably keep TI/TC's functioning in the instrument panel!