"T o d d P a t t i s t" wrote in message
...
I looked through my electronic files, but I haven't found it
yet. I would have posted it if I had. The Chief Counsel's
Office has a searchable database of interpretations, but
only the FAA is allowed to use it. We had a retired FAA
official here who snarfed a copy and he posted the interp
about 2 years ago. Otherwise we wouldn't know about it,
unless the original paper letter recipient posted it.

I have no reason to doubt the existence of that letter, but I've long since
decided that I refuse to consider myself bound by "interpretations" that
actually blatantly contradict the FARs, and that are unavailable except as
Internet rumors. If I ever have to defend that stance in court, so be it.
(In this case, of course, the unpublished "interpretation" is actually more
*lenient* than what the FARs actually say.)

--Gary