Jack wrote:

The third and final stage of defending against an FAA action would be to
appeal the matter to the Federal Circuit Court of Appeals, after an
unsuccessful Administrative Law Judge Hearing and a subsequent appeal to
the NTSB or DOT.

And that court will simply state that the FAA is the sole interpreter of its
rules and rule against you. Unless, of course, you can provide an example of a
case in which the FAA or NTSB ruled the other way.

George Patterson
Coffee is only a way of stealing time that should by rights belong to
your slightly older self.