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Old October 15th 04, 06:36 PM
Ron Natalie
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zatatime wrote:
On Fri, 15 Oct 2004 11:36:43 -0400, Todd Pattist
wrote:


I note that Mr. Lynch's comments are not definitive and he's
been wrong before




How can the guy who wrote 61 be wrong about the interpretation of 61?

Because first, much of Part 61 predates Mr. Lynch's meddling with it.
Second, the rules were NOT enacted as he wrote them but substantially
revised during the rulemaking process. Third, his opinion bears no
offical weight. To get an official opinion you need a decision from
the FAA Legal Counsel's office (which has rightfully disagreed with the
FAQ). Even ALJ decisions don't form a precedent in the morass which
is the FAA enforcement system. The NTSB appeals do, but the FAA still
tries to ignore them.