While many of the regulations that govern our actions are clear, there are a large number that may seem vague or even leave room for unintended interpretations. For these reasons, it is possible to seek official and binding interpretations from FAAs legal department, either through a direct request or possibly more onerous encounters with the regulations.
FAA legal interpretations clarify complex regulations (e.g., fuel, approaches, lost communications), consistently emphasizing the pilot's ultimate responsibility for safe operation.
Under 91.167 (Fuel Requirements), pilots must plan for an approach, a missed approach, diversion to an alternate, and a 45-minute reserve, with actual, verifiable fuel consumption data being critical.
For 91.175 (Takeoff and Landing), pilots are solely responsible for meeting weather minimums and full approach procedures, even when cleared by ATC, but can descend below RVR if cockpit "flight visibility" and other conditions are met.
In a 91.185 (Communications Failure) scenario, the regulation supersedes STARs; pilots must hold at the approach fix until their estimated time of arrival if arriving early and no Expected Further Clearance (EFC) time was given.
While many of the regulations that govern our actions are clear, there are a large number that may seem vague or even leave room for unintended interpretations. For these reasons, it is possible to seek official and binding interpretations from FAA’s legal department, either through a direct request or possibly more onerous encounters with the regulations.
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