The FAA has taken the unusual step of issuing a change to part 61 without the normal comment period. Effective November 15 the so called 'Levy Interpretation' issued by the notorious FAA Chief Counsel's office is overturned. The new change to part 61 Aviation Week Change to part 61 It only took five years for this change to happen. What needs to happen now is: 1) The FAA needs to start charging people for chief counsel opinions, based on the number of hours the counsel requires to research and answer the question. 2) Chief Counsel opinions should be issued as drafts with a comment period. In order to be come official the Administrator should be required to review the comments and then either approve or disapprove the interpretation.