You are expecting far more from the writers of statutes, rules and regulations than they are probably capable of. That's not a slam on them, but just reality. That's why court cases, even if they have precedential value, are ultimately tied to the specific facts presented in them.
Real laws reviewed by real courts will give the strongest preference to the actual literal text of the statue barring any ambiguity or constitutional principles. The FAA just pulls contradictory assertions out of the legal counsel's posterior without any regard to due process, rules of statuary construction, etc....
While I have disagreed with many, I'm sometimes surprised by the exact opposite of your observation — the number of times the FAA folks do a pretty good job. I'd expect agency-level interpretation to be worse.
Some do not understand the definition of recommended vs required either. Many a forum thread has gone 200 replies over that one.
Go ahead and update the PIC column hours in your logbook. Many have.
Being rated is only one of many requirements to be qualified to act as PIC. They are not synonymous at all.
Hi Mark.
Not arguing with Chief Counsel's interpretation, DTDT.
But if you really are interested in learning, and understanding the confusion on this matter, I refer you to Webster's dictionary definition of the word, ""rating" :
((one of them) : "The designation of the operating capacity of a piece of machinery, as expressed in horsepower, kilowatt, etc."
With this common understanding of the definition, it is reasonable to understand that most people would take the meaning of "Rated" to mean qualified to act as PIC.
And, it is reasonable to expect that logging PIC and acting as PIC are one in the same.
The fact that the CC has endorsed the special definition that is outside of the normal definition is why so many of us are outside the loop,..
...in the words of the Great Teacher, "Forgive them, for they know not what they do."
I think I'm a little familiar with the dictionary. But so what?Hi Mark.
Not arguing with Chief Counsel's interpretation, DTDT.
But if you really are interested in learning, and understanding the confusion on this matter, I refer you to Webster's dictionary definition of the word, ""rating" :
or they tested on any of the pilot or instructor checkrides.They are supposed to be tested on the practical test. In fact, that's the very first element in the PP-Airplane PTS -- Area I, Task A, element 1. So, you can't blame this on the FAA -- just CFI's who aren't covering all the things they are supposed to cover, and DPE's who don't test all the things they are supposed to test.The CC aviation specific interpretations in these matters of logging time are not really trained in the mainline training schools, nor
If they were addressed on checkrides, it wouldn't be such an issue, would it?
CFIs could teach differences in acting and logging like differences in actual stalls and approaches to stalls, or some such.
My point is, that CC interps in these time logging matters are not tested, so they are not taught/learned in training.
They are learned by experience from people like u and me.
When it comes to this particular logging rule, 14 CFR 61.51 is the relevant regulation, and that Part is referenced.
I agree even if nosehair doesn't seem to. The problem here is getting the word out so everyone understands the FAA rules about what they require vis a vis your pilot logbook kept to meet the requirements of 14 CFR 61.51, no matter what some possible future employer might want to know about your flying experience some years down the pike.
By that standard, one would have to also include Webster's Dictionary to tell us what the meaning of "is" is.
You mean like "maneuverability" and "stall"? How about "incident," "accident" and "substantial damage"?
By what "commonly accepted meanings of words" does "rated" mean "having a 61.31 additional training endorsement"? You've pulled one version of the definition of the term "rating" out of the dictionary, but ignored the fact that 14 CFR 61.5 clearly states what "ratings" there are, and complex, HP, TW, etc., are not among them.
No Ghery, it was at KTIW. I normally rent DA40's out at BFI, but their complex is getting an overhaul so I went to TIW to knock out my complex time for my commercial..I was going to fly at OLM as its closer to me, but TIW just happened to work out..still have to go back and update my logbook for the PIC time..
