Toeing the Line: The Second Byrne Letter

Following is the complete text of the April 27, 2000, letter from FAA Assistant Chief Counsel, Regulations Division, Donald P. Byrne to Rob Hackman at AOPA. According to FAA spokesman Eliot Brenner, this letter supercedes both the Barton letter/Alkalay memorandum as they apply to FAR 91.109 as well as Mr. Byrne's own previous letter. Also, the letter below applies to any operation conducted under FAR 91.109, not just those within territory covered by the RIC FSDO or within the FAA's eastern region.  As referenced in the AVweb article "Toeing the Line: An FSDO Changes the Definition of 'Dual Controls'."

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