>>>SNIP>>Keep in mind Advisory Circulars are NOT regulatory.They are only
advisory as their name implies. I have been trying to download the referenced
FAA Order 8130.2, but find it to be unavailable at this time.<<SNIP<<


Sounds like a good argument for the NTSB Administrative Law Judge-- hmmmm I
wonder if anyone has used that argument in an enforcement before AND WON???

Jeff Edwards