ALLEGED FAR VIOLATION.

Narrative

PRIOR TO ENTERING REYKJAVIK OCEANIC CTA; I WAS ASKED IF I WAS QUALIFIED IN MNPS -- BEING TRAINED AT ACR A. IN MNPS PROCS; I RESPONDED IN THE AFFIRMATIVE (WE WERE AT FL310). ASSUMING THAT I HAD MET ALL THE REQUIREMENTS AND WAS ALLOWED TO CONTINUE AT FL310 ON A SPACE AVAILABLE BASIS IN THE MNPS AREA; I CONTINUED TO BIKF AT FL310. BECAUSE OF STRONGER THAN PREDICTED WINDS AT LOWER ALTS; I REQUESTED FL310 FROM BIKF TO CYYR. SINCE THIS WAS A FERRY FLT FOR A NEW ACR B FK-100; I WAS NOT AWARE THAT I NEEDED AN LETTER OF AUTHORIZATION FOR FLT ABOVE FL275 AS LONG AS I WAS QUALIFIED IN MNPS PROCS AND COMPLIED WITH ALL OF THESE PROCS IN POSITIVE TRACKING AND FLT FOLLOWING ON THE IRS IN THE MNPS AREA. SINCE I MET ALL OF THE REQUIREMENTS AND FOLLOWED THE PROCS IN THE MNPS AREA; I THOUGHT I WAS LEGAL TO FLY IN MNPS ON A SPACE AVAILABLE BASIS AS REQUESTED. AFTER ARR AT KMDW; THE FAA ASKED WHY I HAD FLOWN IN MNPS WITHOUT AN LETTER OF AUTHORIZATION. I STATED THAT I HAD BEEN TRAINED AND QUALIFIED IN MNPS AND WAS ALLOWED TO FLY ABOVE FL275 ON A SPACE AVAILABLE BASIS AND; BECAUSE OF MORE EXTREME HEADWINDS; REQUIRED FL310 FOR FUEL ECONOMY AND SAFETY. THE LETTER OF AUTHORIZATION IS REALLY HIDDEN IN FAR 91 AND EVEN SO; I FEEL WHEN ASKED 'ARE YOU MNPS QUALIFIED' BY ATC; IF YOU ARE ALLOWED TO CONTINUE; THEN YOU ARE CONSIDERED TO HAVE MET ALL THE REQUIREMENTS IN THE MNPS AIRSPACE. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: THE CRUX OF THIS MATTER IS THE PHILOSOPHY OF FAR 91.705 AND FAR 91 APPENDIX C SECTION 3. APPENDIX C ALLOWS AN ACFT ACCESS TO THE MNPS IF THERE IS SPACE AVAILABLE. 91.705 SEEMS TO SAY THAT THERE MUST BE A LETTER OF AUTHORIZATION FOR EACH FLT THAT IS NOT A REGULARLY SCHEDULED FLT. AN ACI SERVING THE RPTR'S ACR QUESTIONED THE RPTR'S ENTRY INTO THE MNPS WITHOUT A LETTER OF AUTHORIZATION AND SENT A LETTER THREATENING VIOLATION PROCEEDINGS. WHEN THE RPTR SHOWED THE ACI APPENDIX C; THE ACI SENT ANOTHER LETTER SAYING THAT THERE WOULD BE A 'WARNING LETTER' PUT IN THE RPTR'S RECORDS FOR 2 YRS AND THAT THERE WAS NO VIOLATION. THE RPTR BELIEVES THAT THE ACI IS AFTER HIS COMPANY; NOT NECESSARILY HIM. THE RPTR IS OVER AGE 60 AND FLIES FERRY FLTS UNDER FAR 91; NOT FAR 121.