121.436
10-07-2014, 03:28 AM
#31
Gets Weekends Off
Joined APC: Mar 2008
Position: FAA 'Flight Check'
Posts: 13,839
I think the spirit of the rule is that a pilot needs to have 1000 hours of 121 time (PIC or SIC) in order to meet the requirement 121.436 after July 31st to be PIC. The rule probably should have said either SIC or PIC time. Since the date has now come and gone, the spirit of the rule is probably that they want you to have 1000 hours of experience as an SIC in a 121 operation before upgrading to Captain if you have no other 121 flight time.
Further, technically speaking, one could argue that if the pilot had the day off on July 31st, 2013 that he is not excepted from the 1,000 hour air carrier operations experience requirement because he did not serve as PIC on that date.
Further, technically speaking, one could argue that if the pilot had the day off on July 31st, 2013 that he is not excepted from the 1,000 hour air carrier operations experience requirement because he did not serve as PIC on that date.
02-12-2015, 06:18 AM
#32
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Position: BE-90GTx/200/350; CE-500; BE-400
Posts: 79
02-13-2015, 05:40 AM
#34
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Joined APC: Feb 2013
Posts: 3,011
Yep, you will qualify on the 121SIC. The old 121PIC time carries no weight. It's an oversite by the FAA lawyers, but not one they are willing to correct at this point as numerous LOI's have been sent and responded too.
04-01-2015, 10:34 PM
#36
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Joined APC: Jun 2013
Position: die Pilotin
Posts: 286
04-02-2015, 02:21 AM
#37
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Joined APC: Oct 2014
Position: Downward-Facing Dog Pose
Posts: 1,537
Question: how is a 1000 hr TPIC part 135 Brasilia CA flying cargo not good enough to head over to PIC a Brasilia or a Q400 flying 121 pax?
04-02-2015, 03:32 AM
#39
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Joined APC: Feb 2011
Posts: 57
Pax only in an aircraft with 10+ seats. Legal Interpretation here!
04-02-2015, 06:03 AM
#40
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Joined APC: Dec 2010
Position: 767 FO
Posts: 16
Pax only in an aircraft with 10+ seats. Legal Interpretation here!
135.243 (a)(1)
Of a turbojet airplane, of an airplane having a passenger-seat configuration, excluding each crewmember seat, of 10 seats or more, or of a multiengine airplane in a commuter operation as defined in part 119 of this chapter, unless that person holds an airline transport pilot certificate with appropriate category and class ratings and, if required, an appropriate type rating for that airplane.
So I'm curious as to how people are interpreting 135.243(a)(1). When I read it I see reference to 3 distinct categories:
1. Turbojet airplane
2. Airplane with 10 or more pax seats
3. Multiengine airplane in a commuter operation under part 119
However, this interpretation letter from the Assistant Chief Counsel seems to think of it as only referencing 2 distinct categories:
1. Turbojet airplane with 10 or more pax seats
2. Multiengine airplane in a commuter operation under part 119
With this in consideration, if 135.243 (a)(1) is being officially interpreted as only referencing 2 distinct categories then they are saying that you DON'T need an ATP to operate a turbojet part 135 for aircraft with less than 10 pax seats! This is contrary to everything I have understood about 135 turbojet PIC requirements. I called the office and left a message and am waiting to hear back.
Even if you look at 91.1053(a)(2)(i) you will see that it makes NO reference to pax seating number requirements. Only the requirement for an ATP and Type Rating.
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