FAR 117.23 Question

xdashdriver

xdashdriver

Well-Known Member
Hopefully someone here can help me with a question regarding 117.23 Cumulative Duty Limitations.

(a)The limitations of this section include all flying by flightcrew members on behalf of any certificate holder or 91K Program Manager during the applicable periods.

Under the old 121 flight time rules, it said "commercial flying" which I believe most interpreted to mean any flying that was compensated for in one form or another. 117.23 specifies flying on behalf of any certificate holder or 91K program.

So can a CFI now flight instruct on the side while flying 121 and it not affect his flight time limits? Seems like a significant change in the rules.

Ray
 
I thought that was refrencing when your dirtbag 121 operation (Colgan) wants you to complete your 8 hour day and go fly another round trip and 3-4 hours with pax as a part 91 flight.
 
I've looked all over and found nothing that says that CFIing on the side is prohibited. I'm sure an LOI from legal affairs will come, but people I've talked to can't find something that says it's prohibited...
 
On the ATP test, (which I took yesterday), there was a question that was worded like this...(or close)

the flight time limitations for flight crew members include

correct answer "All commercial flying in any flight crewmember position"

The test prep software explanation points to 14 CFR 121.471 " ...no flight crewmember may accept an assignment for flight time in scheduled air transportation or in other commercial flying if that crewmember's total flight time will exceed....."
 
That regulation has been superseded by FAR 117 for passenger operations. New language would seem to indicate only flying for air carriers now counts towards total flight time limitations. See original post for exact wording.
 
raysalmon said:
That regulation has been superseded by FAR 117 for passenger operations. New language would seem to indicate only flying for air carriers now counts towards total flight time limitations. See original post for exact wording.
Click to expand...
Sure.

Your FOM may still prohibit outside commercial flying, though.
 
Here is (my own interpretation) the factors when flying 121:

If you are paid to fly, and working 121, it all must be factored. I could be 100% wrong in my own views, but when reading the regs that's what it seems. The new regs are focused on airline pax ops (obviously, the lawmakers don't think boxes matter... Sidebar). So, anything that has to do with flying for money, and airline passengers in the mix, it all counts. Whether you report the 4 CFI dual-given flights on your off days (to pay the bills) to your 121 company to factor into your flying schedule is on the same level as what you put in the logbook and count on the resume for a future 121 gig.

In dealing with 121 schedules a good bit, it's amazing how fast the 168/672 FDP hours add up. 30/7 and 24/7 was easy to calculate. Now you can have folks fly a 4-day, then a CDO (overnight operations), 2 days off, another 4-day, but you can't do what used to be a rather basic CDO line. It's science, but not meeting logic at times.

To the OP- this would be a good question for a FSDO to put formulate a written answer. Many folks do "other flying", yet consider it outside the pervue of 121, when it is possible that it completely matters and makes for a legality concern.
 
My DO just come out with a memo recently saying part 91 flying was ok and that we just needed to get their written approval first.
 
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