Kelley Interpretation Letter - 121.436

I'm sorry, maybe I wasn't clear. Would an 8 pax seat bizjet operated under 135 qualify?

My interpretation was that it would, reading their letter to you suggests that it would not.
135.243a (1)- of a turbojet.
any turbojet under 135 as pic counts.
 
135.243a (1)- of a turbojet.
any turbojet under 135 as pic counts.

I agree, however, in their reply to you, FAA legal says the following:

"Section 135.243(a)(1) operations are passenger carrying operations using a turbojet with a passenger-seat configuration of 10 seats or more, or using a multiengine airplane in a commuter operation"

Which, to me, implies that the jet must also have 10 seats.
 
I'm sorry, maybe I wasn't clear. Would an 8 pax seat bizjet operated under 135 qualify?

My interpretation was that it would, reading their letter to you suggests that it would not.
Good catch. They had to have messed that up. For what it's worth at no point in my letter did I meantion anything about turbojets. A clarification may be needed.
 
Interesting about Key Lime. If they got their exemption, would that mean pilots that have 1000 hrs of Metro PIC time be able to use it to fly PIC 121 elsewhere?
 
It looks like my company is going to start a 135 commuter operation in a King Air 350 soon. Now, I am even more confused about this.

Section 135.243(a)(1) operations are passenger carrying
operations using a turbojet with a passenger-seat configuration of 10 seats or more, or using
a multiengine airplane in a commuter operation for which the PIC must hold an ATP with
appropriate category and class ratings and, if required, an appropriate type rating.

It looks like if I get 1000 hours PIC in this operation, then I meet the requirement. Is that right?
 
It looks like my company is going to start a 135 commuter operation in a King Air 350 soon. Now, I am even more confused about this.



It looks like if I get 1000 hours PIC in this operation, then I meet the requirement. Is that right?

That is correct - you could get 1000hrs of King Air 350 PIC time in commuter operations...then go to the left seat of a CRJ when they start hiring street captains. However, right now, you could not go fly a Metroliner for a 121 operation as captain, even though you have already have time as a metro captain...
 
So you're tellin me my single pilot Metro time is worthless? :aghast:

Join the club. It's a rather large one. It's not very likely that we would get street hire captain spots, but how I see this really affecting us is going to a regional with quick upgrades and getting passed up because we don't have 1000 SIC part 121. SMH
 
Join the club. It's a rather large one. It's not very likely that we would get street hire captain spots, but how I see this really affecting us is going to a regional with quick upgrades and getting passed up because we don't have 1000 SIC part 121. SMH
Word on the street(talking to a TSA pilot) is TSA has no idea 121.436 exists, or at least what it actually means and they'll upgrade you regardless of what the regs say.
 
Word on the street(talking to a TSA pilot) is TSA has no idea 121.436 exists, or at least what it actually means and they'll upgrade you regardless of what the regs say.
How does that work? And how are they getting away with it?
 
How does that work? And how are they getting away with it?

Well, honestly, in a lot of ways the reg is kind of uncheckable by the feds - I mean, what are they going to do, go through each applicant's log book prior to upgrade ground? It only hurts you if you have an accident while you're there, which is fairly unlikely statistically speaking. This whole reg is the feds covering their own ass so they can say, "look, he had 1000hrs in scheduled operations, he and the company should have known better!"
 
Huh. You would think that the company would want to be meeting these reqs in case they were to get audited or something. But I guess no one checks it just the honors system.
 
Word on the street(talking to a TSA pilot) is TSA has no idea 121.436 exists, or at least what it actually means and they'll upgrade you regardless of what the regs say.
Supposedly, someone went from Ameriflight to Compass(A TSA company) and upgraded in a very short time. Like 6 months. I haven't confirmed if it's true or not, or what(if any) other flight time the guy has. I'm suspicious of such things when there isn't a name associated with the story. :)

What I'm FAR more curious about, is what happens in an interview at say, Delta, when it's discovered that you only have 200 hours 121 SIC time and upgraded? Or even before the interview. AirlineApps would show that lack of time quite obviously, and so would your resume if you had that time allocated separately in it.
 
Supposedly, someone went from Ameriflight to Compass(A TSA company) and upgraded in a very short time. Like 6 months. I haven't confirmed if it's true or not, or what(if any) other flight time the guy has. I'm suspicious of such things when there isn't a name associated with the story. :)

What I'm FAR more curious about, is what happens in an interview at say, Delta, when it's discovered that you only have 200 hours 121 SIC time and upgraded? Or even before the interview. AirlineApps would show that lack of time quite obviously, and so would your resume if you had that time allocated separately in it.

That happened in 2007, I know the guy it happened to, though it wasn't quite 6 months.

Nobody on Compass property right now is upgrading in 6 months. I think the award is happening around 14 currently.
 
Well, honestly, in a lot of ways the reg is kind of uncheckable by the feds - I mean, what are they going to do, go through each applicant's log book prior to upgrade ground?

The Feds won't unless you give them a reason to.

The company on the other had will. We have had more than one person show up to upgrade and then be sent home because they don't meet the requirements. One of the things that they are collecting data on now is how much previous 121/135 PIC, etc. each new hire has.

The FSDO might not check every one, but the company sure does. From a liability standpoint if something were to happen and also from a training schedule standpoint (they don't have the luxury to have a seat in an upgrade class vacant) it is in the company's best interest to make sure each applicant is qualified.
 
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