Airline Pilot Forums

Hello,

I had a question for other 121 supp pilots. I've read all the 121 Regs searching for an answer on this and just wanted some input from other people that have been doing this longer than me.

Is it legal to be doing augmented 3-man crews on flying that is all domestic? I've always associated augmented crews with International flying. Our FOM says something to the effect that it chooses not to comply with 121.513 thru 121.525. These are the portions that deal with Int'l Ops for 121 supplemental rules.

Do any of the other charter companies operate in this manner? I'm talking about being scheduled for 8.0-12.0 block hours and up to 18 hour duty day...but all the flying is all domestic....usually 5 or 6 legs. Crew of 3...2 typed guys and a SIC. No crew rest facilities blocked off.

Is this legal?

An airline I worked for did this for a while, till they got their hands slapped and the feds reminded them that it was only for int'l ops.

Yes it's legal. Here's an excerpt from ALPA's Guide to Flight Time Limitations and Rest Requirements, 6-A Edition June 2004. I believe there is a FAA interpretation for this as well but I couldn't find it.

I reference this guide because the example they use is specifically a domestic trip.

My company choose to not use .513-.525 as well, I think because of the additional rest requirements and limitations that come with it. We too use .507 and .509 for domestic trips, and your question came up years ago when we started using .507 for these trips.

FAR 121.507 provides:
(a) No certificate holder conducting supplemental operations may schedule a pilot.
(1) For flight deck duty in an airplane that has a crew of three pilots for more than eight hours in any 24 consecutive hours; or
(2) To be aloft in an airplane that has a crew of three pilot(s) for more than 12 hours in any 24 consecutive hours.
(b) No pilot of an airplane that has a crew of three pilots may be on duty for more than 18 hours in any 24 consecutive hours.

Q-84. An MD-11 aircraft (two-pilot crew) is scheduled to operate New York-Los Angeles-New York for 10:30 of scheduled flight time. An additional pilot augments the crew. Can this flight operate?

A-84. Yes. The supplemental rules limit flight deck duty to eight hours so with three pilots and 10:30 of flight time, the air carrier can limit each pilot’s duty at the controls to less than eight hours. If the duty time was less than 18 hours, then the flight could operate.

Of course this is all true for now, until the new FAR's take affect in Dec. 2013.

121.437(a) mentions that your entire supplemental augmented crew should also be typed.

Thank you for the replies.

121.437(a) mentions that your entire supplemental augmented crew should also be typed.

I'm not sure on this part, how should this be interpreted? The PIC (1st Captain) has to be type rated, the SIC (2nd Captain) has to be typed as well, but the 3rd dude (or 4th for that matter) can just be a plain Jane Commercial pilot, no type. Right? To get a 3 pilot augmented crew you start with a regular CA/FO pairing and add 1 CA. To get a 4 pilot aug. crew you start with CA/FO and add 2 CA's or 1 of each? How do the ACMI guys crew the 747 for 16 flight/20 duty?

An airline I worked for did this for a while, till they got their hands slapped and the feds reminded them that it was only for int'l ops.

Also, how do you think "international" is interpreted? 121.513

You are part of a 2 pilot, 1 FE crew and you start your trip in Mexico City, fly to El Paso, clear customs and get fuel, and continue on to Seattle. (granted i know this wouldn't exceed flight time limitations, but possibly duty time). So say you wait in MMMX for freight for 10 hours and wait in ELP for wrong customs paperwork for another 5 hours. If you use domestic rules this trip is done. If you use the overseas/int'l rules, you can fly 12 hours and have an unlimited duty day (just make sure to observe 24 hours off in 7 days).

But

Is this an "int'l" operation? 121.513(a), by the letter, would mean that your point outside the US to a point inside the US would be the MMMX-ELP leg. After that point it's domestic...? Or does the tech stop in ELP for customs/fuel not count? The whole "trip" is intl?

And how do you think 121S air carriers like to interpret the rules?

I am having deja vu so sorry if this has already been debated ad nauseum

If ELP is just a tech stop, you press on under flag rules. If there is any change to the payload, anything or one on or off there, it becomes a domestic leg ELP-SEA.

If ELP is just a tech stop, you press on under flag rules. If there is any change to the payload, anything or one on or off there, it becomes a domestic leg ELP-SEA.

Would you mind pointing out the reference you used regarding the tech stop?

Also, you can't just arbitrarily swap from supplemental to flag as you like, unless you have been required to under 119.21(3). Not all certificate holders have this allowance or restriction.

This is some great discussion. Unfortunately the carrier I work for has it's POI from the Detroit FSDO. This particular group of people from the FAA allow the YIP carriers carte Blanche.

This is some great discussion. Unfortunately the carrier I work for has it's POI from the Detroit FSDO. This particular group of people from the FAA allow the YIP carriers carte Blanche.

No "Justice", huh? ;)

Nothing like an ex Chief Pilot for pax operator, "interpret" the regs for a charter type operation.

Always can point out FAA LEGAL interpretations... :eek:

P.S. They like to be known as EMI (Eastern Michigan)... Detroit seems to scare people off...;)

Thank you for the replies.

BTW, congrats on the "Guppy Captain!" Hope life is great in the "Kingdom!"

Just an update...I'm still not sure what the correct interpretation is. BUT...I was just scheduled to deadhead to ORD to pick up the second half of a day's flying that previously we were doing as an augmented crew.

I don't know if this is an admission by the company that they had previously been doing it wrong...or just the fact that they didn't have enough crews at the starting base to augment the trip.

The DO and CP also got fired last week...not necessarily connected to this.

It is legal in domestic ops, just so long as none of the 3 pilots exceed 8 hours. ie fly 4 hours, rotate one pilot, fly 4 more hours rotate the other pilot, fly 4 more and you're done, every pilot has 8 hours of front seat time and the plane has moved for 12 hours. I'm looking for the reg now, but feel free to contact the "East Michigan" FSDO for further. ;) Did it for years and it sucked, lol

It is legal in domestic ops, just so long as none of the 3 pilots exceed 8 hours. ie fly 4 hours, rotate one pilot, fly 4 more hours rotate the other pilot, fly 4 more and you're done, every pilot has 8 hours of front seat time and the plane has moved for 12 hours. I'm looking for the reg now, but feel free to contact the "East Michigan" FSDO for further. ;) Did it for years and it sucked, lol

The reg is 121.507 - 3 pilot crews. Just to clarify, it does not matter whether it is domestic or international.

For the domestic vs int'l rule:
Usually the only time that the international vs domestic thing burns you is when you are operating a 2 pilot, 1 FE aircraft, crewed as such, on a "international" trip. (I think our Boeing 727 brethren feel this the most)

Then, you can use the flight time limitations spelled out in 121.521, because 121.513 says you can for "international" trips.

Those limits are:
1) No more than scheduled 12 hours flight in a 24 hour period.
2) NO DUTY DAY RESTRICTION. That is, you could be on duty almost 6 days and fly 12 hours. The next limiting factor for duty time would be the 1 in 7. 121.503(c)

In my opinion the Feds really messed up on this one.

3 Pilots, max duty of 18 hours
2 Pilots, 1 FE, max duty of 6 days.

This is safe how?

Do it all the time in the classic 74.... basic crew CA, FO, FE.... 12 hours flight time..( contractual to 18 hours duty )......our Gucci brothers :), would not see more than 8 hours in the seat..... crazy. OH..and if the company declares it a part 91 flight... well now all bets are off.

Do it all the time in the classic 74.... basic crew CA, FO, FE.... 12 hours flight time..( contractual to 18 hours duty )......our Gucci brothers :), would not see more than 8 hours in the seat..... crazy. OH..and if the company declares it a part 91 flight... well now all bets are off.


Its worse on planes with the FE...you are all stuck up there for all 12 hours. I did it on the L-1011 and 747-200. I can't sit for more than 2 hours now without getting the urge to land somewhere.

Routine, every day operations here at Xtra...