The way I read this, only passenger-carrying operations count--no cargo ops at all--121.436 explictly says the time counts if it meets the definition of 135.243(a)(1). 135.243(a) states "passenger-carrying operations." By statutory construction/convention, 135.243(a) thus governs any sub-sections, including the definition in 135.243(a)(1), and the reference to 119 commuter ops.

Is that what your class determined? Do the PHX FSDO, Mesa's POI, and Mesa's check airmen all agree with your new hire class's interpretation? You guys must really have it all figured out!!!

Sec. 135.243 — Pilot in command qualifications.

(a) No certificate holder may use a person, nor may any person serve, as pilot in command in passenger-carrying operations—

(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.


Sec. 119.3 — Definitions.

For the purpose of subchapter G of this chapter, the term—

Commuter operation means any scheduled operation conducted by any person operating one of the following types of aircraft with a frequency of operations of at least five round trips per week on at least one route between two or more points according to the published flight schedules:
(1) Airplanes, other than turbojet powered airplanes, having a maximum passenger-seat configuration of 9 seats or less, excluding each crewmember seat, and a maximum payload capacity of 7,500 pounds or less; or
(2) Rotorcraft.