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Old 09-16-2015, 06:50 PM
  #6  
Xdashdriver
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Joined APC: Oct 2013
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Originally Posted by AMC190 View Post
Yeah thanks, according to the 91 rules it states flying as pilot in command for a turbojet aircraft in general, it does not specify carrier or operator, it refers to general terms.

Do you recommend me to check with any fsdo or any location in particular?

Thanks

I guess some more explanation is needed. 91.1053 is a section of Subpart K of Part 91. If you read 91.1001 - Applicability, it says that Subpart K governs fractional ownership programs. As a result, 91.1053 applies specifically to fractional ownership programs, not generally as you suggest. 121.436 says "as pilot in command in operations under 91.1053...".

In several letters of interpretation, the FAA has interpreted this regulation VERY strictly and has denied multiple petitions for exemptions from companies and individuals seeking relief.

I would NOT recommend seeking information from a FSDO. Contrary to popular opinion, general aviation inspectors are not well-versed in Part 121 regulations, and their advice carries no legal weight at all. I would google "121.436 letter of interpretation" and read up on what the FAA legal department has said. That will provide you with much more accurate information.
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