Originally Posted by
Cujo665
Salty, but accurate... with the exception of calling it a supplemental exception to 117. It's not that it's supplemental; it that it's cargo. There are plenty of supplemental passenger operators, and they're under 117.
The link I cited to the ECFR is to 14 CFR 121 Subpart S: Flight Time Limitations, Supplemental Operations.
Your operation (NOT WGA, to be clear) utilizes Operations Specification (OpSpec) A117 to operate under 14 CFR 117.
While you (NOT WGA) are a supplemental carrier, you do not operate under Subpart S, the flight, duty, and rest limitations applicable to Supplemental Operations, because you have been issued OpSpec A117, which authorizes the use of alternate rest, duty, and flight time limitations, with onboard rest facilities. Without that OpSpec, you would be beholden to Subpart S.
WGA does is not authorized OpSpec 117; their MD11 and does not have rest facilities or do on board rest, that airplane makes up the bulk of its fleet.
You are correct, however, that the supplemental cargo segment of the industry was "carved out" of the modernization of rest requirements as now detailed in Part 117. The air cargo industry lobbied to ensure that cargo was kept in the dark ages, so far as rest, duty, and flight time requirements.