Cujo665

Thanks for another great diatribe of really good info but doesn't address the simple fact that what mandates 117 is the type of operation, Passenger vs Cargo; not being supplemental. You're a great source of knowledge in most cases, but on this one not so much.

If you read page 332 from the Federal Register you linked you'll see the FAA exempted Cargo operations from 117. It specifically states; "The FAA also has removed all-cargo operations from the applicability section of the new part 117." The exemption has zero to do with being supplemental and being supplemental appears nowhere in the exemptions.

ALL passenger operations come under 117, there is no choice. The differentiator if 117 is mandatory at any carrier is if the carrier is dispatching as Passenger vs Cargo and has zero to do with supplemental.
The ONLY thing supplemental does from that point is it lets the cargo company choose between part 117 rules and the part 121 domestic and international rest rules

Cargo has three choices.
1.) use 117
2.) use 121 rest rules for domestic (121.503 -121.509)
3.) use 121 rules for international (121.515, 121.521 - 121.525)

The rest of your original post that started this Segway I still agree with.

Oh, by the way..... our Section 4 in our company manual you referenced literally starts off in 4.1 with a huge note added in 2014 by - in summation - saying the difference in the rules is determined by Cargo vs Passenger.

That's why it doesn't say anything about subpart S..... supplemental isn't the criteria, Cargo vs Pax is the criteria for rest rules. Supplemental for cargo just lets the company choose which rest rules they want to use. I never said a company (including my own) can't do 117 for their pax operations, and 121 rules for their cargo operations, and I do not know where you got that from? In our case, a labor agreement restricts them to 117 only. This still goes back to what I originally said, the determining criteria is if the operation is being dispatched cargo or passenger; scheduled, unscheduled, charter, supplemental, flag, international, domestic.... all irrelevant to which rest rules apply. It's either cargo or it's passenger. If it's passenger it's 117; if it's Cargo they have the choice of 117, 121 domestic, 121 international.

Yes, it really is that simple. The type of operation dictates the rules.

I do enjoy the discussions though; it makes me dig into the books more.