Originally Posted by
Cujo665
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.
It really isn't, and clearly you don't understand.
What you clearly don't understand is that Part 117 is not your authorization. Your employer, like any 121 employer (supplemental or otherwise) is issued an operating certificate by the FAA, and the authorizations allowed your operator are granted through the Operations Specifications. The authorization that designates your flight, duty, and rest rules is A117. Dig out your OpSpecs and look.
YOUR operator also utilizes 121 Subpart S, and YOUR general operations manual (Chapter 4: go look) will provide for the use of duty, rest, and flight times for domestic-only supplemental basic regulations, found in 121.503-509.
This is NOT the case for Western Global, and this is a thread about Western Global, much as you seem to wish to make it about you, or your airline. Your airline is not a cargo airline, and yet your airline operations manual also invokes 121 Subpart S (domestic only, even for international operations) for certain operations that it's authorized to do. It is NOT as simple as CARGO AIRLINE vs. PASSENGER AIRLINE. You're a passenger line. You are still beholden to and for certain operations, operate under Subpart S (domestic only).
You stated that your operations manual states nothing about Subpart S. Go read it again. You'll find that Supbart S is cited repeatedly in section 4 of that manual. Imagine that. YOUR airline, a passenger airline, that cites Subpart S in it's FAA-approved General Operations Manual. Go figure.