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Old 08-12-2025 | 08:27 PM
  #15  
JohnBurke
Disinterested Third Party
 
Joined: Jun 2012
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Same applicability. Time as pilot, pilot time: either requires documentation and 14 CFR 61.51 spells out the logging, or documentation, of time as pilot or pilot time. 61.8 excludes UAS pilot time from Part 61, to include the logging of pilot time.

Moreover, Part 107 also provides an exclusion from that entire chapter, from air carrier operations:

https://www.ecfr.gov/current/title-1...ter-F/part-107
Subpart A—General
§ 107.1 Applicability.(a) Except as provided in paragraph (b) of this section, this part applies to the registration, airman certification, and operation of civil small unmanned aircraft systems within the United States. This part also applies to the eligibility of civil small unmanned aircraft systems to operate over human beings in the United States.

(b) This part does not apply to the following:

(1) Air carrier operations;

(2) Any aircraft subject to the provisions of 49 U.S.C. 44809;

(3) Any operation that the holder of an exemption under section 333 of Public Law 112-95 or 49 U.S.C. 44807 elects to conduct pursuant to the exemption, unless otherwise specified in the exemption; or

(4) Any operation that a person elects to conduct under part 91 of this chapter with a small unmanned aircraft system that has been issued an airworthiness certificate.
There is, thus, a double-exclusion if you will, to the use of Part 107 UAS "pilot" time toward 135.243, as well as other pilot certification and privilege, such as the ATP requirements of this thread. Part 107 contains no provision for logging pilot time or pilot-in-command time of any kind; neither a definition of that time, nor a logging requirement or regulation. 61.51 has so such provision. There's no legal basis to present UAS experience as pilot experience toward 135.243, or any other airman rating, or operating privilege or requirement.

While 135.243 is not found in Part 61, obviously, the requirement to document pilot time is found in Part 61, and thus 61.51 is directly applicable to determining the meaning of pilot experience requirements stated under 135.243.
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