Ziggy:

Transport Category= aircraft certified under Part 25

Normal Category=aircraft certified under Part 23

135.399 states that it applies to any aircraft covered by 135.169 (b)1-6---Airplanes, either piston or turbine, that have a passenger seating capacity of ten or more that are either transport category, or normal category with various stipulations. They could be either transport category, or normal category with stipulations on which date in 1970 it was certified on.

Read 135.169(b)1-6, then 135.399. Then go back and read .169

Note that both regs deal only with SMALL airplanes--Less than 12,500 MGTOW.

Another thing to consider is that in .399, there is no "airplane" after the phrase "reciprocating engine". If it read "No person may.....a reciprocating engine airplane OR a turbopropeller powered airpane certified under 135.169 (b)..... THEN I WOULD AGREE TOTALLY WITH YOU.

This is where I figured this discussion would end up. As I said in the beginning, it depends on your region/FSDO.

Are you as supprised as I am that we have held this discussion on our own????????