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Old 10-15-2019, 07:43 PM
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I had a discussion with a possible employer today who stated my 1,000 hrs PIC 'Commuter Airline' would not count towards the 1,000 hrs Part 121 PIC requirement; but it certainly does the way I read the FAR's.

121.436 "(3) If serving as pilot in command in part 121 operations, has 1,000 hours as second in command in operations under this part, pilot in command in operations under § 91.1053(a)(2)(i) of this chapter, pilot in command in operations under § 135.243(a)(1) of this chapter, or any combination thereof."
135.243(a)(1) reads "(1) Of a turbojet airplane, of an airplane having a passenger-seat configuration, excluding each crewmember seat, of 10 seats or more, or of a multiengine airplane in a commuter operation..."

Am I missing something or have the regs changed very recently?
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Old 10-15-2019, 08:07 PM
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Originally Posted by Aurora8 View Post
I had a discussion with a possible employer today who stated my 1,000 hrs PIC 'Commuter Airline' would not count towards the 1,000 hrs Part 121 PIC requirement; but it certainly does the way I read the FAR's.

121.436 "(3) If serving as pilot in command in part 121 operations, has 1,000 hours as second in command in operations under this part, pilot in command in operations under § 91.1053(a)(2)(i) of this chapter, pilot in command in operations under § 135.243(a)(1) of this chapter, or any combination thereof."
135.243(a)(1) reads "(1) Of a turbojet airplane, of an airplane having a passenger-seat configuration, excluding each crewmember seat, of 10 seats or more, or of a multiengine airplane in a commuter operation..."

Am I missing something or have the regs changed very recently?
No, they are wrong. That operation which you quoted requires an ATP (multi-engine commuter), which is probably why that time counts towards the 1000hr requirement in the regulation as far as why they wrote it that way. It wouldn't be the first time someone was wrong. How can you turn it into a positive? You could always ask to speak with their superior...
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Old 10-16-2019, 01:16 AM
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They are wrong
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Old 10-16-2019, 02:22 AM
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Originally Posted by CA Deplorable View Post
They are wrong
What are the company mins? Often the company mins are different (higher) than FAR mins.
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Old 10-18-2019, 11:16 PM
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I recently spoke with an FAA POI about this very subject regarding my flight times. As their Letter of Interp was given to them, “commuter airline” refers to an operation as PIC where utilizing the ATP license is required AND/OR the “commuter” holds out to the general public for flights that are scheduled in advance (I,e: pax can book a ticket from A to B at least three mos out).

My part 135 commuter time is considered on-demand, read cargo, and therefore does not qualify as time that will meet the FAA definition of commuter.

That’s my experience on the subject but it may very well differ with each FSDO. Good luck.
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Old 10-19-2019, 08:25 AM
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Pretty sure Cape Air is the only larger outfit in the US that qualifies for that.
Is it smart to go from C402 to a CRJ CA, no. But it's legal.
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Old 10-19-2019, 11:48 AM
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Originally Posted by dera View Post
Pretty sure Cape Air is the only larger outfit in the US that qualifies for that.


Wouldn’t Contour, JSX, Surf Air and other scheduled pax operators?
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Old 10-19-2019, 02:22 PM
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Originally Posted by majorpilot View Post
Wouldn’t Contour, JSX, Surf Air and other scheduled pax operators?
Surf Air doesn't fly anything so that won't count. Whoever they are scamming this month might, but lately it's been PC12 so single engine stuff. I thought Contour and JSX are all jets?

There are a few companies that run scheduled pax service on multi-engine props, but I did specifically say "larger" outfit. Cape is massive compared to the others that might qualify.
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Old 10-19-2019, 02:59 PM
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Originally Posted by dera View Post
Surf Air doesn't fly anything so that won't count.

That’ll be new to the folks I’ve seen boarding those Surf Air-logo’ed Pilatuses at Signature/KOAK in the last few weeks.
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Old 10-19-2019, 05:50 PM
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Originally Posted by majorpilot View Post
That’ll be new to the folks I’ve seen boarding those Surf Air-logo’ed Pilatuses at Signature/KOAK in the last few weeks.
Not sure if you know how they work, but they are not operated by Surf Air.
Surf doesn't even have a 135 certificate any more.
I think the latest is that they are operated by Advanced Air.
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