121 Supplemental Augmented crews
08-07-2012, 06:59 PM
#1
Gets Weekends Off
Thread Starter
Joined APC: May 2007
Position: A320 Captain
Posts: 1,982
121 Supplemental Augmented crews
Hello,
I had a question for other 121 supp pilots. I've read all the 121 Regs searching for an answer on this and just wanted some input from other people that have been doing this longer than me.
Is it legal to be doing augmented 3-man crews on flying that is all domestic? I've always associated augmented crews with International flying. Our FOM says something to the effect that it chooses not to comply with 121.513 thru 121.525. These are the portions that deal with Int'l Ops for 121 supplemental rules.
Do any of the other charter companies operate in this manner? I'm talking about being scheduled for 8.0-12.0 block hours and up to 18 hour duty day...but all the flying is all domestic....usually 5 or 6 legs. Crew of 3...2 typed guys and a SIC. No crew rest facilities blocked off.
Is this legal?
I had a question for other 121 supp pilots. I've read all the 121 Regs searching for an answer on this and just wanted some input from other people that have been doing this longer than me.
Is it legal to be doing augmented 3-man crews on flying that is all domestic? I've always associated augmented crews with International flying. Our FOM says something to the effect that it chooses not to comply with 121.513 thru 121.525. These are the portions that deal with Int'l Ops for 121 supplemental rules.
Do any of the other charter companies operate in this manner? I'm talking about being scheduled for 8.0-12.0 block hours and up to 18 hour duty day...but all the flying is all domestic....usually 5 or 6 legs. Crew of 3...2 typed guys and a SIC. No crew rest facilities blocked off.
Is this legal?
08-08-2012, 06:19 AM
#3
Gets Weekends Off
Joined APC: Mar 2011
Position: Underemployed!
Posts: 116
Yes it's legal. Here's an excerpt from ALPA's Guide to Flight Time Limitations and Rest Requirements, 6-A Edition June 2004. I believe there is a FAA interpretation for this as well but I couldn't find it.
I reference this guide because the example they use is specifically a domestic trip.
My company choose to not use .513-.525 as well, I think because of the additional rest requirements and limitations that come with it. We too use .507 and .509 for domestic trips, and your question came up years ago when we started using .507 for these trips.
Of course this is all true for now, until the new FAR's take affect in Dec. 2013.
I reference this guide because the example they use is specifically a domestic trip.
My company choose to not use .513-.525 as well, I think because of the additional rest requirements and limitations that come with it. We too use .507 and .509 for domestic trips, and your question came up years ago when we started using .507 for these trips.
FAR 121.507 provides:
(a) No certificate holder conducting supplemental operations may schedule a pilot.
(1) For flight deck duty in an airplane that has a crew of three pilots for more than eight hours in any 24 consecutive hours; or
(2) To be aloft in an airplane that has a crew of three pilot(s) for more than 12 hours in any 24 consecutive hours.
(b) No pilot of an airplane that has a crew of three pilots may be on duty for more than 18 hours in any 24 consecutive hours.
Q-84. An MD-11 aircraft (two-pilot crew) is scheduled to operate New York-Los Angeles-New York for 10:30 of scheduled flight time. An additional pilot augments the crew. Can this flight operate?
A-84. Yes. The supplemental rules limit flight deck duty to eight hours so with three pilots and 10:30 of flight time, the air carrier can limit each pilot’s duty at the controls to less than eight hours. If the duty time was less than 18 hours, then the flight could operate.
(a) No certificate holder conducting supplemental operations may schedule a pilot.
(1) For flight deck duty in an airplane that has a crew of three pilots for more than eight hours in any 24 consecutive hours; or
(2) To be aloft in an airplane that has a crew of three pilot(s) for more than 12 hours in any 24 consecutive hours.
(b) No pilot of an airplane that has a crew of three pilots may be on duty for more than 18 hours in any 24 consecutive hours.
Q-84. An MD-11 aircraft (two-pilot crew) is scheduled to operate New York-Los Angeles-New York for 10:30 of scheduled flight time. An additional pilot augments the crew. Can this flight operate?
A-84. Yes. The supplemental rules limit flight deck duty to eight hours so with three pilots and 10:30 of flight time, the air carrier can limit each pilot’s duty at the controls to less than eight hours. If the duty time was less than 18 hours, then the flight could operate.
08-17-2012, 06:26 PM
#6
Gets Weekends Off
Joined APC: Jun 2011
Posts: 127
Originally Posted by noalign
121.437(a) mentions that your entire supplemental augmented crew should also be typed.
Originally Posted by EatinRamen
An airline I worked for did this for a while, till they got their hands slapped and the feds reminded them that it was only for int'l ops.
You are part of a 2 pilot, 1 FE crew and you start your trip in Mexico City, fly to El Paso, clear customs and get fuel, and continue on to Seattle. (granted i know this wouldn't exceed flight time limitations, but possibly duty time). So say you wait in MMMX for freight for 10 hours and wait in ELP for wrong customs paperwork for another 5 hours. If you use domestic rules this trip is done. If you use the overseas/int'l rules, you can fly 12 hours and have an unlimited duty day (just make sure to observe 24 hours off in 7 days).
But
Is this an "int'l" operation? 121.513(a), by the letter, would mean that your point outside the US to a point inside the US would be the MMMX-ELP leg. After that point it's domestic...? Or does the tech stop in ELP for customs/fuel not count? The whole "trip" is intl?
And how do you think 121S air carriers like to interpret the rules?
I am having deja vu so sorry if this has already been debated ad nauseum
08-18-2012, 09:47 AM
#8
Gets Weekends Off
Joined APC: Jun 2011
Posts: 127
Originally Posted by Twin Wasp
If ELP is just a tech stop, you press on under flag rules. If there is any change to the payload, anything or one on or off there, it becomes a domestic leg ELP-SEA.
Also, you can't just arbitrarily swap from supplemental to flag as you like, unless you have been required to under 119.21(3). Not all certificate holders have this allowance or restriction.
08-19-2012, 06:15 PM
#10
Gets Weekends Off
Joined APC: Nov 2005
Position: Guppy Capt.
Posts: 1,887
Originally Posted by BeaglePilot
This is some great discussion. Unfortunately the carrier I work for has it's POI from the Detroit FSDO. This particular group of people from the FAA allow the YIP carriers carte Blanche.
Nothing like an ex Chief Pilot for pax operator, "interpret" the regs for a charter type operation.
Always can point out FAA LEGAL interpretations...
P.S. They like to be known as EMI (Eastern Michigan)... Detroit seems to scare people off...
Thread
Thread Starter
Forum
Replies
Last Post
