Can you fly part 91?
12-22-2018, 03:45 PM
#32
Line Holder
Joined APC: Feb 2018
Posts: 46
Originally Posted by JohnBurke
Flight instruction performed under Part 91, if you are compensated, is "other commercial flying,' and must be considered in calculating your flight time limitations.
Flight instruction under Part 91 which is not compensated is not "other commercial flying."
Use caution, as the FAA has determined that the logging of flight time is considered compensation.
https://www.faa.gov/about/office_org...rpretation.pdf
Flying other than instruction, if compensated, is "other commerical flying," and likewise counts against your flight time limitations under Part 121.
Banner towing, firefighting, flying jumpers, ag flying, etc...all count toward the total flight time limitations applicable under 121 or 135.
Flight instruction under Part 91 which is not compensated is not "other commercial flying."
Use caution, as the FAA has determined that the logging of flight time is considered compensation.
https://www.faa.gov/about/office_org...rpretation.pdf
Flying other than instruction, if compensated, is "other commerical flying," and likewise counts against your flight time limitations under Part 121.
Banner towing, firefighting, flying jumpers, ag flying, etc...all count toward the total flight time limitations applicable under 121 or 135.
According to that letter, yes but that no longer applies since 117 changed a few years back and no longer covers “commercial flying”.
§ 117.1 Applicability.
(a) This part prescribes flight and duty limitations and rest requirements for all flightcrew members and certificate holders conducting passenger operations under part 121 of this chapter.
(b) This part applies to all operations directed by part 121 certificate holders under part 91, other than subpart K, of this chapter if any segment is conducted as a domestic passenger, flag passenger, or supplemental passenger operation.
(c) This part applies to all flightcrew members when participating in an operation under part 91, other than subpart K of this chapter, on behalf of the part 121 certificate holder if any flight segment is conducted as a domestic passenger, flag passenger, or supplemental passenger operation
(d) Notwithstanding paragraphs (a), (b) and (c) of this section, a certificate holder may conduct under part 117 its part 121 operations pursuant to 121.470, 121.480, or 121.500.
Part 117 only applies to certificate holders and pilots performing flying for certificate holders. Instructing in Joe Bobs local flight school does not count against 117 since there is no certificate. Instructing for a university or some other 141 school counts since it is on behalf of a certificate holder. Flying under 135, 91k, 121 (even if its a nonrevenue 91 leg) counts too.
The company may have a problem with it but the only rule you need to comply with is no more than 8 in 24 as a cfi.
12-25-2018, 12:48 PM
#33
Gets Weekends Off
Joined APC: Jul 2013
Posts: 10,061
Originally Posted by Biggbird
According to that letter, yes but that no longer applies since 117 changed a few years back and no longer covers “commercial flying”.
§ 117.1 Applicability.
(a) This part prescribes flight and duty limitations and rest requirements for all flightcrew members and certificate holders conducting passenger operations under part 121 of this chapter.
(b) This part applies to all operations directed by part 121 certificate holders under part 91, other than subpart K, of this chapter if any segment is conducted as a domestic passenger, flag passenger, or supplemental passenger operation.
(c) This part applies to all flightcrew members when participating in an operation under part 91, other than subpart K of this chapter, on behalf of the part 121 certificate holder if any flight segment is conducted as a domestic passenger, flag passenger, or supplemental passenger operation
(d) Notwithstanding paragraphs (a), (b) and (c) of this section, a certificate holder may conduct under part 117 its part 121 operations pursuant to 121.470, 121.480, or 121.500.
Part 117 only applies to certificate holders and pilots performing flying for certificate holders. Instructing in Joe Bobs local flight school does not count against 117 since there is no certificate. Instructing for a university or some other 141 school counts since it is on behalf of a certificate holder. Flying under 135, 91k, 121 (even if its a nonrevenue 91 leg) counts too.
The company may have a problem with it but the only rule you need to comply with is no more than 8 in 24 as a cfi.
§ 117.1 Applicability.
(a) This part prescribes flight and duty limitations and rest requirements for all flightcrew members and certificate holders conducting passenger operations under part 121 of this chapter.
(b) This part applies to all operations directed by part 121 certificate holders under part 91, other than subpart K, of this chapter if any segment is conducted as a domestic passenger, flag passenger, or supplemental passenger operation.
(c) This part applies to all flightcrew members when participating in an operation under part 91, other than subpart K of this chapter, on behalf of the part 121 certificate holder if any flight segment is conducted as a domestic passenger, flag passenger, or supplemental passenger operation
(d) Notwithstanding paragraphs (a), (b) and (c) of this section, a certificate holder may conduct under part 117 its part 121 operations pursuant to 121.470, 121.480, or 121.500.
Part 117 only applies to certificate holders and pilots performing flying for certificate holders. Instructing in Joe Bobs local flight school does not count against 117 since there is no certificate. Instructing for a university or some other 141 school counts since it is on behalf of a certificate holder. Flying under 135, 91k, 121 (even if its a nonrevenue 91 leg) counts too.
The company may have a problem with it but the only rule you need to comply with is no more than 8 in 24 as a cfi.
12-25-2018, 08:13 PM
#35
Line Holder
Joined APC: Feb 2018
Posts: 46
Originally Posted by CBreezy
According to your own post, the applicability applies when operating for the 121 certificate holder. FAR 117 doesn't apply to 141 doesn't fall under 117 and wouldn't be applied to 117 limits.
Other posters incorrectly thought time flight instructing, flying skydivers, etc. counted against their 117 limits. It doesnt.
01-01-2019, 07:52 AM
#36
Gets Weekends Off
Joined APC: Jan 2016
Posts: 529
Originally Posted by Biggbird
Right, that’s the point. Flying done outside the airline (even commercial) does not count towards part 117 flight time limits at the airline for this exact reason... 117 only applies to your limits at the airline.
Other posters incorrectly thought time flight instructing, flying skydivers, etc. counted against their 117 limits. It doesnt.
Other posters incorrectly thought time flight instructing, flying skydivers, etc. counted against their 117 limits. It doesnt.
117.23 Cumulative limitations.
(a) The limitations of this section include all flying by flightcrew members on behalf of any certificate holder or 91K Program Manager during the applicable periods.
As far as I can tell, flight instruction does not need to be included when considering cumulative totals, but most carriers want to know about it.
Last edited by TimetoClimb; 01-01-2019 at 08:09 AM.
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