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04-23-2019 | 05:02 PM
#91
Covfefe
Joined: Jun 2015
Posts: 3,001
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Which OpSpec discusses a part 121 repo flight? Or was that in your FOM/GOM? Not saying your company manual doesn't say what you said above, but by definition an empty "repo" flight that isn't scheduled service, and isn't operated for revenue, is not a flight governed by part 121...it falls under part 91. Also, when you (or a dispatcher) files a flight plan, pretty sure there is no spot to file something under either part 91 or part 121. It's just the type of operation being conducted that dictates under which CFRs it falls...i.e. revenue/scheduled flight (121) or nonrevenue "other" flight (91).
04-23-2019 | 05:16 PM
#92
Line Holder
Joined: Sep 2016
Posts: 1,165
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Which OpSpec discusses a part 121 repo flight? Or was that in your FOM/GOM? Not saying your company manual doesn't say what you said above, but by definition an empty "repo" flight that isn't scheduled service, and isn't operated for revenue, is not a flight governed by part 121...it falls under part 91. Also, when you (or a dispatcher) files a flight plan, pretty sure there is no spot to file something under either part 91 or part 121. It's just the type of operation being conducted that dictates under which CFRs it falls...i.e. revenue/scheduled flight (121) or nonrevenue "other" flight (91).
Edit: I will also go as far as check airmen conducting IOE. Dispatch will develop the release and file under part 121 so that a repo flight can count towards IOE part 121 flight time.
04-23-2019 | 05:19 PM
#93
New Hire
Joined: Jan 2014
Posts: 6
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I understand your take on the idea and it has me question what I see in the manual, but that doesn't change what's in the company operating manual that I just reviewed. So we'll agree to disagree. I can't think of a logical explanation of why the difference but it's there. We can do repo part 121.
04-23-2019 | 05:47 PM
#95
Line Holder
Joined: Sep 2016
Posts: 1,165
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I believe that most companies require MX/repo flights to be operated under the same rules of a normal revenue part 121 flight, particularly pertaining to company SOP, etc, etc. Thus most company manuals will be written to this end, but technically as per the FAA these flights are part 91.
04-23-2019 | 05:49 PM
#96
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Joined: Feb 2019
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04-23-2019 | 06:13 PM
#97
Covfefe
Joined: Jun 2015
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Yeah but at the same time check airmen here can use repo flight filed/developed (however we wanna play the semantics) under part 121 to count towards IOE. And I believe IOE part 121 hrs requirement is something the FAA pays attention to. If they're doing it wrong then ohhhhh boy!!
Why would they bother to put that ‘however’ part in there if any repo/ferry flight could just be deemed a part 121 flight as you say commutair can do and count toward the 25 hours? Maybe I’m missing something.
04-23-2019 | 06:44 PM
#98
Line Holder
Joined: Sep 2016
Posts: 1,165
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Interesting point you bring up. 121.434 says (3) The experience must be acquired in flight during operations under this part. However, in the case of an aircraft not previously used by the certificate holder in operations under this part, operating experience acquired in the aircraft during proving flights or ferry flights may be used to meet this requirement.
Why would they bother to put that ‘however’ part in there if any repo/ferry flight could just be deemed a part 121 flight as you say commutair can do and count toward the 25 hours? Maybe I’m missing something.
Why would they bother to put that ‘however’ part in there if any repo/ferry flight could just be deemed a part 121 flight as you say commutair can do and count toward the 25 hours? Maybe I’m missing something.
04-23-2019 | 07:26 PM
#99
Gets Weekends Off
Joined: Dec 2016
Posts: 478
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I wouldn't say the ultimatum though that its always 91 for repo flight. Several times I have done repo where dispatch filed it as 121 (flight number instead of tail number when talking with ATC, signing a release and getting a cargo load report and everything else that would go with a 121 revenue flight). We are authorized to do repo flights either under 91 or 121 but maintenance flights as part 91. Maybe that's the difference though, OpsSpecs.
04-23-2019 | 07:33 PM
#100
Gets Weekends Off
Joined: Aug 2013
Posts: 627
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From: FO
FWIW, 91k is closer to 135 than 91, but not the same. In many cases, 91K is more restrictive.
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