Face to Face interview
04-23-2019 | 08:21 PM
#101
Covfefe
Joined: Jun 2015
Posts: 3,001
Likes: 0
In a somewhat related question to the FAA, someone asked for an LOI about whether experience in non 121 flights at 121 carriers can be used for the 1,000 hours of 121 SIC to upgrade. Link Here's the answer:
"only those flight hours accrued during operations conducted under the operating rules of part 121 may be credited. This means that flight time accrued during operations conducted under the operating rules of part 91, including repositioning flights and flight training conducted in a flight simulation training device are not considered operations under part 121 for purposes of satisfying the
§ 121.436(a)(3) experience prerequisite...."
Since this interpretation uses the exact same verbiage as the OE verbiage "operations under this part," I'm willing to bet the FAA would say repo flights can't be counted toward required OE time.
Now if someone can show me how an empty/non-rev repo flight can be operated under part 121, my mind might be changed. I've used all my google-fu tricks and can't find it.
04-24-2019 | 03:09 AM
#102
Line Holder
Joined: Sep 2016
Posts: 1,165
Likes: 38
I still don't think an empty repo/non-revenue flight can ever be considered an operation under part 121. I can't find anything that says it can be, nor any examples or references of it happening that way.
In a somewhat related question to the FAA, someone asked for an LOI about whether experience in non 121 flights at 121 carriers can be used for the 1,000 hours of 121 SIC to upgrade. Link Here's the answer:
"only those flight hours accrued during operations conducted under the operating rules of part 121 may be credited. This means that flight time accrued during operations conducted under the operating rules of part 91, including repositioning flights and flight training conducted in a flight simulation training device are not considered operations under part 121 for purposes of satisfying the
§ 121.436(a)(3) experience prerequisite...."
Since this interpretation uses the exact same verbiage as the OE verbiage "operations under this part," I'm willing to bet the FAA would say repo flights can't be counted toward required OE time.
Now if someone can show me how an empty/non-rev repo flight can be operated under part 121, my mind might be changed. I've used all my google-fu tricks and can't find it.
In a somewhat related question to the FAA, someone asked for an LOI about whether experience in non 121 flights at 121 carriers can be used for the 1,000 hours of 121 SIC to upgrade. Link Here's the answer:
"only those flight hours accrued during operations conducted under the operating rules of part 121 may be credited. This means that flight time accrued during operations conducted under the operating rules of part 91, including repositioning flights and flight training conducted in a flight simulation training device are not considered operations under part 121 for purposes of satisfying the
§ 121.436(a)(3) experience prerequisite...."
Since this interpretation uses the exact same verbiage as the OE verbiage "operations under this part," I'm willing to bet the FAA would say repo flights can't be counted toward required OE time.
Now if someone can show me how an empty/non-rev repo flight can be operated under part 121, my mind might be changed. I've used all my google-fu tricks and can't find it.
04-24-2019 | 04:49 AM
#103
facing forward
Joined: Sep 2006
Posts: 290
Likes: 0
From: forward facing stick actuator
Face to Face interview
I still don't think an empty repo/non-revenue flight can ever be considered an operation under part 121. I can't find anything that says it can be, nor any examples or references of it happening that way.
In a somewhat related question to the FAA, someone asked for an LOI about whether experience in non 121 flights at 121 carriers can be used for the 1,000 hours of 121 SIC to upgrade. Link Here's the answer:
"only those flight hours accrued during operations conducted under the operating rules of part 121 may be credited. This means that flight time accrued during operations conducted under the operating rules of part 91, including repositioning flights and flight training conducted in a flight simulation training device are not considered operations under part 121 for purposes of satisfying the
§ 121.436(a)(3) experience prerequisite...."
Since this interpretation uses the exact same verbiage as the OE verbiage "operations under this part," I'm willing to bet the FAA would say repo flights can't be counted toward required OE time.
Now if someone can show me how an empty/non-rev repo flight can be operated under part 121, my mind might be changed. I've used all my google-fu tricks and can't find it.
In a somewhat related question to the FAA, someone asked for an LOI about whether experience in non 121 flights at 121 carriers can be used for the 1,000 hours of 121 SIC to upgrade. Link Here's the answer:
"only those flight hours accrued during operations conducted under the operating rules of part 121 may be credited. This means that flight time accrued during operations conducted under the operating rules of part 91, including repositioning flights and flight training conducted in a flight simulation training device are not considered operations under part 121 for purposes of satisfying the
§ 121.436(a)(3) experience prerequisite...."
Since this interpretation uses the exact same verbiage as the OE verbiage "operations under this part," I'm willing to bet the FAA would say repo flights can't be counted toward required OE time.
Now if someone can show me how an empty/non-rev repo flight can be operated under part 121, my mind might be changed. I've used all my google-fu tricks and can't find it.
In my personal opinion it will depend on the flight release and flight number. In my personal experience airlines use specific number ranges for types of flights. While most repo flights will be under 91 regs but rest and duty can still be controlled by 117/121 if specified in a CBA or company policies.
In the past at previous carriers I have operated planes empty under 121 with a live flight number and a 121 release to just help completion factor numbers and to get the plane in position for originator the next am.
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04-24-2019 | 05:22 AM
#104
Gets Weekends Off
Joined: Dec 2016
Posts: 478
Likes: 0
I still don't think an empty repo/non-revenue flight can ever be considered an operation under part 121. I can't find anything that says it can be, nor any examples or references of it happening that way.
In a somewhat related question to the FAA, someone asked for an LOI about whether experience in non 121 flights at 121 carriers can be used for the 1,000 hours of 121 SIC to upgrade. Link Here's the answer:
"only those flight hours accrued during operations conducted under the operating rules of part 121 may be credited. This means that flight time accrued during operations conducted under the operating rules of part 91, including repositioning flights and flight training conducted in a flight simulation training device are not considered operations under part 121 for purposes of satisfying the
§ 121.436(a)(3) experience prerequisite...."
Since this interpretation uses the exact same verbiage as the OE verbiage "operations under this part," I'm willing to bet the FAA would say repo flights can't be counted toward required OE time.
Now if someone can show me how an empty/non-rev repo flight can be operated under part 121, my mind might be changed. I've used all my google-fu tricks and can't find it.
In a somewhat related question to the FAA, someone asked for an LOI about whether experience in non 121 flights at 121 carriers can be used for the 1,000 hours of 121 SIC to upgrade. Link Here's the answer:
"only those flight hours accrued during operations conducted under the operating rules of part 121 may be credited. This means that flight time accrued during operations conducted under the operating rules of part 91, including repositioning flights and flight training conducted in a flight simulation training device are not considered operations under part 121 for purposes of satisfying the
§ 121.436(a)(3) experience prerequisite...."
Since this interpretation uses the exact same verbiage as the OE verbiage "operations under this part," I'm willing to bet the FAA would say repo flights can't be counted toward required OE time.
Now if someone can show me how an empty/non-rev repo flight can be operated under part 121, my mind might be changed. I've used all my google-fu tricks and can't find it.
04-24-2019 | 05:30 AM
#105
facing forward
Joined: Sep 2006
Posts: 290
Likes: 0
From: forward facing stick actuator
I’ve been on a delta repo flights without FA’s. As it was explained to me they can take OAL jumpseaters = number jumpseats in the cockpit and delta non rev employees in the back not to exceed a total of 19 peeps. After 19 you have to have FA’s.
I think the takeaway is there is no hard and fast rules. Each situation is unique and it may be 91 or 121.
Sent from my iPhone using Tapatalk
I think the takeaway is there is no hard and fast rules. Each situation is unique and it may be 91 or 121.
Sent from my iPhone using Tapatalk
04-24-2019 | 05:39 AM
#106
New Hire
Joined: Jan 2014
Posts: 6
Likes: 0
As stated above there is zero evidence in any of the regs that would provide the verbiage for non-scheduled repo flights to be considered part 121. An empty flight operating 24 hours late between two regularly serviced airports with a live flight number would qualify. But a random repo does not. Likewise MX ferry flights most certainly are part 91. Airlines might pretend they are 121 but according to the FAA language they are not...
04-24-2019 | 05:53 AM
#107
Covfefe
Joined: Jun 2015
Posts: 3,001
Likes: 0
That’s correct...any non revenue passengers the company allows can fly on it since it’s part 91 (which is also why revenue passengers cannot legally fly on it). 1.34.2 in JB’s FOM discusses it (the pt 91 operations section), and opspec A001.d is what allows it. At the end of the day it’s kind of semantics and probably doesn’t matter that much, sorry this thread’s drifted into a semantics discussion.
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