135.243(a)(1) hours toward 121 upgrade
 

Hey All,


Hoping someone on here can help. I've seen this asked in various forms across the forums but haven't been able to find this specific situation so apologies in advance if this is a repeat question.


I have a CJO for a regional and was wonder about the applicable 135 time for upgrade. I don't really want that fast an upgrade but this regional uses it to calculate the bonus as well.


The way I read §135.243 Pilot in command qualifications. is that each of these items are mutually exclusive:

• 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 as defined in part 119 of this chapter

This would mean that if the aircraft is certified for 10 passengers, and flown in that configuration for 135 operations, it should count toward this time correct?


It would seem that in the "spirit" of this regulation, they are looking for operations requiring an ATP. However, the aircraft in question, which I have around 900hrs in, is a de Havilland DHC-3 Otter (Single Engine, both piston and turbine variants), which to my knowledge is one of the only, if not the only, aircraft certified in the US for more than 9 passengers under 135, that doesn't require an ATP.


So I'm wondering if anyone here has successfully used Single Otter DHC-3 time toward a 121 upgrade, and if so what carriers?




Thanks,
Dash3t

Probably need to write a letter to FAA legal in DC.

Reading the reg verbatim, you should be good, but the reg obviously *assumes* you had an ATP to do that. If you didn't actually have an ATP when you did the flying I could see a DPE stopping a checkride. Would be safer to get a definitive legal answer.

I’ve had the same question answered two different ways by two different outfits. I currently do not hold an ATP just a commercial. Time was as PIC of an aircraft which met the guidelines.

One said all my 135 time counted towards upgrade since the aircraft met the requirements. The other said that since I did not hold an ATP while obtaining that time, it will not count, even though the aircraft which I flew required a type rating (which the checkride is completed to ATP standards).

Didn’t exactly make sense to me, hours are hours after all. By that logic, it would be as if my total time obtained during my private or instrument wouldn’t count either. Some clarification on the regulation would be helpful.

Most aircraft like that have an STC that brings them back to 9 or less and most 135 companies operate them 9 or less. I know the Caravan is type certificated for something ridiculous like 14 people, but in commuter service most run 9 or less due to the difference in operating requirements. On-demand is different though. Once you go 10 or more, there are many more regulations that have to be complied with. Not sure how this all affects it, but those would be the issues I'd delve into for further research.

True, however the otter does not require that. It is allowed to operate with 10 passengers in commuter operations. This is why many of the Alaska operators and my company prefer them to the Caravan, because of that extra revenue seat.

I don't remember the specifics, but is something to do with them being type certified before the 9 pax rule was written i think. They are grandfathered in and allowed to operate with 10 pax without an ATP or second pilot. My company and several in Alaska do this as SOP.



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From a buddy that helped me out with this told me the rule is basically to prevent caravan and similar time from being used.

I have 1026hrs 135 PIC in a Hawker that counted