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Old 02-01-2014, 12:33 PM
  #1  
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Default Other commercial flying while working 121

So ignoring any imposed company requirements in any respective FOM, do the new 117 rest rules permit working commercially outside of working 121? The reason I ask is because I was reading the actual regs to clarify some things and under Part 117 for cumulative flight limits it says (117.23 (a))
"(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."

Under the old 121 regs it read like this (121.471)
"(a) No certificate holder conducting domestic operations may schedule any flight crewmember and no flight crewmember may accept an assignment for flight time in scheduled air transportation or in other commercial flying if that crewmember's total flight time in all commercial flying will exceed—"

So the question I have is, 91K program manger flying? What is that and what does it mean? And since the old regulations specifically mentioned "other commercial flying" as counting towards 121 limits and Part 117 does not say that, does that mean a 121 pilot can now instruct/do photo flights/whatever type of flying on the side? Short of making the "fit for duty/sleep opportunity" argument I think the answer is yes barring some other piece of the regs I haven't seen yet or companies specifically denying it.
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Old 02-01-2014, 12:39 PM
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91K is fractional ownership flying, so ANY flying under a "certificate" (121, 125, 135 or any flying where a commercial certificate is issued) plus any flying under a 91K is included for Part 117 duty limits. 91K technically isn't a certificate holder. But, instructing under Part 141 or Part 142 would count, I think.

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Old 02-01-2014, 03:11 PM
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Company requirements aside, you can do whatever you want in your off time, even during your rest period (check my reference and tell me I'm wrong) as long as you're adequately rested for your assignment. Just as long as it's not 121, 135, or 91K.

§117.3 Definitions.
Certificate holder means a person who holds or is required to hold an air carrier certificate or operating certificate issued under part 119 of this chapter.

Rest period means a continuous period determined prospectively during which the flightcrew member is free from all restraint by the certificate holder, including freedom from present responsibility for work should the occasion arise.

§119.1 Applicability specifically excludes pretty much all commercial flying activities you would be doing outside of a Part 135 or 121 operation.

For me, this is a spectacular change to the rules. I was ready to leave Part 121 because I want to have my logbook filled with more than shiny jet time. I still love to instruct, tow banners, give rides, ferry planes cross country, and all of the other things I used to build time for this job. Now I can. Well, that is, if the company will let me. I'm working on that.

"Do you have one thousand hours, or one thousand of the same hour?"
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