I am trying to wrap my head around 121.525 in regards to flying more than one type of flight crew.

Say I typically fly a 4 man flight crew, so under 3 pilots with an additonal crew member. I am then scheduled to fly two legs, under a two man flight crew. Then they have me scheduled to fly normal again afterwards, so 4 man.

How does 121.525 pertain to that scenario. Since I am interupted more once, two separate legs as a two man. Do I fall under two man regulations for 30 days, after the trip? Or do I fall under other regulations?

Thanks!

 

(b) The flight time limitations for a pilot who is scheduled for duty aloft for more than 20 hours in two-pilot crews in 30 consecutive days, or whose assignment in such a crew is interrupted more than once in any 30 consecutive days by assignment to a crew of two or more pilots and an additional flight crewmember, are those listed in §§ 121.503 through 121.509, as appropriate.

Duty aloft more than 100 hours in 30 days is needlessly complex but i suppose the administrator has its reasons. Additional flight crewmember opens the door for engineers and nav’s. Are there any left but on Herc/L100s that apply?

 

When you say "under three pilots," do you mean under the number of three pilots, as in less than three pilots and an additional crew member, or do you mean under the regulation for three pilots and an additional crewmember? If you mean under, as in less than, or three pilots (three-man crew), you're looking at 14 CFR 121.521, as opposed to three or more pilots and an additional crew member (four-man crew), 121.523.

The regulation starts with domestic rules, even when flying internationally; for supplemental operations, 121-503 through 121.509 apply, unless the company elects, in writing, to option the international regulations, under 121.513. This means that the company must put in writing that they'll be using international rules, and must communicate that to the crew at the time the flight is assigned. In that case, the company may elect (in writing) to use 121.515 through 121.525.

If your company is electing to use 121.515 through 121.525, then for three man crews, use 121.521, and four-man crew use 121.523. 121.525 covers mixing crew-compliments (numbers of crew members). In a nutshell: if you've operated in. more than one kind of crew in a 30 day period under international rules (121.513 through 121.525, as elected and communicated by your employer in writing in advance, and at the time of the flight), you're restricted to one of three options.

If you're operated 20 or more hours in a two-pilot crew in that 30 consecutive day time time frame, or had your crew compliment interrupted two more times by two-pilot crews, then you must operate under domestic 121.505, 121.507, or 121.509, until your 2-pilot time is no longer in the 30 day window. So if you just did the 2-pilot flight twice, yesterday, then you'll be restricted to domestic rules for the next 29 days. If you did the two-pilot thing 28 days ago, then you're restricted to domestic rules for two more days.

If you're operated 20 hours in a three-pilot crew, or been interrupted two or more times by operating in a three-pilot crew, then you're restricted to operating under 121.521. The employer may always choose to stick with the limitations of domestic flying, which is overly restrictive for international legs...but if the employer chooses in writing, to use international rules (121.513 through 121.525), int his case, the only options is 121.521.

Any other combination, and you'll be operating under 121.523, if your employer still wants to use international rules. The employer may always choose to stick with the limitations of domestic flying, which is overly restrictive for international legs...but if the employer chooses in writing, to use international rules (121.513 through 121.525), int his case, the only options is 121.523.

The basic flight, duty, and rest regulations are domestic, found in 121.503 through 121.509. There are restrictions with these rules, in terms of duty, flight time, and rest. These rules apply regardless of whether a flight is operated internationally, unless the company elects to use international rules (121.513). A company may elect to use international rules, which provide increased flight, duty, and rest times. In order to elect to use those rules, the company must notify the crew via the FOM, and at the time the trip is assigned, of the rules under which the flight is operating. If the crew is not notified, the default rules are domestic. There are no 2-pilot international crew regulations: 2-pilot crews always fall under domestic regulations. The biggest and most critical difference between domestic and international regulations is that the regulations do NOT permit flights over 8 hours, regardless of whether 2-pilot, -3-pilot, or 4-pilot crews. The company may fly pilots more than 8 hours, but not in a single leg. (There are only two exceptions: transcontinental flights with a flight engineer, and operations for which the company has specific authority granted by the FAA).

The company must advise pilots the duty, flight, and rest regulation under which they will be operating, and election to use international regulation, under 121.513 must be done in advance, and the crew must be notified. The crew cannot be expected to guess as to the flight, duty, and rest limitations and requirements being applied to them. This is a legal requirement imposed by an FAA Chief Legal Counsel Letter of Interpretation (MacPherson, 2012) (Byrne, 2003).

The Legal Counsel Interpretation states: “Therefore, a certificate holder may choose to operate international flights under either segment of the rules and is not required to make the election for all flights, so long as the election is clearly communicated when the flight or series of flights is scheduled.” (MacPherson, Letter to Whitaker, 2012)

A crew of 2 pilots is always under domestic flight and duty limitations. There is no provision under the regulation for international 2-pilot duty, rest and flight time (eg, 121.313-.325). (Peter, Letter to Enzer, 2015)

A 2-pilot crew may not be scheduled for a flight in excess of eight hours in length. Flying time of more than 8 hours is acceptable, but must have a rest period a or before the end of eight hours of flight time. The rest period must be a minimum of eight hours, up to twice the number of hours flown (eg, if six hours were flown, then 12 hours of rest is required). No leg may be more than 8 hours aloft (block time). (Bury, Smith Memorandum, 2013)

FAA Chief Legal Counsel legal interpretation published in the Federal Register (Federal Aviation Administration, 2015) specifies that 121.521 does not apply to two-pilot crews, which must use domestic regulation 14 CFR 121.503 and 121.505 (Peter, Letter to Enzer, 2015). 121.521 applies to three-pilot crews. The Enzer letter provides a full explanation. (An earlier interpretation, the Whitaker letter, stated that 121.521 applied to two pilot crews: this interpretation was reversed by the Enzer letter three years later).121.521 also applies to four pilot crews if a pilot has been assigned to a three-pilot crew for more than 20 hours in the previous 30 days (Bury, Letter to Osmudson, 2014). There are no supplemental international 2-pilot regulations.

Incidentally: 121.523 establishes a duty limit of 30 hours, and requires adequate sleeping quarters onboard if time aloft (block time) exceeds 12 hours in a 24 hour period (also triggers 16 hours rest after duty ends). 121.523 limits flight deck duty for Flight Engineers and Navigators to 12 hours (Peter, Letter to Enzer, 2015), but not flight time for pilots, and not flight deck duty time for pilots. (Peter, Letter to Dickson, 2015)

You may note that I've emphasized the lack of 2-pilot international supplemental regulation, several times; 121.521 is titled "two pilots and one additional airman as required," which does lead one to think it actually means two pilots. It does not, as noted above. There are no two-pilot international supplemental regulations, and two pilots fall under domestic regulations; having a schedule interrupted twice by domestic limitations, or 20 hours by domestic limitations, means that the company cannot choose to take advantage of the greater flight time and duty options of the international regulations. The company must continue using the pilot(s) under domestic rules until outside the 30-day window. This is designed to prevent the company from using 2-man crews, and then throwing them into situations that contribute to fatigue. Larger international crew compliments require onboard rest facilities and trigger other rest requirements, and divide workload among more crew, but the crew has already been exposed to operations that offer neither extra crew, or rest, or increased rest. The FAA allows the company to briefly use the crew for two-man operations up to 20 hours, or interrupting an augmented crew once, but if it exceeds 20 hours or happens more than once in that 30 day time frame, the FAA limits what the company can do with those crew. It's for the protection of the crew.

 

Thank you both for the replies. I should have been clearer in the original post. The 4 man crew legs will be operated under 121.523. As for the two man legs, it will be under 20 hours of duty time. The only limitation for that leg seems to be flight time under 8 hours.

If I am reading 121.525 correctly, it wouldn't apply since I am only interuppted once going from the 2 man to go back to 4 man.

Thanks again for all the help!

 

That is correct.