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View Full Version : Reg 206 (1) C = FAR Part 135?


flying-spike
11th Sep 2018, 10:04
Has anybody had hours as PIC hours under CAR 206 (1) recognised as equivalent to FAR Part 135 for the purpose of credit toward the 1,000 required for PIC under Part 121?

havick
11th Sep 2018, 22:27
Has anybody had hours as PIC hours under CAR 206 (1) recognised as equivalent to FAR Part 135 for the purpose of credit toward the 1,000 required for PIC under Part 121?

Doesnít work that way. FAA is very prescriptive and hours must be flown under an FAA certificate for them to count for uograde.

flying-spike
12th Sep 2018, 03:34
Doesnít work that way. FAA is very prescriptive and hours must be flown under an FAA certificate for them to count for uograde.
cheers, thanks.

LeadSled
12th Sep 2018, 07:14
cheers, thanks.

Flying spike,
That doesn't sound right to me, based on experience, some time ago.
FAA recognised ALL my hours, not just flying on commercial operations, but this was some time ago.
The answer you have got, so far, implies that only hours flown on an FAA license count for the purposes of an ATR, or flying as a co-pilot on an RPT operation.
Check with the FAA is the only real answer.
Tootle pip!!

VH DSJ
12th Sep 2018, 08:18
This is the relevant CFR to which this regulation applies. I was also told by an FAA check airman that the hours which applies to this regulation had to be accrued under the FAA license. The key phrase in the regs below is 'operations under this part/chapter' which I assume means 'under an FAA license'.

14 CFR 121.436 - Pilot Qualification: Certificates and experience requirements.
ß 121.436 Pilot Qualification: Certificates and experience requirements.
(a) No certificate holder may use nor may any pilot act as pilot in command of an aircraft (or as second in command of an aircraft in a flag or supplemental operation that requires three or more pilots) unless the pilot:(1) Holds an airline transport pilot certificate not subject to the limitations in ß 61.167 of this chapter;
(2) Holds an appropriate aircraft type rating for the aircraft being flown; and
(3) If serving as pilot in command in part 121 operations, has 1,000 hours as second in command in operations under this part, pilot in command in operations under ß 91.1053(a)(2)(i) of this chapter, pilot in command in operations under ß 135.243(a)(1) of this chapter, or any combination thereof. For those pilots who are employed as pilot in command in part 121 operations on July 31, 2013, compliance with the requirements of this paragraph (a)(3) is not required.

(b) No certificate holder may use nor may any pilot act as second in command unless the pilot holds an airline transport pilot certificate and an appropriate aircraft type rating for the aircraft being flown. A second-in-command type rating obtained under ß 61.55 does not satisfy the requirements of this section.

(c) For the purpose of satisfying the flight hour requirement in paragraph (a)(3) of this section, a pilot may credit 500 hours of military flight time obtained as pilot in command of a multiengine turbine-powered, fixed-wing airplane in an operation requiring more than one pilot.

(d) Compliance with the requirements of this section is required by August 1, 2013. However, for those pilots who are employed as second in command in part 121 operations on July 31, 2013, compliance with the type rating requirement in paragraph (b) of this section is not required until January 1, 2016.

https://www.law.cornell.edu/cfr/text/14/121.436

chimbu warrior
12th Sep 2018, 10:21
If serving as pilot in command in part 121 operations, has 1,000 hours as second in command in operations under this part

USA is not the only country that has Part 121. NZ does, PNG does, and someday Australia will.

stillcallozhome
12th Sep 2018, 13:16
It 100% has to be 1000 hrs on a FAA Part 121 AOC.

havick
12th Sep 2018, 15:02
USA is not the only country that has Part 121. NZ does, PNG does, and someday Australia will.

what do you think ďunder this partĒ
means? Itís literal. Itís refering to the part/subsection of the FARís, not some other countries regs.

i donít see how you can comprehend it any other way.

flying-spike
13th Sep 2018, 03:35
It would be nice if it was recognised but I agree that 12 or so months in the right seat would be better value than a couple of thousand hours Chieftain I did years ago. Thanks guys

LeadSled
13th Sep 2018, 08:31
It would be nice if it was recognised but I agree that 12 or so months in the right seat would be better value than a couple of thousand hours Chieftain I did years ago. Thanks guys




Flying Spike,,
As I said before, check with a convenient FISDO, if possible. Also check with any prospective employer.

In recognition of foreign experience, the practical answer is what FAA will recognise as satisfying the reg. quoted above, the reg. is not new.

Quite a number of Australian pilots, in recent years, have taken up employment with Regional/Commuter carriers in US based on foreign experience verified to the satisfaction of FAA. Several have actually sent recruiters to Australia. If nil non- US hours counted, such programs would not work.

Those I know have had to do the ATR examinations, have a Class I medical, and pass a (in our terms) APC/IPC, plus all the usual security clearances and holding the appropriate visa/green card. FAA-wise, the result is the issue of a ATR/Multi/Land/Instrument set of paperwork and license.

The progress from the RHS to command has been rapid, such is the turnover on seniority lists of small carriers.

Tootle pip!!

PS1: The people I have personally known have all had at least 1500 hr multi command time, not just 1500 hr. total or command.

PS: All RPT "commuter" operations in the US work under Part 121. Part 135 is (almost) exclusively "air taxi".

stillcallozhome
13th Sep 2018, 09:43
Flying Spike,,
As I said before, check with a convenient FISDO, if possible. Also check with any prospective employer.

In recognition of foreign experience, the practical answer is what FAA will recognise as satisfying the reg. quoted above, the reg. is not new.

Quite a number of Australian pilots, in recent years, have taken up employment with Regional/Commuter carriers in US based on foreign experience verified to the satisfaction of FAA. Several have actually sent recruiters to Australia. If nil non- US hours counted, such programs would not work.

Those I know have had to do the ATR examinations, have a Class I medical, and pass a (in our terms) APC/IPC, plus all the usual security clearances and holding the appropriate visa/green card. FAA-wise, the result is the issue of a ATR/Multi/Land/Instrument set of paperwork and license.

The progress from the RHS to command has been rapid, such is the turnover on seniority lists of small carriers.

Tootle pip!!

PS1: The people I have personally known have all had at least 1500 hr multi command time, not just 1500 hr. total or command.

PS: All RPT "commuter" operations in the US work under Part 121. Part 135 is (almost) exclusively "air taxi".

I think you're talking about something different. As you have said, all your hours accumulated outside of the USA will be recognised there in the USA. But, the requirement of 1000hrs Part 121 time HAS to be under FAR Part 121 ie. A carrier flying 121 under a FAA issued AOC.

Most airlines know this as they have a POI that tells them. I had 2 guys in my class a couple years ago with thousands of hours flying a range of Boeing aircraft and were told immediate upgrades but unfortunately the FAA ruled otherwise.

Easy to get though - 13-14 months once IOE starts. Best of luck!

flying-spike
13th Sep 2018, 11:01
I think you're talking about something different. As you have said, all your hours accumulated outside of the USA will be recognised there in the USA. But, the requirement of 1000hrs Part 121 time HAS to be under FAR Part 121 ie. A carrier flying 121 under a FAA issued AOC.

Most airlines know this as they have a POI that tells them. I had 2 guys in my class a couple years ago with thousands of hours flying a range of Boeing aircraft and were told immediate upgrades but unfortunately the FAA ruled otherwise.

Easy to get though - 13-14 months once IOE starts. Best of luck!
Thanks for the responses. PIC of Part 135 operations (even in a Chieftain) can be used as credit towards the 1,000 required for Part 121 PIC but it is U.S. Part 135. Not saying I should get an immediate command upgrade but as the supply screws get tightened the FAA might get more flexible. That might even be an incentive to a few that turn their noses up at Reg 206 in a piston twin.

havick
13th Sep 2018, 13:53
Flying Spike,,
As I said before, check with a convenient FISDO, if possible. Also check with any prospective employer.

In recognition of foreign experience, the practical answer is what FAA will recognise as satisfying the reg. quoted above, the reg. is not new.

Quite a number of Australian pilots, in recent years, have taken up employment with Regional/Commuter carriers in US based on foreign experience verified to the satisfaction of FAA. Several have actually sent recruiters to Australia. If nil non- US hours counted, such programs would not work.

Those I know have had to do the ATR examinations, have a Class I medical, and pass a (in our terms) APC/IPC, plus all the usual security clearances and holding the appropriate visa/green card. FAA-wise, the result is the issue of a ATR/Multi/Land/Instrument set of paperwork and license.

The progress from the RHS to command has been rapid, such is the turnover on seniority lists of small carriers.

Tootle pip!!

PS1: The people I have personally known have all had at least 1500 hr multi command time, not just 1500 hr. total or command.

PS: All RPT "commuter" operations in the US work under Part 121. Part 135 is (almost) exclusively "air taxi".

leadsled sorry youíre wrong. His hours count towards gaining an FAA license but they donít count towards an upgrade at a regional (part 121 operator).

Power
13th Sep 2018, 16:07
Spike maybe you should actually start at the airline first before worrying about a command ? I have seen a lot of older pilots join my airline (US regional) in the last year who have washed out in training, they just couldn't keep up. To suggest that some chieftain time will enable you a quick jet command upgrade is ludicrous, upgrade times are at about 12-18 months now anyway so it's not a long wait. The regs are black and white, you need 1000 hours in the right hand seat under part 121 operations before you are eligible to make the move to the LHS.

flying-spike
14th Sep 2018, 01:59
Spike maybe you should actually start at the airline first before worrying about a command ? I have seen a lot of older pilots join my airline (US regional) in the last year who have washed out in training, they just couldn't keep up. To suggest that some chieftain time will enable you a quick jet command upgrade is ludicrous, upgrade times are at about 12-18 months now anyway so it's not a long wait. The regs are black and white, you need 1000 hours in the right hand seat under part 121 operations before you are eligible to make the move to the LHS.
Gee, thanks power, I have never made the contention the Chieftain time will enable me to get a quick jet command. If you read ny posts you will see that I have commented that I see 1000 hours in the right seat to be a better grounding for upgrade.

The regs Are black and white but there is als a bit of grey that you have neglected to cite and that is the ability to use part 135 PIC time also to go towards the 1000 hours. (Also in my posts, and an interpretation attached). My concern is that, as supply shrinks, there will be a push to have pilots upgrade before they are ready.

I have no illusion that it will not be a steep learning curve for me, but I relish the challenge.

havick
14th Sep 2018, 04:02
Gee, thanks power, I have never made the contention the Chieftain time will enable me to get a quick jet command. If you read ny posts you will see that I have commented that I see 1000 hours in the right seat to be a better grounding for upgrade.

The regs Are black and white but there is als a bit of grey that you have neglected to cite and that is the ability to use part 135 PIC time also to go towards the 1000 hours. (Also in my posts, and an interpretation attached). My concern is that, as supply shrinks, there will be a push to have pilots upgrade before they are ready.

I have no illusion that it will not be a steep learning curve for me, but I relish the challenge.

Part 135 time under an FAA AOC.

Not to mention the regs are hardly grey at all. They are very black and white and stipulate what Part 135 flying can and canít be counted.

LeadSled
15th Sep 2018, 01:46
havic, stillcallozhome,
Agreed, I was looking more broadly, not at the specific 1000h
Just a guess, but given the severity of the pilot shortage, and the number of "commuter" aircraft backed against the fence, I would be most surprised if there were not a few FAA concessions floating around.
Tootle pip!!

havick
15th Sep 2018, 02:41
havic, stillcallozhome,
Agreed, I was looking more broadly, not at the specific 1000h
Just a guess, but given the severity of the pilot shortage, and the number of "commuter" aircraft backed against the fence, I would be most surprised if there were not a few FAA concessions floating around.
Tootle pip!!

no there are none, and wonít be.

LeadSled
15th Sep 2018, 03:57
no there are none, and wonít be.
Havick,
Given the very broad rule-making (and breaking via determinations) powers of the Administrator, and based on many years experience, I wouldn't bet on it.
After all, this whole rule only came about as a result of political pressure, not the usual rule-making process.
Tootle pip!!