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ANTI-ICE ON
27th Dec 2023, 17:02
Greetings and Merry Christmas to all.

Not sure if this is the right place for this question, so please re-direct if not.

Part 135 states that the airplane used must have a maximum payload of 7,500 pounds or less.

If I got that rule right, how would one operate a heavier (ATR / 737 / A320) cargo aircraft in on demand cargo charter operation in the US ?
Is Part 121 the only other option available ?

Thank you in advance.

MarkerInbound
28th Dec 2023, 02:58
Yes, an on demand operation carrying more than 7500 falls under the Supplemental section of 121. The old 135 rules almost reverse engineered a DC-3 talking about 300 and some pounds of oil and how far they could fly carrying 7500 pounds. So Threes can operate under 135 but step up to a Super Three (there might be one left flying) and you have to move up to part 121. The FAA has an Advisory Circular 120-49A that has a few flow charts to figure out what rules an operation falls under.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_120-49A.pdf

ANTI-ICE ON
28th Dec 2023, 15:11
Thank you for your reply and for the document provided.
Excellent source of information.

I am surprised that on demand charter heavy cargo operations do not exist in the US.

Would you happen to know if appart from the required manuals, procedures, personnel and financial resources etc. required, the process of going from part 135 to 121 is relatively straightforward or a pain in the neck ?
Does the FAA actually support such "upgrades" or do they rather encourage one to go through the full process from scratch ?

Cheers.

MarkerInbound
29th Dec 2023, 03:33
I flew 38 years of on demand charter heavy cargo operations. A General Motors assembly plant finds out their supply of left front doors for the 800 vehicles they’re going to make that day didn’t show up overnight. They’ll call and start an airlift from the stamping plant 400 miles away. Some race horses need to get to their next race, they get an airplane. Internationally Formula One cars don’t drive from one race to the next, they fly. I can tell you that Madonna is a very material girl, it took two 747s to move her stage show around. The US Air Force doesn’t have near the lift capability to support US miles operations, they call civilian cargo companies, Companies like National Air Cargo, Western Global, Connie Kalitta and Atlas are all on demand charter heavy cargo operations. And there are smaller companies that carry more than 7500 pounds so they operate under 121 Supplemental rules.

I don’t quite understand the question about going from 135 to 121. For the pilots it’s a new set of rules and a bit more structure to the operations. Supplemental operators don’t have official Dispatchers with operational control over the flight. They have Flight Followers to prepare the paperwork and monitor the flight. But every 121 Supplemental carrier I know only hires folks with Dispatcher certificates as Flight Followers. The FAA required it at a job in the 80s and 90s and I imagine they still do at current operators. For the company it’s a different set of rules they have to comply with. When the DC-3 company wanted to grow into Super Threes they had to create a new operations manual and training manual to meet 121 standards. So one day in a Three you could fly a trip under VFR and just head that away and the next day in a Super Three it had to be an IFR flight plan with an alternate even if the destination was severe clear.

When you start an airline you have to create a compliance letter. The company explains how they meet the requirements of each section of the regulations. So to some extent the company is starting from scratch when they cross the line from 135 to 121.

ANTI-ICE ON
29th Dec 2023, 15:34
Much clearer now.
I thought that you had to change the rules under which you operate, from 135 to 121 (in other words to rebuild the business or "upgrade" it).
Now I get it, you keep your Part 135 certificate, but then apply to operate under Part 121 supplemental rules in order to accommodate larger aircraft.
Thanks a million.