CREW CURRENCY RULES: SHARED REFERENCE

GOM §3.8.2 · §3.8.3 · §3.8.4 · §4.5.4 | Dolphin Atlantic, Inc. DBA Gold Aviation Services

Working reference for DO, Chief Pilot and Director of Safety

Why this exists. Rev-3 of the GOM rewrote four currency sections, and working through them turned up more regulatory nuance than any of us expected. This puts the whole picture in one place so we are all working from the same model rather than reconstructing it from an email chain.

Everything here traces to the CFR. Where we have made a Company choice rather than followed a rule, it says so. Where something is still open, it is flagged rather than smoothed over.

Amber = question

Grey = regulation

Green = established

Red = constraint

Blue = still to decide

The two rulebooks

start here

Part 61 is the rulebook for individual pilots: what any airman needs to fly. Part 135 is the rulebook for us as a charter operator: what the Company may and may not do. They overlap heavily on currency, in nearly identical words, and that overlap is where most of the confusion in this section lives.

61.57(e)(3) "This section does not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 135 when the pilot is engaged in a flight operation under parts 91 and 135 for that certificate holder if the pilot in command is in compliance with §§ 135.243 and 135.247."

What we established Four conditions, and our pilots meet all four on a company trip. 135.243 is what the pilot must hold (ATP plus type rating for our turbojets). 135.247 is what they must have recently done. Meet both and Part 61 steps aside; it is not a floor that Part 135 sits on top of.

Part 61 still applies to their flying outside the Company: their own airplane, someone else's, instructing.

Why Part 61 cannot serve as a backup route 135.247(a) opens: "No certificate holder may use any person, nor may any person serve, as pilot in command of an aircraft carrying passengers unless..."

Two prohibitions in one sentence. The pilot may not serve, and separately the Company may not use them. Most Part 61 currency rules bind only the pilot. This one binds the Company as well, so a pilot who misses 135.247 is not usable on a company trip regardless of Part 61 status.

Landing currency

§3.8.4 · 14 CFR 135.247

Praetor 600 (EMB-550): what a captain needs

Phenom 300/300E (EMB-505): what a captain needs

The practical consequence. Every Phenom captain needs three night takeoffs and landings, in the airplane, every 90 days. Nothing in the regulation relieves it, and nothing in Rev-3 changes it. This is the requirement the DO builds and rebuilds the training and trip schedule around.

The type certificate gate, and why it matters most

Established The alternative at 135.247(a)(3) reaches only "a pilot in command of a turbine-powered airplane that is type certificated for more than one pilot crewmember."

EMB-550 Praetor 600: requires two pilots. Qualifies.
EMB-505 Phenom 300/300E: the type certificate approves "a minimum crew of one pilot." Does not qualify.

None of this is new to us; the fleet distinction is well understood internally and the draft already limits paragraph C to multi-crew certificated airplanes. What following the thread surfaced is that the limitation is only visible if the reader already knows how the two types are certificated. A crew member reading paragraph C who has not thought about type certification could reasonably assume the alternative is open to them.

The manual should not assume that. Adding to §3.8.4 paragraph C:

"The EMB-550 is type certificated for more than one pilot crewmember. The EMB-505 is type certificated for single-pilot operation, and the alternative in this paragraph C is therefore not available to a pilot in command of the EMB-505."

Two sentences, no change to what the section requires. It just removes the step where a reader has to derive the answer from a type certificate they are unlikely to have in front of them.

The distinction that is easy to misread We do crew the Phenom with two pilots, and we are required to. That comes from 135.101 (no passengers under IFR without a second in command, unless the Company holds the autopilot authorization under 135.105). That is an operating rule about how we staff the flight.

It does not change the type certificate. Two-crew in practice, single-pilot on paper, and 135.247(a)(3) turns on the paper.

Consequence: no relief anywhere for the Phenom Not 135.247, for the reason above. Not Part 61 either, but not for the reason it might look: 61.57(e)(3) means Part 61's recent experience rules do not reach our PICs on company flying at all, so there is nothing there to fall back on. Worth knowing that Part 61 on its own is actually more permissive here, since 61.57(a)(3) and (b)(2) allow a simulator for day and night with no multi-crew condition. None of that is available to us, because 135.247 binds the Company directly and a pilot current under Part 61 still could not be used on a company trip without meeting it. Not a pilot certificate marked "SIC required," because that limits the pilot rather than the type certificate. Not crewing it two-pilot under 135.101, because that is an operating rule.

So a Phenom captain needs 3 takeoffs and 3 landings at night, every 90 days, in the airplane. No simulator, no alternative. As the regs currently stand. There are things in the works that could change this, none resolved yet, so we write to what is published today and revisit if that changes.

The simulator question, and where it actually landed

The question Rev-2 paragraph A allowed the 90-day takeoffs and landings "in the type aircraft (simulator)." 135.247(a)(1) says they must be in an aircraft. Where did the simulator permission come from?

What the training record shows FlightSafety certifies 135.247(a)(3)(ii)(D) on the Praetor curriculum. That is real, documented, and it is the basis for the simulator route already in the draft at item 4(ii).

It answers a different paragraph (a)(3)(ii)(D) is relief from (a)(2), night currency. Rev-2's "(simulator)" was in paragraph A, the 90-day day landings under (a)(1). There is no simulator provision anywhere in 135.247 for those.

So the original question is still open, and the working conclusion is that Rev-2 allowed simulator credit for day landings with nothing behind it. It has been left out of Rev-3. If anyone knows of an OpSpec or training program provision covering it, that would close the question. Otherwise we treat it as settled.

Thinking ahead to the next audit (ii)(D) says the approved training program "must have required, and the pilot must have performed" the 6 night takeoffs and landings. So the curriculum has to mandate them, not just the pilot happening to fly them in a session.

A Part 142 provider ticking that box implies their curriculum does, and it almost certainly does. But the document that proves it is the curriculum, not the training record. Our own approved training program may also carry it, if it specifies the Part 142 course content, though the approval the rule points to is the provider’s. Worth knowing which document we would reach for before someone asks.

Other changes to §3.8.4, and why

Change	Reason
Dropped 61.57 from the reference line	61.57(e)(3). On company flying it steps aside, so 135.247 is the governing rule.
Removed "scheduled air transportation"	Scheduled means a published timetable. We are on-demand, so as written the requirement arguably never triggered.
Added "carrying passengers"	That is the actual trigger in 135.247(a). Without it the manual gated empty repositioning legs, which the reg does not.
Narrowed "PIC or SIC" to pilot in command	135.247 is PIC only. This was already removed in the draft that went out; the question was only whether to add an SIC standard back as Company policy. Confirmed we do not want one, day or night.
Removed "to a full stop" from B	135.247(a)(2) has no full stop qualifier. Full stop is 61.57(b), which does not reach company flying. See the open decision below.
Added the relief sentence to B	135.247(a)(2) provides that night landings also satisfy the day requirement. Rev-2 omitted it, so the manual read as six landings every 90 days instead of three.
Removed the Part 142 school gate from C	See below. The Part 142 requirement itself was not removed.
Added the commercial certificate condition to C	The rule bundles the certificate and ratings with the 1,500 hours. Rev-2 stated only the hours, so the manual gave half the eligibility test.
Fixed the item 2 cross-reference	Rev-2 pointed at "item 1," the 1,500 hours. The rule is about day currency, so it now points at paragraph A.
Added paragraph-level citations	Each requirement can now be checked against its exact subparagraph. "Of this section" added where the text points at paragraph A or B, so GOM paragraphs are not confused with CFR ones.

The Part 142 reference, since this one reads worse than it is

What Rev-2 said "C. An alternative method of compliance, if a pilot has attended a part 142 school within the preceding 6 months and meets the following requirements: ... 4. Within the preceding 12 months prior to the month of the flight, the pilot must have completed the Dolphin Atlantic, Inc. training program under an approved 142 vendor..."

What changed The Part 142 requirement is still there, at item 4(ii), with the 12-month window the rule specifies at 135.247(a)(3)(ii)(D). Nothing was lost.

What came out was the opening line, which gated the whole alternative behind a 6-month Part 142 window. That condition is not in the rule, and it contradicted Rev-2's own item 4 two paragraphs later, which said 12 months. It looks like the 6-month window from route (i) got merged with the Part 142 program from route (ii).

The three checks, and which ones rotate

§3.8.1 · §3.8.2 · §3.8.3

Rule	What it is	How often	Airplane rule
135.293	Competency check	12 calendar months	Type specific for jets. Does not rotate. A Praetor check does not cover the Phenom.
135.297	Instrument proficiency check	6 calendar months	Rotates. A pilot on both types alternates, one check per period, and the current check covers both.
135.299	Line check	12 calendar months	One of the types the pilot flies, not each.

Where the confusion came from

Rev-2 section	What it said	Verdict
135.293	"a competency check under 14 CFR Part 135.293 for the aircraft to which they are assigned"	Correct
135.297	"a competency check under 14 CFR Part 135.297 for the in the same make and model"	Wrong name, wrong limit
135.299	"a competency check under 14 CFR Part 135.299 for the aircraft to which they are assigned"	Wrong name, wrong limit

The 135.293 sentence is right: 135.293 is the competency check and it is type specific for jets. The other two are that same sentence with the regulation number swapped and nothing else changed. They inherited both the name and the airplane restriction, neither of which belongs on 297 or 299. The 297 line even reads "for the in the same make and model," with a stranded "the," which looks like an edit someone started and abandoned. One correct sentence became a template for two wrong ones.

§3.8.2 rotation, in detail

135.297, the relevant paragraphs (a) "...unless, since the beginning of the 6th calendar month before that service, that pilot has passed an instrument proficiency check..."

(d) "If the pilot in command is assigned to pilot only one type of aircraft, that pilot must take the instrument proficiency check ... in that type of aircraft."

(e) "If the pilot in command is assigned to pilot more than one type of aircraft, that pilot must take the instrument proficiency check ... in each type of aircraft to which that pilot is assigned, in rotation, but not more than one flight check during each period described in paragraph (a) of this section."

What "period" means, and how the rotation works "Each period described in paragraph (a)" is the six calendar month cycle. So the rule is one instrument check every six months, alternating types, not one in each type every six months.

Why the current check must cover both types. (e) expressly bars more than one flight check per period. If a Praetor check did not cover Phenom flying, a pilot assigned to both types could never be legal on both at the same time, because they are prohibited from taking two checks in a period. The rotation provision would defeat itself. The only reading that works is that the most recent check covers every type the pilot is assigned to.

A pilot assigned to only one type is a different case: 135.297(d), check in that type.

Worth confirming Does this match how we have actually been scheduling? And does our approved training program say anything more restrictive? Under 135.21(a) we must follow our own accepted program, so if it is stricter than 135.297(e), the program governs and the GOM should say so.

Training on non-trip days

new §4.5.4

What we are trying to achieve Cover training scheduled on days a pilot is not flying a trip, without creating a conflict with the rest requirements. The operational need is real: training slots are fixed well in advance and the charter schedule moves constantly, so training frequently has to land on a day the pilot would otherwise be off.

The draft as it stands A. Recurrent ground and flight training and required checks may be scheduled on a day a pilot is not assigned to a trip, provided the assignment does not encroach on a required rest period.

B. A day on which a pilot is assigned a training event does not count toward the 13 rest periods of at least 24 consecutive hours each per calendar quarter required by 14 CFR 135.267(f).

Why B is there 135.267(f) requires the Company to provide each flight crewmember at least 13 rest periods of at least 24 consecutive hours each in each calendar quarter.

GOM §4.5.1 already states that a rest period is "free of all forms of duty and company responsibility." Training is duty. Without B, training assigned to one of the 13 protected days would breach both the regulation and our own manual, and nothing in the system would flag it.

The proposed addition, and the two things to work out

Proposed wording (German) "A pilot may be assigned to training while on an OFF-Duty day as a last resort. At the pilot's request, a change in date may be requested, and the company may consider if and when circumstances allow the rescheduling. If a training event is rescheduled at the pilot's request, the subsequent training date becomes unmovable."

"Off-duty day" is not a defined term The GOM defines rest period (§4.5.1) but not "off-duty day," so the wording does not tell us which days it reaches.

If it means any day a pilot is not assigned a trip, paragraph A already permits training on those days and no new wording is needed.

If it includes the 13 protected rest periods, then assigning training to one puts us crossways with 135.267(f) and with §4.5.1. That is the one line the GOM needs to hold, and it is all paragraph B is doing.

Suggested fix: use "a day a pilot is not assigned to a trip" in the GOM, which is unambiguous, and keep "day off" language in the CPP where it can carry its employment meaning.

The rescheduling terms are a work rule, and belong in the CPP Requesting a date change, the Company considering it, the second date being fixed: none of that is an operating procedure. It is an agreement between the Company and the pilot about how training assignments are handled, which is the definition of a work rule.

Three reasons it sits better in the CPP:

1. That is where a pilot would look. Nobody reads the GOM to find out whether they can move a training date. They read the work rules.

2. It can be revised without an FAA-facing change. The GOM is an accepted manual; changing it means a revision cycle and POI coordination. The CPP is Company-controlled, so if the rescheduling practice needs adjusting after a few months of real use, that is a quick change rather than a manual revision.

3. It keeps the GOM to the regulatory "what." The GOM says training may be scheduled on non-trip days and must not encroach on required rest. The CPP says how a pilot requests a change and what happens when they do. Clean split, and it matches how we have handled this elsewhere.

Suggested CPP language, for discussion: "Where a training event is assigned on a day the pilot is not scheduled to fly, the pilot may request a change of date. The Company will consider the request and reschedule where operational circumstances allow. Where a training event is rescheduled at the pilot's request, the rescheduled date is fixed and further changes will not be accommodated except in exceptional circumstances."

The GOM would then keep paragraphs A and B as drafted, with no cross-reference to the CPP, since the GOM does not name the CPP.

Still to decide

Item	Options
§3.8.4 item 4, which routes to document	Both (i) and (ii), or (ii) only. The reg allows either for the Praetor. Both routes are in the draft. Listing only the Part 142 route would make the Manual stricter than the regulation, and under 135.21(a) the Company would then be bound by the narrower version, so a pilot who genuinely met the real-airplane route would be unusable on Company paperwork for no regulatory reason.
§3.8.4 paragraph B, full stop	Leave it out to match 135.247(a)(2), or restore it. If we restore it, it should read as a Company standard rather than a regulatory requirement, since 61.57 does not reach company flying. (If it is a Company choice rather than a reg, it may sit better in the CPP than the GOM, same logic as the 4.5.4 rescheduling terms. Worth a view on that.)
§4.5.4, where the scheduling terms live	All in the GOM, or GOM protects the rest periods and the CPP carries the rescheduling terms.
Training program vs 135.297(e)	Does the approved program say anything stricter on rotation? If so it governs under 135.21(a).
(ii)(D) curriculum evidence	Which document evidences that the Part 142 program required the 6 night landings, the provider curriculum or our own approved training program? Low risk, but the training record alone does not prove it.
Day-landing simulator basis	Rev-2 allowed it in paragraph A with no source found. Left out of Rev-3. Closes if anyone can point to an OpSpec or training program provision.
Lou's project	The phrase "representative of a turbine-powered airplane that requires more than one pilot crewmember" sits inside (ii)(D), the route we rely on. Holding current wording until it resolves.

Phenom night currency: not a manual problem

worth stating plainly

The constraint, restated Every Phenom captain needs 3 takeoffs and 3 landings at night, in the airplane, every 90 days. No simulator credit, no alternative, no Part 61 fallback. The regulation offers nothing.

And it is being complied with This is tracked and scheduled today, and it lands squarely on the DO to build and rebuild around a charter schedule that moves constantly. Fixed currency deadlines against a moving trip schedule is a genuinely difficult planning problem, and it is worth recording that the compliance here is the result of active work rather than something the flying happens to produce on its own.

Nothing in the Rev-3 rewrite changes this requirement. The manual was never the constraint; the regulation is.

Where the manual could actually help Two things worth considering, neither urgent:

Visibility. If night currency status per Phenom captain were surfaced somewhere scheduling can see it at a glance, the rebuilds would at least start from a clear picture. That is a tooling question rather than a manual one.

Documenting the practice. Currency is tracked and scheduled today. What the GOM does not do is say so. Oregon Sunstone's manual, for comparison, names a quarterly review by the Director of Operations. A short statement of how currency is monitored would put the existing practice on the record for a POI, without changing anything the operation already does. Rev-4 candidate.

Dolphin Atlantic, Inc. DBA Gold Aviation Services | Working reference | Not a controlled document