Johnson-ALPA 2009

Page 1

U.S. Deportment of Transportation Federal Aviation Administration MAR 1 1 2009 Office of the Chief Counsel Air Line Pilots Association, International James W. Johnson 535 Herndon Parkway P.O. Box 1169 Herndon, VA 20172- 1169

Dear Mr. Johnson:

800 Independence Ave .. S.W.

Washington. D.C. 20591 This is in response to your November 4, 2008, request for information regarding appropriate procedures for documenting "other commercial flying" as addressed in Information for Operators (InFO) 08015, dated March 21, 2008.

As noted in the InFO, time spent conducting other commercial flying must be included in a flight crewmember' s total flight time to determine whether he or she has exceeded the flight time limitations established in parts 121 and 135. The InFO advised the directors of safety and operation to ensure that their manuals provided instruction and information to their flight crewmembers regarding reporting other commercial flying, and that a process was in place to ensure that other commercial flying time is recorded in the air carrier's records. You question whether documenting other commercial ilight time, as recorded by a pilot in his or her logbook, in the air carrier's records, is an appropriate means to address this issue. The FAA has determined that this is one appropriate method for monitoring a flight crewmember's other commercial flying time.

We appreciate your patience and trust that the above responds to your concerns. If you need further assistance, please contact my staff at (202) 267-3073. This response was prepared by Anne Bechdolt, Acting Manager of the Operations Law Branch of the Regulations Division of the Office of the Chief Counsel, and.coordinated with the Air Transportation Division of Flight Standards Service.

'Sincerely, Re~ct.::n JIJz-- Assistant Chief Counsel for Regulations, AGC-200