Legal Interpretations
Johnson-ALPA 2009
Summary
The Question
Is recording a pilot's logbook-documented other commercial flight time in the air carrier's records an appropriate way to account for other commercial flying?
Background
InFO 08015 said other commercial flying counts toward flight time limits and advised carriers to have a process for recording it in their records. The Air Line Pilots Association asked about appropriate procedures for documenting that flying.
The FAA’s Interpretation
Yes. Time spent conducting other commercial flying must be included in a flight crewmember's total flight time to determine whether the flight time limitations in 14 CFR part 121 and 14 CFR part 135 have been exceeded. The FAA determined that documenting this time, as recorded in the pilot's logbook, in the air carrier's records is one appropriate method for monitoring it.
- Requester
- Johnson
- Organization
- ALPA
- Issued
- May 11, 2009
- Subject
- Air Carrier & Commercial Operations
Regulations Cited
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
Regulations Referenced
Snapshot retrieved August 6, 2026.