Legal Interpretations
Raines 1992
Summary
The Question
Was a hypothetical crew schedule combining domestic and flag flights between rest periods within the flight time limitations and rest requirements of 14 CFR part 121?
Background
A requester described a hypothetical crew of two pilots and one additional flight crewmember flying two domestic segments (3 hours total) and then two flag segments to Panama City and back (8 hours), with 23 hours between rest periods.
The FAA’s Interpretation
Yes, on these facts. Assuming the carrier holds both domestic and flag operating certificates, the domestic limits of 14 CFR 121.471 apply to the domestic segments and the flag limits of 14 CFR 121.483 apply to the flag segments. The 3 domestic hours were within the 8-hour limit between required rest periods, and the 11 total hours in 23 consecutive hours were within the flag limit of 12 hours in 24 consecutive hours.
- Requester
- Raines
- Issued
- October 14, 1992
- Subject
- Flight & Duty Time
Regulations Cited
Page 1
October 14, 1992
fos G. Raines-
Dear Mr. Raines:
Thank you for your letter of August 10, 1992, in which you request the agency's inte1prntation of FAR Pait 121 regarding flight time limitations and rest requirements. We apologize that the press of other matters, including safety mlemaking, petitions for exemptions, and requests for interpretations received prior to yours, has prevented us from answering sooner.
You describe the following hypothetical situation:
A crew consisting oftwo pilots and one additional flight crewmember operntes a scheduled domestic flight from Los Angeles (LAX) to P01tland (PDX) with a flight time of 1 hour 30 minutes. After 7 hours on the ground (not considered arest period), the saine crew operntes another schechtled domestic flight :from Portland (PDX) back to Los Angeles (LAX) for another 1 hom 30 minutes flight time. The crew then operates a scheduled flag flight to Pai:iama City (MPTO) and back to Los Angeles (LAX) for a total flight time of 8 additional hours. Total domestic flight time (segments 1 and 2) is 3 hours. Total flag flight time (segments 3 and 4) is 8 hours. Total combined flight time is 11 hours. Flight time did not exceed scheduled time. Total time between rest periods is 23 hours.
You state that if either the domestic or flag portions ofthis flight were conducted sepai<1tely, both would appai·ently be in compliance with their respective FAR Subpaits. You ask, when all the flights are combined has this crew conducted a legal flight?
Yes, given the flights in the hypothetical, all flights were flown in accordance with applicable FARs peitaining to flight time limitations ai1d rest requirements. We assume for pUiposes of answering this question that the air cairier holds both a domestic and flag air can ier operating cert ificate.
Page 2
The applicable sections of the FARS state, in pertinent part:
121.471 Flight time limitations and rest requirements: All flight crewmembers.
No domestic air carrier may schedule any flight crewmember and no flight crewmember may accept an assignment for flight time in scheduled air transportation or in other commercial flying if that crewmember's total flight times in all commercial flying will exceed- * * * * * *
(4) 8 hours between required rest periods.
121.483 Flight time limitations: Two pilots and one additional flight crewmember.
No flag carrier may schedule a pilot to fly, in an airplane that has a crew of two pilots and at least one additional flight crewmember, for a total of more than 12 hours during any 24 consecutive hours.
The domestic limitations apply to domestic operations and the flag limitations apply to the flag operations. FAR 121.471 governs domestic operations, while FAR 121.483 governs flag operations. In the case of combined operations the domestic regulations apply to the domestic portions of the trip while the flag limitations apply to the flag operations. To illustrate, where a scheduled carrier has certificate authority to fly from a point outside the continental United States to a point inside the United States, enplane passengers or cargo, and then proceed to a final destination in the continental United States, the flag air carrier flight time limitations apply to the first leg of the flight while the domestic air carrier flight time limitations govern the leg within the United States. Conversely, where scheduled carriers has authority to operate from a point in the continental United States to another point in the United States, deplane passengers or cargo, and then proceed to a final destination outside the United States, the domestic air carrier rules govern the first leg and the flag rules govern the international leg. Under the hypothetical situation you describe, the first two segments, Los Angeles (LAX) to Portland (PDX) and return, are domestic flights. The total flight time limitation under FAR 121.471(a) (4) is 8 hours between required rest periods.
Page 3
The total domestic flight time in our facts is 3 hours. Similarly, the third and fourth segments, to Panama City (MPTO) and back to Los Angeles (LAX), are flag flights. The total flight time limitation under FAR 121.483(a) is 12 hours in 24 consecutive hours. The total flight time, domestic and flag, in your facts is 11 hours in 23 consecutive hours. Therefore, the hypothetical situation you describe is consistent with the flight time limitations and rest requirements for domestic and flag operations under FARs 121.471 and 121.483. This response was prepared by Francis C. Heil, Attorney, Operations Law Branch; Richard C. Beitel, Manager, and has been coordinated with the Air Transportation Division of the Flight Standards Service at FAA Headquarters. We hope this information satisfies your request.
Sincerely,
Donald P. Byrne Assistant Chief Counsel
Regulations and Enforcement Division
Regulations Referenced
Snapshot retrieved August 6, 2026.