Legal Interpretations
Gallup-Suburban Air Freight 2014
Summary
The Question
Does 14 CFR 135.63(a)(4)(vii) require flight-qualified management at a part 135 air carrier to maintain a duty time log?
Background
Suburban Air Freight, Inc. asked whether the part 135 recordkeeping rule in 14 CFR 135.63(a)(4)(vii) requires flight-qualified management personnel at an air carrier to keep a "duty time log."
The FAA’s Interpretation
No. 14 CFR 135.63(a)(4)(vii) requires a record of a pilot's flight time in sufficient detail to determine compliance with flight time limitations, but says nothing about duty time. However, the certificate holder must still ensure its operations comply with all applicable 14 CFR part 135 flight, duty, and rest regulations, which are subject to FAA inspection.
- Requester
- Gallup
- Organization
- Suburban Air Freight
- Issued
- July 12, 2014
- Subjects
- Air Carrier & Commercial Operations · Flight & Duty Time
Regulations Cited
Page 1
U.S. Department
of Transportation -Jll_ ~a Z<1f4'
Federal Aviation .:· . .. ·
Administration
Geoffrey C. Gallup
Suburban Air Freight, Inc.
40 l 0 Amelia Earhart Plaza
Omaha, NE 68110
Dear Mr. Gallup,
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington, D.C. 20591
This is in response to your e-mails asking whether 14 C.F.R. § 135.63(a)(4)(vii) requires flight-qualified management at an air carrier to maintain a "duty time log." Section 135.63 specifies a set ofrecordkeeping requirements for part 135 certificate holders. Subsection 135.63(a)(4)(vii) requires a certificate holder to maintain a record of a "pilot' s flight time in sufficient detail to determine compliance with the flight time limitations of this part." (emphasis added). As can be seen from the emphasized portion of the above quotation, the regulatory text of§ 135.63(a)(4)(vii) requires a certificate holder to maintain a record of a pilot's flight time, but says nothing about maintaining a record of a pilot's duty time. Thus, § 135.63(a)(4)(vii) does not require a certificate holder to maintain a specific record of a pilot's duty time. We note, however, that each certificate holder operating under part 135 is responsible for complying with all applicable flight, duty, and rest regulations of part 135 . Thus, while § 135.63(a)(4)(vii) does not restrict the certificate holder to a specific method of recording duty time, the certificate holder must nevertheless ensure that its operations do not violate the pertinent flight, duty, and rest regulations. A certificate holder' s compliance with these regulations is subject to FAA inspection. 1 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 Alex Zektser, Attorney, International Law, Legislation, and Regulations Division of the Office of the Chief Counsel, and coordinated with the Air Transportation Division of Flight Standards Service.
. ury Assistant Chief Counsel for International Law, Legislation, arid Regulations, AGC-200 1 See 14 C.F.R. § 119.59.
I
Regulations Referenced
Snapshot retrieved August 6, 2026.