Gregory J. Reigel
Serving clients throughout the U.S.
Tel (214) 780-1482
Email: info@aerolegalservices.com

 
[Top Background]
Aviation Law Discussions Subscribe XML

A site devoted to aviation law, safety and security.

July 12, 2019

Can A Person Be Chief Pilot For A Part 121/135 Operator With A Third-Class Medical Certificate?

This was the question posed and answered in a recent Legal Interpretation issued by the FAA's Office of Chief Counsel (AGC). The Interpretation specifically answered the question "whether a chief pilot who no longer holds a first-or second-class medical certificate but holds a third-class medical certificate and is qualified to serve as pilot in command (PIC) in at least one aircraft used in the certificate holder's operation may continue to hold the chief pilot position."

Under 14 C.F.R. 119.71 the chief pilot of a Part 121 or Part 135 air carrier must hold either an airline transport pilot (ATP) certificate or a commercial pilot certificate. And as we know, under 14 C.F.R. 61.23 a person must hold a first-class medical certificate to exercise PIC privileges of an ATP certificate and a second-class medical certificate to exercise privileges of a commercial pilot certificate. The Interpretation notes that " 119.71(c) and (d) only require the chief pilot to be qualified to serve as PIC in at least one aircraft in the certificate holder's operation." However, Section 119.71 does not specify that the chief pilot must be qualified to serve as pilot in command "in Part 121/135 operations."

As a result, the Interpretation concludes as long as the person (a) continues to hold either an ATP or commercial pilot certificate with appropriate ratings, (b) is qualified to serve as PIC in at least one aircraft used in the certificate holder's operation (which can include just Part 91 operations), and (c) has satisfactory experience (or has been granted a deviation from the experience requirements), then he or she may serve as chief pilot for the air carrier while holding only a third-class medical certificate.

So, in addition to holding at least a third-class medical certificate, the key issue for the chief pilot will be that he or she is qualified to act as PIC in at least one of the aircraft that the carrier is authorized to operate under its certificate. And this qualification can be limited to Part 91 operations rather than Part 121/135 operations.

As a practical matter I think this Interpretation probably has limited impact on most carriers since they typically expect the individual designated as chief pilot to also act as PIC in Part 121 or Part 135 flight operations. But where the chief pilot is not expected to act as PIC in Part 121/235 flight operations, this Interpretation does provide some flexibility to a carrier considering an individual without a first or second class medical certificate for the chief pilot position.

Posted by Greg

Aviation Law Discussions - Archives

12/01/2003 - 12/31/2003
01/01/2004 - 01/31/2004
02/01/2004 - 02/29/2004
03/01/2004 - 03/31/2004
04/01/2004 - 04/30/2004
05/01/2004 - 05/31/2004
06/01/2004 - 06/30/2004
07/01/2004 - 07/31/2004
08/01/2004 - 08/31/2004
09/01/2004 - 09/30/2004
10/01/2004 - 10/31/2004
11/01/2004 - 11/30/2004
12/01/2004 - 12/31/2004
01/01/2005 - 01/31/2005
02/01/2005 - 02/28/2005
03/01/2005 - 03/31/2005
04/01/2005 - 04/30/2005
05/01/2005 - 05/31/2005
06/01/2005 - 06/30/2005
07/01/2005 - 07/31/2005
08/01/2005 - 08/31/2005
09/01/2005 - 09/30/2005
10/01/2005 - 10/31/2005
11/01/2005 - 11/30/2005
12/01/2005 - 12/31/2005
01/01/2006 - 01/31/2006
02/01/2006 - 02/28/2006
03/01/2006 - 03/31/2006
04/01/2006 - 04/30/2006
05/01/2006 - 05/31/2006
06/01/2006 - 06/30/2006
07/01/2006 - 07/31/2006
08/01/2006 - 08/31/2006
09/01/2006 - 09/30/2006
10/01/2006 - 10/31/2006
11/01/2006 - 11/30/2006
12/01/2006 - 12/31/2006
01/01/2007 - 01/31/2007
02/01/2007 - 02/28/2007
03/01/2007 - 03/31/2007
04/01/2007 - 04/30/2007
05/01/2007 - 05/31/2007
06/01/2007 - 06/30/2007
07/01/2007 - 07/31/2007
08/01/2007 - 08/31/2007
09/01/2007 - 09/30/2007
10/01/2007 - 10/31/2007
11/01/2007 - 11/30/2007
12/01/2007 - 12/31/2007
01/01/2008 - 01/31/2008
02/01/2008 - 02/29/2008
03/01/2008 - 03/31/2008
04/01/2008 - 04/30/2008
05/01/2008 - 05/31/2008
06/01/2008 - 06/30/2008
07/01/2008 - 07/31/2008
08/01/2008 - 08/31/2008
09/01/2008 - 09/30/2008
10/01/2008 - 10/31/2008
11/01/2008 - 11/30/2008
12/01/2008 - 12/31/2008
01/01/2009 - 01/31/2009
02/01/2009 - 02/28/2009
03/01/2009 - 03/31/2009
04/01/2009 - 04/30/2009
05/01/2009 - 05/31/2009
06/01/2009 - 06/30/2009
07/01/2009 - 07/31/2009
08/01/2009 - 08/31/2009
09/01/2009 - 09/30/2009
10/01/2009 - 10/31/2009
11/01/2009 - 11/30/2009
12/01/2009 - 12/31/2009
01/01/2010 - 01/31/2010
02/01/2010 - 02/28/2010
03/01/2010 - 03/31/2010
04/01/2010 - 04/30/2010
05/01/2010 - 05/31/2010
06/01/2010 - 06/30/2010
07/01/2010 - 07/31/2010
08/01/2010 - 08/31/2010
09/01/2010 - 09/30/2010
10/01/2010 - 10/31/2010
11/01/2010 - 11/30/2010
12/01/2010 - 12/31/2010
01/01/2011 - 01/31/2011
02/01/2011 - 02/28/2011
03/01/2011 - 03/31/2011
05/01/2011 - 05/31/2011
06/01/2011 - 06/30/2011
07/01/2011 - 07/31/2011
08/01/2011 - 08/31/2011
09/01/2011 - 09/30/2011
10/01/2011 - 10/31/2011
11/01/2011 - 11/30/2011
12/01/2011 - 12/31/2011
01/01/2012 - 01/31/2012
02/01/2012 - 02/29/2012
03/01/2012 - 03/31/2012
04/01/2012 - 04/30/2012
05/01/2012 - 05/31/2012
06/01/2012 - 06/30/2012
07/01/2012 - 07/31/2012
08/01/2012 - 08/31/2012
10/01/2012 - 10/31/2012
11/01/2012 - 11/30/2012
12/01/2012 - 12/31/2012
02/01/2013 - 02/28/2013
04/01/2013 - 04/30/2013
05/01/2013 - 05/31/2013
06/01/2013 - 06/30/2013
07/01/2013 - 07/31/2013
08/01/2013 - 08/31/2013
11/01/2013 - 11/30/2013
12/01/2013 - 12/31/2013
01/01/2014 - 01/31/2014
02/01/2014 - 02/28/2014
05/01/2014 - 05/31/2014
07/01/2014 - 07/31/2014
08/01/2014 - 08/31/2014
10/01/2014 - 10/31/2014
12/01/2014 - 12/31/2014
01/01/2015 - 01/31/2015
03/01/2015 - 03/31/2015
04/01/2015 - 04/30/2015
06/01/2015 - 06/30/2015
07/01/2015 - 07/31/2015
08/01/2015 - 08/31/2015
10/01/2015 - 10/31/2015
12/01/2015 - 12/31/2015
03/01/2016 - 03/31/2016
07/01/2016 - 07/31/2016
08/01/2016 - 08/31/2016
10/01/2016 - 10/31/2016
01/01/2017 - 01/31/2017
02/01/2017 - 02/28/2017
03/01/2017 - 03/31/2017
04/01/2017 - 04/30/2017
05/01/2017 - 05/31/2017
06/01/2017 - 06/30/2017
07/01/2017 - 07/31/2017
08/01/2017 - 08/31/2017
09/01/2017 - 09/30/2017
10/01/2017 - 10/31/2017
11/01/2017 - 11/30/2017
12/01/2017 - 12/31/2017
01/01/2018 - 01/31/2018
02/01/2018 - 02/28/2018
03/01/2018 - 03/31/2018
05/01/2018 - 05/31/2018
07/01/2018 - 07/31/2018
08/01/2018 - 08/31/2018
09/01/2018 - 09/30/2018
10/01/2018 - 10/31/2018
12/01/2018 - 12/31/2018
01/01/2019 - 01/31/2019
02/01/2019 - 02/28/2019
04/01/2019 - 04/30/2019
05/01/2019 - 05/31/2019
07/01/2019 - 07/31/2019
08/01/2019 - 08/31/2019
09/01/2019 - 09/30/2019

< ? law blogs # >

The information contained in this web-site is intended for the education and benefit of those visiting the Aero Legal Services site. The information should not be relied upon as advice to help you with your specific issue. Each case is unique and must be analyzed by an attorney licensed to practice in your area with respect to the particular facts and applicable current law before any advice can be given. Sending an e-mail to Aero Legal Services or Gregory J. Reigel does not create an attorney-client relationship. Advice will not be given by e-mail until an attorney-client relationship has been established.

© Gregory J. Reigel-Aero Legal Services 2002-Present. All rights reserved.