135.293 .297 .299

[Corp Pilot]

Flyin Moose,

I respect your opinion but I think we may have to agree to disagree on this one. I cannot find a case, nor do I know of one, where a pilot or operator had an action brought against them while in compliance with the guidance provided in 8400. 8400 is published for inspectors, pilots and operators and is used as guidance to comply with the CFRs. (I say pilots and operators because several FAA inspectors have told me to reference 8400)
I hear what you are saying but I would feel very comfortable walking into any court using any guidance published in 8400. A judge or jury would have a difficult if not impossible time issuing a penalty or fine to anyone following the FAA's own system of compliance.

We are in agreement as to the original question. He is legal through June.
I don't want this to turn into a long debate so I will end my contribution here.
You make some very valid points.

Take Care,

Corp Pilot

 

[simav8r]

B.

Eligibility Period. The eligibility period is a 3-month

period comprised of the calendar month before the month

in which training is due, the month in which training is
due, and the calendar month after the month in which
training is due. In both Part 121 and Part 135 operations,
required recurrent training or checking that is completed
any time during the eligibility period is considered to have
been completed during the month in which training is due.
A crewmember who has not completed all recurrent
training or checking requirements in the month due may be
scheduled and may serve in revenue service during the
remainder of the eligibility period, but not thereafter. A
flight crewmember who fails to complete all required
training and qualification modules within the eligibility
period must complete requalification training before serving
in revenue operations.

Keep in mind that this paragraph refers to training and qualification modules with regard to the execution of requalification training, not the currency requirements of 293, 297, and 299. Technically the regulations stand as written. You are legal under 301 only if a checkride and or training event is successfully completed. If no checkride or training event is completed, per the CFR all flying done in the "grace" month is not done in compliance with 293, 297, 299 as appropriate and prosecutable as such. Whether the FAA chooses to do so depends upon the severity of the infraction that leads to the discovery. In other words, it's all good until someone looses an eye, then the defecation hits the rotary oscilator and they'll throw everything they can at you.

To be safe, do not do any flying in the grace month provided under 135.301 unless you plan on taking a checkride. I agree with everyone else in that you are good until midnight on June 30, then you turn into a pumpkin.

FWIW​