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135.299 line check ?

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Well-known member
Jan 2, 2005
If you are PIC on two different aircraft (jets) on two certificates, do you need a separate 135.299 line check for each certificate holder?

Our FSDO says yes.

If your FSDO (your POI, specifically) says yes, there's your answer.

Unless you move your 135 certificate to another FSDO.
Usually the FSDO wants to see how you operate within that companies ops manual... that you have a grasp on how they are supposed to operate... that is why they require the PIC to have a .299 ride for each certificate that you are on.

It really depends on your POI. Order 8400.10 deesn't specify. Presntly I am on three different certificates and have only 1 .299. It has been my experience if the .299 was given by a FAA inspector, they will usually accept it. If it was given by a check airman, it really depends on the check airman's rep with the FAA, are the certificates held by the same office, what sort of mood the inspector is in that day, etc.
My POI "accepts" another carrier's 299 after I send him a copy of the 8410 and a letter requesting the approval. Never been denied, just paperwork to cover everyone's a**.
Geeze, guys,

Brush the dust off that FAR and get a spine. Operators who do not hold FSDO's to THEIR letter of the law set a dangerous precedence.

135.299(a) clearly states "...12 months...ONE type of aircraft..."

They are clearly taking advantage of your Operations' lack of comprehension for the regs and/or unwillingness (inability) to say, "no."

The only time a FSDO can call for something alternative to what is written in the FAR's in when the statement, "Unless otherwise approved/authorized by the Administrator..." accompanies that regulation.

FAA 8400.10, 8300.10 are guidance for the Inspector's governance of the Certificate within the Certificate Holding District Office-CHDO. These manuals by the FAA's own admission may not supercede the FAR's which undergo a gruling approval process, where the inspector's Handbooks are internal manuals revised with the swipe of a pen.



Unless of course it is incidental to a crew, instrument or equipment check. Otherwise, you are only required to hold a 299 for one type of aircraft in which you are to serve as PIC. It is indifferent to the Certificate(s) or their number and types of aircraft.

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I agree...But!

Our POI even called the regional office in Dallas and they used some sort of guidance B.S. to come up with the decision that I need a Line check for each operator. Short of hiring a Lawyer, I am stuck.
There is a guy in DAL who used to be head counsel for the FAA and now has a private practice to represent us, keeping the FAA in Check. A couple of hundred bucks an hour for counsel to write a letter or a couple thousand dollars per year per airplane so that you can feed your family.

pm me if you want the number.

The reg states that no certificate holder may use and no pilot may fly...Short of laying down on the ramp in front of the aircraft to keep you from flying, any certificate action by your POI will be reviewed by the FAA legal team and they will definitely set the POI straight. That is if you want a fight. If your certificate holder (either) refuses to use you that is a different story. So long as they are willing to pay for the check ride and your time.

Otherwise. The POI is wrong and the Legal team will not proceed with cert action against you. The regs are very clear on this one.
The reg clearly says in "one of the types of aircraft which that pilot is to fly." I've never heard a POI claim that a line check needed to be done in multiple types of aircraft.

However, the reg says nothing about one certificate holder accepting another certificate holder's line checks.

Anyway, from a certificate holder's point of view, why would you want to accept someone else's line check? I know I would want to have one of my people fly with someone before I sent them out as a PIC.

Of course, I can see specific instances where a certificate holder doesn't have a check airman available and it would be more convenient, but generally a line check (if it is truly conducted on the line) is a valuable tool for evaluating someone as a PIC.

100-1/2 said:
Brush the dust off that FAR and get a spine. Operators who do not hold FSDO's to THEIR letter of the law set a dangerous precedence.

135.299(a) clearly states "...12 months...ONE type of aircraft..."

They are clearly taking advantage of your Operations' lack of comprehension for the regs and/or unwillingness (inability) to say, "no."
135.293... 1 yr Initial/Recurrent (EQUIPMENT) check.
135.297... 6 month Instrument (PROFICIENCY) check.
135.299... 1 yr Line check: (ROUTES & AIRPORTS) Check.

...Seems to me with multiple aircraft under your belt, the FAA and any Certificate Holder you would fly for has ample opportunity to.. "evaluate someone as PIC".

When you dive into .299 in its current form and the background on its inception, its justification is elementary when you consider how easily the requirements of each paragraph are satisfied during the normal course of the 293 and 297 checks. The problem occurs for On Demand Operators who are required to operate to outlying airports during the course of EXCESSIVE appeasement of this section for EVERY Aircraft the Pilot is qualified to ACT as PIC. Many FSDO's interprit (a)(3) to mean "an airport OTHER than where the flight check originates." This creates a significant consumption of the aircraft and pilot(s) for airports not near an airway or additionally suitable airport(s) for the type of aircraft being checked.

There has been significant speculation of the FAA's rewrite of 135 to include deleting this section as it was originally intended for scheduled commuters, whereby the 299 flight checks could be conducted during scheduled revenue operations. Now it serves a dual purpose in that with todays simulator quality and realism, Authorized "Factory" Schools can, and do conduct all parts of 293 and 297 in many of these aircraft. 299 allows the FAA to maintain control and hands on surveillance of operators' PIC's by requiring "[route checks]...IN ONE OF THE TYPES of aircraft...". There is not a lot of wiggle room in thi paragraph for "simulator" or "representative aircraft". Removal of 299 from the regs would take the FSDO out of the cockpit of On Demand Operators for which Flight training and checks could be accomplished entirely within the 142 Simulator. Never gonna happen. There is nothing in writing to permit an inspector to "require" a 299 for every aircraft nor for each certificate the pilot is authorized to fly on. If an operator chooses to conduct this check with their own Check Pilot, and maintain the pilot's records, so be it. Many will proprieterize that check internally, so be it. However, they are required to file the results of each check with the FSDO who then records that against your airman certificate. You then have free access to the 8410 via Airman Records request.

POI's demanding compliance on a reg that does not exist sets a dangerous precedence. Local FSDO Mgmt should be appealed for relief. If not there, then the Regional level. No Joy there. FAA Counsel ought to be warned of the practice by your legal counsel for damages. That should just about do the trick. I am guessing the FSDO Manager has a loose cannon in the office and no one has squeaked uncle yet. Done deal after that. Retaliation by the POI. Most of the Power Tools from the 90's have been weeded out by the new customer service initiatives. An appeal process to the MGR should dissway retaliation if the guy wants to continue to be a POI. Besides, Pay is pretty good these days with the trimmed staffs, these guys are making a bit more than normal GS levels with the increased workload from the hiring freezes.


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