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Ultra yes I am a 121 Captain current qualified, been so for the last 12 years or so.
Long time gone dude...
No comment, just a bit dissapointed to see a collegue so quick to pass judgement assuming you are a collegue.
I fly a 737-700 with 19 seats in it and we are not required to have a FA. Never had one, actually. We have Customer Service Representatives.
I'm not saying you haven't...but I'll bet it's not Pt 121. It's a Pt 91 or 91K. Right?
Pace, in 2002 was offered a contract on an ambulance rated 737 with 12 seats and ultimately we turned it down b/c of the conformity checks and contract-term were too short...but b/c of MTOW it did require an FA; to fly it as a Pt 121 gig.
It can all be true...just depends on the CFR etc under which the operator wants to fly.
Your are all correct!
People make the the assumption that the FAA regulations are BLACK and WHITE, they are not.
A 121 carrier is required to develop a series of manuals that dictate what the procedures are for dealing with common issues and how they comply with the regulations.
The FAA approves that manual through the CMO assigned to that airline. That manual provides a framework of how the airline complies with the regulations.
It is quite possible that Airline A's CMO may approve a manual saying up to 19 passengers may be carried on a 148 seat MD 80 with no FA's
It is quite possible that Airline B's CMO may require that all seats above 19 must be MEL'd before up to 19 passengers may be carried on a 148 seat MD 80 with no FA's
Airlines C, CMO may say no how, no way, you can never carry passengers without an FA.
For the point of this example it does not matter if the passengers are company personel, non-revs or paying passengers. What does matter, is the approved procedure in your company manual.
For many regualtions, the differences in approved procedures from one airline to another can be eye-opening.