Narrative:

I may have violated far 135.267(B)(1). I flew freight from 7d2 to mei in 6.4 hours. I then dropped off the freight and returned to 7d2 in 4.8 hours. My understanding of the applicable rules is that my return flight was under the jurisdiction of far 91, not far 135. Therefore, I was not subject to the 8 hour maximum of commercial flight time required by far 135.267(B)(1) for my return trip. It is clearly obvious to me that my trip from 7d2 to mei was an far 135 flight, I complied with the 8 hour flight time. My return flight was a 'deadhead' run, there was no freight on board. Since I interpret the rules of the far to allow the 'deadhead' return flight to be conducted under far 91, then I did not have to stop flying 8 hours after I left 7d2 providing I was 'deadheading' when I reached the 8 hour flight time limit. Furthermore, I was not required to return the plane to 7d2, or anywhere else, nor was I assigned any other duty beyond my 'drop off' point of mei. I was relieved of duty upon reaching mei. The fact that I decided to return was my own choice. I flew 11.2 hours in a 24 consecutive hour period, but only 6.4 hours of that time were commercial flight hours. I am investigating the definition of 'commercial flight time.' I submit this report in the event that my interpretation is wrong, putting me in violation. Callback conversation with reporter revealed the following information: reporter stated that he had no other commercial flight time within the 24 hours prior to his assigned part 135 flight. In addition, he was off duty and rested more than 10 hours prior to the atx flight. Therefore, his commercial flight back to base, which was not for the purpose of part 135, was only commercial time as a pilot to be considered prior to the next 135 assignment.

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Original NASA ASRS Text

Title: AN ATX PLT IS CONCERNED THAT HE MAY HAVE EXCEEDED THE FLT TIME DUTY LIMITATION.

Narrative: I MAY HAVE VIOLATED FAR 135.267(B)(1). I FLEW FREIGHT FROM 7D2 TO MEI IN 6.4 HRS. I THEN DROPPED OFF THE FREIGHT AND RETURNED TO 7D2 IN 4.8 HRS. MY UNDERSTANDING OF THE APPLICABLE RULES IS THAT MY RETURN FLT WAS UNDER THE JURISDICTION OF FAR 91, NOT FAR 135. THEREFORE, I WAS NOT SUBJECT TO THE 8 HR MAX OF COMMERCIAL FLT TIME REQUIRED BY FAR 135.267(B)(1) FOR MY RETURN TRIP. IT IS CLRLY OBVIOUS TO ME THAT MY TRIP FROM 7D2 TO MEI WAS AN FAR 135 FLT, I COMPLIED WITH THE 8 HR FLT TIME. MY RETURN FLT WAS A 'DEADHEAD' RUN, THERE WAS NO FREIGHT ON BOARD. SINCE I INTERPRET THE RULES OF THE FAR TO ALLOW THE 'DEADHEAD' RETURN FLT TO BE CONDUCTED UNDER FAR 91, THEN I DID NOT HAVE TO STOP FLYING 8 HRS AFTER I LEFT 7D2 PROVIDING I WAS 'DEADHEADING' WHEN I REACHED THE 8 HR FLT TIME LIMIT. FURTHERMORE, I WAS NOT REQUIRED TO RETURN THE PLANE TO 7D2, OR ANYWHERE ELSE, NOR WAS I ASSIGNED ANY OTHER DUTY BEYOND MY 'DROP OFF' POINT OF MEI. I WAS RELIEVED OF DUTY UPON REACHING MEI. THE FACT THAT I DECIDED TO RETURN WAS MY OWN CHOICE. I FLEW 11.2 HRS IN A 24 CONSECUTIVE HR PERIOD, BUT ONLY 6.4 HRS OF THAT TIME WERE COMMERCIAL FLT HRS. I AM INVESTIGATING THE DEFINITION OF 'COMMERCIAL FLT TIME.' I SUBMIT THIS RPT IN THE EVENT THAT MY INTERP IS WRONG, PUTTING ME IN VIOLATION. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: RPTR STATED THAT HE HAD NO OTHER COMMERCIAL FLT TIME WITHIN THE 24 HRS PRIOR TO HIS ASSIGNED PART 135 FLT. IN ADDITION, HE WAS OFF DUTY AND RESTED MORE THAN 10 HRS PRIOR TO THE ATX FLT. THEREFORE, HIS COMMERCIAL FLT BACK TO BASE, WHICH WAS NOT FOR THE PURPOSE OF PART 135, WAS ONLY COMMERCIAL TIME AS A PLT TO BE CONSIDERED PRIOR TO THE NEXT 135 ASSIGNMENT.

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.