Narrative:

I completed an FAA approved training course for initial qualification in the shorts sd-3 aircraft, and successfully accomplished an FAA type rating flight test on mar/wed/95. I was then assigned and completed 10.5 plus hours of IOE with 20 plus lndgs to satisfy IOE requirements for scheduled commuter service. I am also qualified, and fly as captain, an emb 110. On mar/fri/95, I was assigned to fly the sd-360 under part 135 from rota island to saipan island in the cnml. The flight departed late, and arrived late into saipan. By the time we landed approximately 1:20 after sunset had lapsed, thus causing the flight to be a 'night operation' (1 hour after sunset) by 20 mins. My training and IOE did not include any night flying and although I just got qualified on the aircraft, I question now whether my serving as PIC may have violated far 135.247. I thought that under 61.57, since an ATP was required for this operation, the 3 night lndgs in type were not required, however, after several hours of research today, I believe that I may have unwittingly violated far 135.247 requiring 3 night lndgs in type. While one may dismiss the concept that a pilot who just completes a type rating flight test with an FAA inspector just 9 days earlier could not serve because he is not current, a close, careful study of the regulations seems to state just that. I question whether a chkride with the FAA 'wipes the slate clean' and begins currency issues anew. I cannot find anything that answers this question. It would seem logical, but I am not sure. If this anomaly does exist, a clarification in the regulation would be helpful to state that a check ride or 135.293 ride does or does not count toward currency for night operations. I wonder how many others complete training, chkride, and IOE, and draw a night assignment and inadvertently fall victim to this regulation's prohibition on serving as PIC unless 3 night lndgs are accomplished within the last 90 days. For one who strives to obey the regulations and laws, it is with the most humble embarrassment that this report is submitted. Regardless of whether this incident was in violation of 135.247, I will not undertake any more night flts until the company allows 3 full stop night lndgs without passenger.

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Original NASA ASRS Text

Title: FLC NIGHT LNDG CURRENCY.

Narrative: I COMPLETED AN FAA APPROVED TRAINING COURSE FOR INITIAL QUALIFICATION IN THE SHORTS SD-3 ACFT, AND SUCCESSFULLY ACCOMPLISHED AN FAA TYPE RATING FLT TEST ON MAR/WED/95. I WAS THEN ASSIGNED AND COMPLETED 10.5 PLUS HRS OF IOE WITH 20 PLUS LNDGS TO SATISFY IOE REQUIREMENTS FOR SCHEDULED COMMUTER SVC. I AM ALSO QUALIFIED, AND FLY AS CAPT, AN EMB 110. ON MAR/FRI/95, I WAS ASSIGNED TO FLY THE SD-360 UNDER PART 135 FROM ROTA ISLAND TO SAIPAN ISLAND IN THE CNML. THE FLT DEPARTED LATE, AND ARRIVED LATE INTO SAIPAN. BY THE TIME WE LANDED APPROX 1:20 AFTER SUNSET HAD LAPSED, THUS CAUSING THE FLT TO BE A 'NIGHT OP' (1 HR AFTER SUNSET) BY 20 MINS. MY TRAINING AND IOE DID NOT INCLUDE ANY NIGHT FLYING AND ALTHOUGH I JUST GOT QUALIFIED ON THE ACFT, I QUESTION NOW WHETHER MY SERVING AS PIC MAY HAVE VIOLATED FAR 135.247. I THOUGHT THAT UNDER 61.57, SINCE AN ATP WAS REQUIRED FOR THIS OP, THE 3 NIGHT LNDGS IN TYPE WERE NOT REQUIRED, HOWEVER, AFTER SEVERAL HRS OF RESEARCH TODAY, I BELIEVE THAT I MAY HAVE UNWITTINGLY VIOLATED FAR 135.247 REQUIRING 3 NIGHT LNDGS IN TYPE. WHILE ONE MAY DISMISS THE CONCEPT THAT A PLT WHO JUST COMPLETES A TYPE RATING FLT TEST WITH AN FAA INSPECTOR JUST 9 DAYS EARLIER COULD NOT SERVE BECAUSE HE IS NOT CURRENT, A CLOSE, CAREFUL STUDY OF THE REGS SEEMS TO STATE JUST THAT. I QUESTION WHETHER A CHKRIDE WITH THE FAA 'WIPES THE SLATE CLEAN' AND BEGINS CURRENCY ISSUES ANEW. I CANNOT FIND ANYTHING THAT ANSWERS THIS QUESTION. IT WOULD SEEM LOGICAL, BUT I AM NOT SURE. IF THIS ANOMALY DOES EXIST, A CLARIFICATION IN THE REG WOULD BE HELPFUL TO STATE THAT A CHK RIDE OR 135.293 RIDE DOES OR DOES NOT COUNT TOWARD CURRENCY FOR NIGHT OPS. I WONDER HOW MANY OTHERS COMPLETE TRAINING, CHKRIDE, AND IOE, AND DRAW A NIGHT ASSIGNMENT AND INADVERTENTLY FALL VICTIM TO THIS REG'S PROHIBITION ON SERVING AS PIC UNLESS 3 NIGHT LNDGS ARE ACCOMPLISHED WITHIN THE LAST 90 DAYS. FOR ONE WHO STRIVES TO OBEY THE REGS AND LAWS, IT IS WITH THE MOST HUMBLE EMBARRASSMENT THAT THIS RPT IS SUBMITTED. REGARDLESS OF WHETHER THIS INCIDENT WAS IN VIOLATION OF 135.247, I WILL NOT UNDERTAKE ANY MORE NIGHT FLTS UNTIL THE COMPANY ALLOWS 3 FULL STOP NIGHT LNDGS WITHOUT PAX.

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.