Is a checkride which is required in order to qualify a pilot for 121 or 135 operations itself conducted under Part 91 or Part 121/135 rules?

For instance, is a first class medical required in order to be PIC for the line check required by 135.299 or is only a second class medical required? Is a fully qualified 121/135 SIC required in order to do the flight (in non-revenue service), or could it be done with an SIC qualified only for Part 91 flights?

I understand that in order to act as PIC of a Part 121/135 flight you need those, but what about for the actual checkride?

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    $\begingroup$ I'm sending my local FSDO (LNK FWIW) an email about this via the contact form -- hopefully I hear back by the time the bounty expires! (Obviously, if that's not enough, we'll have to get a Chief Counsel interpretation, but that takes a while :P) $\endgroup$ Nov 11, 2016 at 2:39
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    $\begingroup$ BTW -- the FSDO did respond to me, but with an "ask your carrier or POI" response. It seems that the OpSpec-based answer from JonathanWalters is the closest we'll come to an authoritative answer unless we want to bug the Chief Counsel about this question... $\endgroup$ Nov 16, 2016 at 1:50
  • $\begingroup$ @UnrecognizedFallingObject Thanks for checking!! $\endgroup$
    – Lnafziger
    Nov 16, 2016 at 16:23

2 Answers 2


Any flights operated by a certificate holder must be operated in accordance with the authorization of their certificate. Authorization will vary.

An Air Carrier may conduct training1 flights under §91 if authorized to do so. If not authorized, any flights operated by that Air Carrier—including training flights—must be conducted under the part of 14 CFR (§121, §135, etc) specified by their Air Operating Certificate (AOC).

An Air Carrier may be authorized to conduct training flights under 14 CFR 91 in accordance with their Operation Specifications authorized by the FAA.

The exception to this would be if that Air Carrier's Operation Specifications do not authorize the Air Carrier to conduct flights under §91. I know of no reason for such exception, nor if any such exception has been withheld from any actual Air Carrier.

The authorization is found within the Operation Specifications of the company in question, not necessarily in 14 CFR, though it can be inferred there. See Operation Specification A001 for authorization to conduct training flights under 14 CFR 91, for example:

d. The certificate holder is authorized to conduct flights under 14 CFR Part 91 for crewmember training, maintenance tests, ferrying, re-positioning, and the carriage of company officials using the applicable authorizations in these operations specifications, without obtaining a Letter of Authorization, provided the flights are not conducted for compensation or hire and no charge of any kind is made for the conduct of the flights.

(The above is an example only; actual authorization may vary.)

An Air Carrier may also be authorized by A031 of their Ops Spec to make arrangements with an outside party for Contract Training, including instruction and evaluation. An authorized outside party under this specification may include a §142 Training Center and/or a different §119 Certificate holder authorized to conduct training and/or checking. Any training flights operated by either such certificate holder must likewise be authorized by the terms of their certificate.

1Note: Regarding the question of what is included under the definition of the term training—particularly whether checkrides are included in that definition—no explicit guidance is offered. However, a definition might well be inferred from—among other things—the definitions for the following two terms as found in Ops Spec A002, Definitions and Abbreviations:

Major Contract Training
Any flight training, flight testing, or flight checking leading to and maintaining certification and qualification of air carrier flight crew members in accordance with the requirements (maneuvers and procedures) explicitly stated in 14 CFR Parts 61, 121, or 135; or in SFAR 58 Advanced Qualification Program (AQP), as applicable.

Outsourced Training
Any training, testing, or checking activity which an air carrier certificate holder provides by way of a contract arrangement with another party.

  • $\begingroup$ Curiously enough, this specifies training, while some regulations specify training and checking. Does this exclude checkride, or are they included here as part of training? $\endgroup$
    – Lnafziger
    Nov 15, 2016 at 5:04
  • $\begingroup$ @Lnagziger In this case, checkrides would be included under the term "training". $\endgroup$
    – J W
    Nov 15, 2016 at 5:15
  • $\begingroup$ Do you have a reference for that? It's curious to me that they use both phrases... $\endgroup$
    – Lnafziger
    Nov 15, 2016 at 16:20
  • $\begingroup$ Ops Specs will sometimes use the term "training flight" to encompass training, evaluation, and checking flights, though sometimes each are differentiated for clarity, particularly when authority is granted to outside parties to perform one or more of each. See Ops Spec A031 "Contract Training" for an example of both phenomenon. $\endgroup$
    – J W
    Nov 15, 2016 at 16:39
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    $\begingroup$ @Lnafziger See my edit here adding support for checking to be included under the definition of "training". $\endgroup$
    – J W
    Nov 17, 2016 at 19:52

You're asking a couple of different questions here, I think.

Neither FSIMS nor the FARs specify whether a particular checkride flight must be conducted under part 91 or 135/121. Regarding medical certificates, FSIMS 5-887 indicates that for ATP 121/135 applicants:

CREW QUALIFICATIONS. The crew, with the exception of the applicant, must be qualified and current. [emphasis added]

As for checkrides, they're part 61.. So as to the part of your question that asks about what medical you need during a checkride, FAR 61.23(a)(3) says that you need at least a 3rd class medical.

That said, FSIMS guidance for examiners conducting 121/135 checks occasionally makes reference to "limitations as specified by the certificate holder's operating manual". Since this wouldn't make sense if the flight was conducted under part 91, I suspect that:

  1. There is no defined answer to your question
  2. The flight that a checkride happens during is conducted according to whichever rules would otherwise apply
  3. Checkride flights are just special that way
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    $\begingroup$ A flight isn't conducted under Part 61.... I wonder if the FAA had issued any letter of interpretation covering this. $\endgroup$
    – Lnafziger
    Mar 7, 2014 at 11:32
  • $\begingroup$ @Lnafziger - obviously. I'll edit the question to make what I'm trying to say more clear. $\endgroup$
    – Steve V.
    Mar 7, 2014 at 14:13

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