In a recent legal opinion, the FAA stated that simulator instructors and check airmen who conduct training and checking for a Part 135 certificate holder may meet flight currency requirements by acting as a required crewmember on Part 91 flights. The FAA noted that “it appears the agency intended to add some flexibility into this requirements as compared to other qualifications, which are explicitly required to be completed in operations under a specific part.” These requirements ensure that check airmen and flight instructors continue to experience flying under conditions that are comparable to what may be encountered in their operational environment.
To accomplish this, the FAA prefers that instructors and check airmen meet these requirements is by flying on the line. However, this is not strictly required nor is it the only method available for satisfying these experience requirements. Therefore, those flight segments may be conducted in an operation under part 135 or in an operation under part 91.