Required Crewmember Definition
A practical interpretation of FAA legal opinion on the meaning of 'required crewmember seat' and its regulatory implications.
Key Conclusion
The definition of “required crewmember seat” depends on interpretation, and creates a regulatory tension between Part 61 and Part 142 medical requirements.
Why It Matters
The real issue is not medical certificates, but:
- Who is considered a required crewmember
- How that definition affects regulatory requirements
Core Logic
1. Definition is role-based
FAA interprets:
- “Required crewmember seat” (Part 142)
- Same meaning as “required crewmember” (Part 61)
👉 It depends on assigned duty during flight, not aircraft type
2. Instructor may become a required crewmember
An instructor may be considered required when:
- The student cannot act as PIC
- Or regulations require an additional pilot
👉 This is situational, not automatic
3. Medical requirement depends on context
- Under Part 61 → required crewmember needs at least third-class
- Under Part 142 → instructing from required crewmember seat may require second-class
👉 This creates different outcomes depending on which rule applies
4. Regulatory tension
FAA acknowledges:
- Part 142 imposes a stricter requirement
- Part 61 sets a lower baseline
👉 The relationship between these rules is not fully harmonized
5. Key implication
The interpretation expands:
- “Required crewmember seat” beyond multi-pilot aircraft
👉 Leading to broader application than some operators expect
Common Misunderstandings
- ❌ “Aircraft type determines requirement”
- ❌ “One rule clearly overrides the other”
👉 The outcome depends on how “required crewmember” is applied
One-Sentence Summary
This interpretation centers on how “required crewmember” is defined, and highlights a regulatory conflict rather than a fixed rule.