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.