The operator implements Subpart ORO.FTL for its operations with aeroplanes of 20 seats or more.
For air taxi operations with aeroplanes of 19 seats or less, the operator complies with EU OPS, Subpart Q.
However, the aim of the requirements is to ensure that crew members are able to operate at a satisfactory level of alertness. Fatigue accrued during an operation in one fleet might impact on the performance of a crew member when conducting a following flight in the other fleet.
Therefore, from a fatigue management perspective, it makes sense to apply a common FTL scheme under Subpart ORO.FTL consistently to pilots in such operations.