Originally Posted by
jbt1407
Whale Driver,
Thank you for taking time to post this letter. Not only does it answer my question, but it solves many others that were still unclear to me.
That opinion letter is extremely helpful, but understand it's limitations.
Your letter presents the following scenario: a Part 135 certificate holder conducts operations in multiengine airplanes under instrument flight rules (IFR). The operator has approval to conduct operations without an SIC using an approved autopilot under the provisions of FAR 135.105. The operator has assigned a fully qualified pilot, who has had a Part 135 competency check, to act as SIC in an aircraft that does not require two pilots under its type certification. Although FAR 135.101 requires an SIC for Part 135 operations in IFR conditions, the autopilot approval is an exception to that requirement.
Go back to the question I asked about the source of the requirement for more than one pilot. In the case of this letter, it's 135.101
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§ 135.101 Second in command required under IFR.
Except as provided in § 135.105, no person may operate an aircraft carrying passengers under IFR unless there is a second in command in the aircraft.
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In other words, the scenario
starts with an operation that requires an SIC and then points out that there is an exception that allows 1 pilot operation with an autopilot.
Hence my question to you: You mentioned that it was a cargo flight, so 135.101 doesn't apply. What is the source of a SIC requirement in
your scenario?
Here's the rule on logging SIC:
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61.51(f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of § 61.55 of this part,
and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or
(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and
more than one pilot is required under the type certification of the aircraft orthe regulations under which the flight is being conducted.
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Since it's a single-pilot aircraft, 61.51(f)(1) doesn't apply. 61.51(f)(2) may
if (using your scenario as an example), the type certification requires 2-pilot operations but only one with an autopilot. Similarly, an OpSpec might require two pilots if no autopilot.
The question remains the same; what's the 2-pilot requirement and what is it based on?