Originally Posted by
JohnBurke
I'm not a management type. I'm someone who read the original posters comments and asked him to cite the regulation that he knows for a fact is broken.
Put up, or shut up. He came here and introduced it. Ball's in his court.
He says it's illegal. Knows it for a fact. What regulation has been violated?
One had better not be announcing publicly that one knows something is illegal, if one doesn't really know.
He says it's a fact. State the fact. It's very simple.
Regulation is clear. These are the same rules why you can't let a passenger operate your airplane under revenue service, whether they are a rated pilot or not. There are more affected regulations than just these, such as hour requirements for SICs for on-demand, all the regulations that say "crewmember", IFR and autopilot, etc., but these are a start:
§135.323 Training program: General.
(a) Each certificate holder required to have a training program under §135.341 shall:
(1) Establish and implement a training program that satisfies the requirements of this subpart and that ensures that each crewmember, aircraft dispatcher, flight instructor and check airman is adequately trained to perform his or her assigned duties. Prior to implementation, the certificate holder must obtain initial and final FAA approval of the training program.
§135.329 Crewmember training requirements.
(a) Each certificate holder must include in its training program the following initial and transition ground training as appropriate to the particular assignment of the crewmember:
§135.293 Initial and recurrent pilot testing requirements.
(a) No certificate holder may use a pilot, nor may any person serve as a pilot, unless, since the beginning of the 12th calendar month before that service, that pilot has passed a written or oral test, given by the Administrator or an authorized check pilot, on that pilot's knowledge in the following areas—
And if they are having him flip switches, run checklists, there is little legal wiggle-room to claim he is not acting as a pilot and SIC for the company. 135.323 requires them to be trained in their duties and roles they are serving in, this requires training records, syllabus, etc. Unless there was information that operation was contrary to 135.115 was being conducted, it would be left out.