Originally Posted by
EMAW
I could justify this. The operator I fly for has a lot of empty legs, and the trip sheets are marked as 91 legs but only to show that they are reposition legs. EVERY leg is flown under 135 Regs. 0 issues logging SIC as assigned SIC on the flight.
No no no no no NOOOOO!
If you mark the trip sheet as 91 leg, _IT IS FLOWN AS PART 91!!_
I cannot emphasize that enough. The part in the trip sheet that says it's Part 91 means it's Part 91. Not some pseudo-135. The fact that you fly in a 135 operation DOES NOT mean the empty legs are flown 135. Your trip sheet will say what regulations you follow. Part 91 does not just "show they are reposition legs", it means you are flying under Part 91 and 135 limitations and regs do not apply.
And continuing - why does an empty leg require an SIC? It is NOT passenger carrying operation.
Don't say "zero issues" when there are plenty.