Originally Posted by
dera
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.
Um no. Our OM says we always operate under 135 regs. Flight following, alternate weather requirements, operational control, et al does not change from leg to leg.
I, along with more than half of our pilots, are not single-pilot typed, we are an EOD operator, and we have no A015. So we always have SICs. Also everyone of our trip sheets has a PIC AND SIC designated.