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Old 09-11-2019, 09:07 PM   #10  
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Joined APC: Apr 2007
Posts: 805

Originally Posted by EMAW View Post
Almost. Part 135 passenger ops always requires an SIC (135.101), no matter the seats, UNLESS the operator has OPSPEC A015 which allows an autopilot in lieu of SIC AND the aircraft has 9 passenger seats or less. (135.105)
If the aircraft has more than 9 passenger seats, you can’t use A015 and therefore an SIC is always required. 135.99 (b)
My company doesn’t have A015 therefore, under 135, an SIC is required even though we only have 9 passenger seats.
In other words, the regulations require an SIC. The OPSPECS give you relief under A015.
That pretty much sums it up for 135. Good summary with the references.

As for 91, you can go to the FAA’s Chief Counsel webpage and look up the Cato, Nichols, and Herman Letters of Interpretation and get your answers from the proverbial horse’s mouth.
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