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Old 12-05-2008, 07:08 AM   #21  
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GauleyPilot's Avatar
Joined APC: Apr 2006
Position: BE-20, RA390
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Originally Posted by joepilot View Post
Yes, it is absolutely true that the positioning legs are operated under Part 91.

HOWEVER, according to FAR Part 135 regs, the positioning legs cannot be part of your required rest period, and Part 91 commercial flight time counts against your maximum Part 135 flight time. The Feds don't buy the idea that professional pilots jump in an airplane and fly empty to Omaha for free, and only then start getting paid.

Agree with all you say Joe. I was pointing out that you are not considered part 135 on a reposition.

The professional pilots didn't have to do a load manifest for the empty trip to Omaha, and they took off with an RVR of 300, but that is OK in this case too (maybe not smart, but legal)
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Old 09-05-2009, 07:48 AM   #22  
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Joined APC: Feb 2009
Position: B747-400 Cpt retired
Posts: 67

The term PIC is obviously used to mean more than one thing. To a job interviewer, it means time when you were fully in command of all aspects of the flight. However, the logging of PIC time is addressed by the FAA in only one place, part 61. (The definition in Part 1 is included in the part 61 language.) If you are fully rated for PIC in the airplane and are sole manipulator of the controls (from either seat, revenue leg or not) it should be logged as PIC. (The recent change to SIC type ratings leaves some ambiguity about whether an SIC-rated pilot can log PIC time; that language needs to be cleaned up.)
Bottom line: your logbook time should be entered only as defined by Part 61. However, for the job interviewer, be prepared to differentiate those flights where you were not the pilot signed for the aircraft.
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Old 09-11-2009, 07:29 PM   #23  
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Joined APC: Nov 2006
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Originally Posted by Qtip View Post
In regards to your question in bold:
I don't think that an empty aircraft in your example necessarily is a Part 91 flight.
I agree Qtip.

Bottom line; check your company Ops Specs. Granted, I come from a 121 environment but I've flown Part 135 and I believe Qtip is correct. In our 121 operation, every flight is conducted under FAR 121 regardless of who or what is onboard. I flew for a 135 operator whose Ops Specs dictated the same requirement.

Relief can be granted from FAR 121/135 duty time regulations by positioning an aircraft to a domicile/base after a revenue flight;however, the only relief is from the duty time requirements and the flight is still conducted under 121/135 regs. Again, check your Ops Specs if applicable. Otherwise, go with Qtips posting.

G'Day Mates
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