Logging Part 135 time
 

I have a peculiar question about logging Part 135 time. I have currently only been logging time as Part 135 when I am on a leg that is required to be operated under Part 135, but there are many times that I have empty legs that are actually Part 91 because I have already dropped the pax or cargo off and am heading home empty. Should I also log these legs as Part 135? It would add about 35% more time to my 135 time. Also, should I log training time in the aircraft (me being trained), checkride time in the aircraft, and time that I am training others for a Part 135 checkride ( I am a 135 instructor ) as part 135 time since it is being flown for the Part 135 operation?

I am specifically asking this because of how it will be looked at by potential hiring authorities in the future. I appreciate any input.

I've never heard of anyone specifically logging 135 time. If someone asks me how much 135 time I have, I can give an estimate based on my total time in the airplanes I've flown 135. I couldn't see someone being picky about only wanting to know your time on 135 live legs. On the 91 dead legs, you still operate according to your GOM don't you?

I don't know why you would need to log 135 time, however...

A dead leg is not automatically part 91. I would assume that unless you specifically identify it as 91, or if the company policy states that all such legs are 91, that they would be 135 by default.

Obviously if you exceed duty time or other 135 requirements, then a dead leg would have to be part 91.

The reason to keep track of it is for hiring purposes in the future. Applications frequently ask how much Part 121 or Part 135 PIC time you have. Due to the nature of some of my flying, I have quite a few empty legs, which could be considered as being operated under Part 91. If so, my total time acting as Captain under Part 135 would be considerably less if those legs were considered Part 91 legs.

Check rides, training flights, and aircraft reposition are Part 91. All other legs should be 135. Returning to your base empty after dropping cargo should also be 135. Look through your GOM or talk to your CP. They should have an answer because this affects your rest and duty times.

That said, different places run their stuff differently.

All of your time in the aircraft that you fly for a certificate holder is "135 time."

There are times when you will not operate it in accordance with certain 135 requirements, but it will always be beholden to 135 maintenance standards, just as you'll always be beholden to currency under the certificate holder's training program, drug testing requirements, flight checking, etc.

When you're operating under Part 135, you're still operating under Part 91. The notion that you're either "Part 135" or "Part 91" is misplaced. You are better thinking of yourself operating under Part 91 at all times, with additional requirements (and relief) imposed by Part 135.

There is no FAA classification or definition of the logging of "Part 135" time.

You can complete your duty day, end your duty to that certificate holder, and fly the airplane on a repositioning flight as a "Part 91" flight; you're still an employee of the 135 certificate holder and you're still able to log that time as "135" time; doing so doesn't make it duty, nor does it impose any additional legal burden on you. All of your time operating the company aircraft may be assessed as "135 time," even if you're not on duty or operating under "135" at the time. If you're repositioning for the certificate holder after duty has concluded, you're still working for the certificate holder (even though as a flight after duty is over, the certificate holder can't compel you to make the flight).

Don't get too wrapped around the axle about Part 91 vs. Part 135. It's always Part 91, but sometimes has additional regulation to consider.