mojo6911

I think he has a valid point when it comes to any 91 or repo legs. The GOM or OpsSpecs doesn't apply. Either way, it's probably a small percentage of the operation.

deadstick35

According to the Nichols letter, it applies to the 135 when the autopilot is utilized.

mojo6911

Yes, that is why I specifically said part 91.

gvinflight

Ah. I see. Thanks. Now if I could just get the call for the interview. Mutual benefit!

RI830

Even under 91, the operational control falls under the certificate holders FOM/GOM/OpsSpecs/Company Policies.

Think of it as when 91 you will still abide by EAS's rules and ops with the exception of a few things.

The GOM/OpsSpecs/training manual are approved and signed off by the POI. So what one operator under 135 does has no bearing on what another 135 operator can or can't do.

The list of "interpretations/understandings" is endless
We can go on for days with the FAA's interpretations of Duty Legalities ie "The Kidd letter" or Crew in a SP airplane. The consistent thing about the FAA is the inconsistency.

deadstick35

I'll go check out the Kidd letter. My understanding is that these LOI's trump POI because, as you noted, there is a lack of consistency from FSDO to FSDO, or ASI to ASI for that matter.

In another discussion on this topic, two different companies had a GOM requirement for 2 pilots. However, in that case one company's GOM was "Accepted" and the other's was "Approved." The consensus from that was the one with the "Approved" stamp was good to go (logging SIC) and the requirements of the client or insurance were not pertinent.

RI830

I won't even pretend to understand the accepted vs approved piece.
All I can say is that EAS SICs can log the time. As for LOI's superseding company policy.....if I was pulled in to do the FAA carpet dance, I would rather base my actions/decisions based on my companies approved SOP's and procedures than the fairly uncirculated LOI's. Most people don't even know the many LOI's even exist.

Other variants in ops that I have found are some 135's can use hold over tables while others can't. Some have DAAP while others don't.
It's all about the POI signing off on it.

RI830

As for the regularly scheduled programming,....


Has anyone interviewed lately?
Experience, news, hired?

DFWAviatior

I wasn't trying to get anything off topic. I've flown for several 135 carriers and am familiar with Part 135 OpSpecs that will allow for a single pilot certified aircraft to Operate with an SIC who would be a required crewmember per OpSpecs approved by the FAA for that company. The reason I raise this issue is that, on the fractional side, EAS operates under Part 91, NOT part 135.

Given that:
1) An SIC cannot log time simply because an Insurance policy states that aircraft must have two pilots. Insurance companies are not regulatory and have no oversight authority.

2) Part 135 OpSpecs are not binding upon flights operated under Part 91, therefore an OpSpec requiring aircraft to be flown with a second in command would allow for an SIC to log time ONLY during part 135 flights or during 91 flights in a TurboJet where the PIC does not have the Single Pilot Designation on his License/Rating.

3) Someone stated that if one elects to not use the autopilot a case can be made for logging SIC time. I think this statement likely goes back to the OpSpec for Autopilot in lieu of SIC, which would be a 135 OpSpec and not apply to Part 91. However, even if it did...would it be possible to fly in RVSM airspace without an autopilot? This would restrict all flights to FL280 or less.

4) If you can legally use a GOM under Part 91 to require a second crewmember, what is to prevent someone for writing a policy with their Cessna 152 or Piper Seminole that "requires two crewmembers"

The reason I ask all this is because my friend's goal is to end up at a 121 carrier (not a regional). I'm not sure how he would be able to explain SIC time in a King Air 90 or 350 or any of the Phenom aircraft. I ran into a Part 91 crew just yesterday in Florida and asked them their thoughts. The right seater stated he doesn't log the time on his Part 91 flights but that their aircraft is on a 135 certificate (with OpSpecs requiring two crewmembers) and on the occasional 135 flights they do, he does log SIC time (he received an SIC type rating from CAE).

I encouraged my friend to apply for a LearJet SIC position, so hopefully that will work out for him as he can log SIC for both Part 91 flights and 135 flights on that! I just can't find any evidance that would allow for SIC time in a single pilot certified aircraft operating with a PIC who is typed (and designated as a PIC type rated single pilot (S) when applicable).

Super27

Going to interview on the 28th. 4,200 hour ex-regional guy, currently flying light-twin 135 and enjoying it, but fractional is the long term goal.

I'm really looking forward to it - this sounds like an overall great place to work.