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Old 06-13-2018, 03:50 AM   #1831
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Um, no. Your OM does not apply to flights that are dispatched as 91 legs. You need to remember that GOM, OpSpecs etc are only valid when the flight is flown under 135. If it's been dispatched as 91, none of that is relevant.
There are no "single pilot types" for PC12, it is a single pilot plane. All the single pilot training is 135 stuff.
I was specifically talking about single pilot type in the 350. We may only be required to follow 91 regs on the 91 legs, but as an operator we choose to follow the 135 regs. We will not get dinged for using the more restrictive rules.

We’re off into the weeds, and our operation is totally different than Boutique.
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Old 06-13-2018, 04:10 AM   #1832
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For 91, I believe it’s A001d that specifies what may be done Part 91. However, the big thing that’s different 91->135 is the derived alternate mins. Make sure you’re using the right one for the operation you’re conducting.
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Old 06-13-2018, 07:10 AM   #1833
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[QUOTE=deadstick35;2613467]For 91, I believe it’s A001d that specifies what may be done Part 91. However, the big thing that’s different 91->135 is the derived alternate mins. Make sure you’re using the right one for the operation you’re conducting.[/QUOTE

Without stating verbatim what our OM says, it says that while performing part 91 flights, we will still conform to the policies set forth in our OPSPECS, OM, and other manuals to include weather minima unless we get specific authorization from our DO or the Chief Pilot and that exemption authorization is on a flight by flight basis.
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Old 06-13-2018, 07:24 AM   #1834
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[QUOTE=EMAW;2613602]
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Originally Posted by deadstick35 View Post
For 91, I believe it’s A001d that specifies what may be done Part 91. However, the big thing that’s different 91->135 is the derived alternate mins. Make sure you’re using the right one for the operation you’re conducting.[/QUOTE

Without stating verbatim what our OM says, it says that while performing part 91 flights, we will still conform to the policies set forth in our OPSPECS, OM, and other manuals to include weather minima unless we get specific authorization from our DO or the Chief Pilot and that exemption authorization is on a flight by flight basis.
Your operations specifications are “FAA Approved” and carry the weight of 14 CFR. GOMs are just “FAA accepted.” A long time ago, the difference was explained to me like this: You can get fired for violating the GOM, but you still might not get certificate action because a reg was not busted. You will get violated for busting a reg (opspec) and possibly fired, too.

It’s the operator and pilot’s responsibility to comply. It’s like the 24/7 on call deal. The pilot has no defense just because the boss said to do it.
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Old 06-13-2018, 08:14 AM   #1835
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[QUOTE=deadstick35;2613613]
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Your operations specifications are “FAA Approved” and carry the weight of 14 CFR. GOMs are just “FAA accepted.” A long time ago, the difference was explained to me like this: You can get fired for violating the GOM, but you still might not get certificate action because a reg was not busted. You will get violated for busting a reg (opspec) and possibly fired, too.

It’s the operator and pilot’s responsibility to comply. It’s like the 24/7 on call deal. The pilot has no defense just because the boss said to do it.
A001 d
d. The certificate holder is authorized to conduct flights under 14 CFR Part 91 for crewmember training, maintenance tests, ferrying, re-positioning, and the carriage of company officials using the applicable authorizations in these operations specifications, without obtaining a Letter of Authorization, provided the flights are not conducted for compensation or hire and no charge of any kind is made for the conduct of the flights.

This gives authorization to operate under part 91. Its not a directive, it does not say shall or must. It authorizes us to fly under part 91 and gives us leave from the OPSPECS if we so choose, for flights under the circumstances listed.
Where is the directive that says we have to disreguard the OPSPECS and only operate under 91 if we don't have PAX on board?

Last edited by EMAW; 06-13-2018 at 08:35 AM.
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Old 06-13-2018, 12:08 PM   #1836
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Where is the directive that says we have to disreguard the OPSPECS and only operate under 91 if we don't have PAX on board?
What makes an empty leg a Part 135 leg? It is not a "passenger carrying operation".
The fact that you choose to use more restrictive regs is only relevant internally. For example, 135.101 does not apply because you are not flying passengers.
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Old 06-13-2018, 12:09 PM   #1837
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Starting at the end of page 2 of the Nichols letter is on point — 135 in a single-pilot certified aircraft. With A015, an operative AP, and a hunk of meat in the right seat, the only way that hunk of meat logs SIC time is if the AP is not used the entire flight. So you can’t just throw anybody in the right seat. The aircraft has to be equipped properly for the other seat, there has to be a CVR, and the SIC must be Part 61 IFR current. So, when can an SIC be required in a SP aircraft, with A015? Lower than standard takeoffs and when planned flight time for a duty period exceeds 8 hrs.

Put these “SIC-ish” hours on the application for an ATP at your own risk.
100% my point right here. But the PIC time as sole manipulator is 100% accepted and safe. That's why I would log every bit of it that I could.
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Old 06-13-2018, 04:15 PM   #1838
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What makes an empty leg a Part 135 leg? It is not a "passenger carrying operation".
The fact that you choose to use more restrictive regs is only relevant internally. For example, 135.101 does not apply because you are not flying passengers.
Using Boutique as an example, I would bet that because it's all subsidized flying the empty legs are still 135. I don't know for sure, but that's my guess.

We were assigned different flight numbers for 91 legs.
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Old 06-13-2018, 04:54 PM   #1839
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Using Boutique as an example, I would bet that because it's all subsidized flying the empty legs are still 135. I don't know for sure, but that's my guess.

We were assigned different flight numbers for 91 legs.
EAS flights are a bit murky, because they technically are commuter operations even when empty, but they are not, as in 135.101, "an aircraft carrying passengers under IFR ", so SIC is never required by the regs on those legs.
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Old 06-13-2018, 05:03 PM   #1840
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This gives authorization to operate under part 91. Its not a directive, it does not say shall or must. It authorizes us to fly under part 91 and gives us leave from the OPSPECS if we so choose, for flights under the circumstances listed.
Where is the directive that says we have to disreguard the OPSPECS and only operate under 91 if we don't have PAX on board?
Reading into the definitions in Part 119, if your operation is not an on-demand (which charter repos are not), or commuter (which empty scheduled flying is), it's not an 135 operation and 135 regulations do not apply to them.

So, in Boutiques example, empty scheduled legs are Part 135, but they are not carrying passengers, so doesn't matter what your GOM says, SIC is never required and SIC cannot log that time, unless SIC is PF and then he can log PIC time as sole manipulator of controls.
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