Boutique Air
#1831
Gets Weekends Off
Joined APC: Jul 2013
Posts: 459
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.
There are no "single pilot types" for PC12, it is a single pilot plane. All the single pilot training is 135 stuff.
We’re off into the weeds, and our operation is totally different than Boutique.
#1832
Gets Weekends Off
Joined APC: Apr 2007
Posts: 867
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.
#1833
Gets Weekends Off
Joined APC: Jul 2013
Posts: 459
[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.
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.
#1834
Gets Weekends Off
Joined APC: Apr 2007
Posts: 867
[QUOTE=EMAW;2613602]
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.
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.
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.
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.
#1835
Gets Weekends Off
Joined APC: Jul 2013
Posts: 459
[QUOTE=deadstick35;2613613]
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?
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.
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.
#1836
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,453
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.
#1837
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,453
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.
Put these “SIC-ish” hours on the application for an ATP at your own risk.
#1838
Gets Weekends Off
Joined APC: Feb 2017
Posts: 154
We were assigned different flight numbers for 91 legs.
#1839
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,453
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.
#1840
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,453
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?
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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