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Old 06-13-2018, 05:30 PM
  #1841  
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Originally Posted by dera View Post
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.
How can you prove when you were the sole manipulator of controls if you didn't start the engine, were listed as SIC on a flight log and flew from the right seat in a single pilot airplane under 135? PF or not, I would log SIC as per the flight log. Many pilots have logged SIC flying right seat in Caravans and PC-12s with no problems.
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Old 06-13-2018, 05:56 PM
  #1842  
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Originally Posted by V1VRV2setleft View Post
How can you prove when you were the sole manipulator of controls if you didn't start the engine, were listed as SIC on a flight log and flew from the right seat in a single pilot airplane under 135? PF or not, I would log SIC as per the flight log. Many pilots have logged SIC flying right seat in Caravans and PC-12s with no problems.
How can you prove anything in aviation? It's very much a honor system.

Many pilots have logged SIC in Caravans, 172's etc, but I'm just saying it's not 100% kosher and clear cut if you read the regs. Logging PIC is. There is zero ambiguity about it. As long as you are honest about it.

I forgot BTQ pilots are "seat locked". At our PC12 operation, PF is always left seat, even though we do get qualified to fly from both seats.
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Old 06-13-2018, 07:03 PM
  #1843  
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Originally Posted by dera View Post
How can you prove anything in aviation? It's very much a honor system.

Many pilots have logged SIC in Caravans, 172's etc, but I'm just saying it's not 100% kosher and clear cut if you read the regs. Logging PIC is. There is zero ambiguity about it. As long as you are honest about it.

I forgot BTQ pilots are "seat locked". At our PC12 operation, PF is always left seat, even though we do get qualified to fly from both seats.
Are both pilots PIC qualified under 135?
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Old 06-13-2018, 07:48 PM
  #1844  
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Originally Posted by V1VRV2setleft View Post
Are both pilots PIC qualified under 135?
What does that mean?
Remember, we are in the reg nitpick land, you've got to be more specific.
To be a sole manipulator of controls, you don't need the 135.243 experience requirements. That's for acting PIC, not logging PIC time.
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Old 06-15-2018, 03:14 PM
  #1845  
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Originally Posted by dera View Post
This is exactly the point. FAA has explicitly stated that you can log PIC if you are sole manipulator of controls, but they have not stated you can log SIC in 135 operation carrying passengers under IFR if you are using the autopilot.
This is the point I'm trying to make here. Logging the PIC time is 100% safe and appropriate and legal, logging SIC time is not.
Logging SIC time is simply widely accepted, but it's murky before someone asks the FAA if it's OK or not.

I don't think anyone should ask the FAA, people might not like the answer.

I've flown with at least a dozen pilots in the 121 world who built 135 SIC time at Planesense, Tradewind, Boutique, and other Caravan operators. There must be thousands of pilots flying 121 today who built SIC hours at these operations. Never heard of anyone ever getting hassled about whether or not they were using their autopilot.


Are you saying that under 135 the the co-pilot can never log SIC time? Then what is he or she supposed to log when they are the pilot monitoring? Just total time?
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Old 06-15-2018, 05:49 PM
  #1846  
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Originally Posted by TreeShade View Post
I've flown with at least a dozen pilots in the 121 world who built 135 SIC time at Planesense, Tradewind, Boutique, and other Caravan operators. There must be thousands of pilots flying 121 today who built SIC hours at these operations. Never heard of anyone ever getting hassled about whether or not they were using their autopilot.


Are you saying that under 135 the the co-pilot can never log SIC time? Then what is he or she supposed to log when they are the pilot monitoring? Just total time?
If the company doesn’t have A015, SIC is a required crew member for passenger carrying ops under Part 135. The question comes if you have A015 in your Opspecs. Then can you disregard it, or are you held to it? I’ve never seen a legal interpretation on it.
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Old 06-15-2018, 06:02 PM
  #1847  
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Originally Posted by EMAW View Post
If the company doesn’t have A015, SIC is a required crew member for passenger carrying ops under Part 135. The question comes if you have A015 in your Opspecs. Then can you disregard it, or are you held to it? I’ve never seen a legal interpretation on it.
How does the Nichols letter not address this question?
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Old 06-15-2018, 06:10 PM
  #1848  
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Originally Posted by TreeShade View Post
I've flown with at least a dozen pilots in the 121 world who built 135 SIC time at Planesense, Tradewind, Boutique, and other Caravan operators. There must be thousands of pilots flying 121 today who built SIC hours at these operations. Never heard of anyone ever getting hassled about whether or not they were using their autopilot.


Are you saying that under 135 the the co-pilot can never log SIC time? Then what is he or she supposed to log when they are the pilot monitoring? Just total time?
Like I've been saying, 99% of time you will get away with it, but it's not 100% legit if we really nitpick with the regs.
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Old 06-15-2018, 06:11 PM
  #1849  
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Originally Posted by deadstick35 View Post
How does the Nichols letter not address this question?
Nichols doesn't say what happens, if you have a functioning autopilot and A015. Are you allowed to use it or not. One could say, that using autopilot automatically "triggers" the use of A015.
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Old 06-15-2018, 06:12 PM
  #1850  
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Originally Posted by EMAW View Post
If the company doesn’t have A015, SIC is a required crew member for passenger carrying ops under Part 135. The question comes if you have A015 in your Opspecs. Then can you disregard it, or are you held to it? I’ve never seen a legal interpretation on it.
Exactly. There is no FAA opinion about this. Tarsa letter says it does not mandate the use of an Opspec, but nothing says you can "have your cake and eat it" with them. That is, operate with A015, SIC, AND autopilot.
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