Boutique Air
06-15-2018, 07:09 PM
#1851
Gets Weekends Off
Joined APC: Jul 2013
Posts: 460
Originally Posted by dera
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.
Approval for single pilot operations with use of an operative
approved autopilot system under FAR 135.105 gives an operator an
additional option in the conduct of operations. It does not
mandate that all future flights be conducted in that manner. The
operator can elect to fly trips with two pilots, as is otherwise
required for flight in IFR conditions under FAR 135.101, using
the second in command instead of the autopilot.
Your second question asks if, under the circumstances given
above, the SIC can log time as SIC when the designated pilot in
command is flying the aircraft. The answer is yes, as long as
the certificate holder is using the SIC as a crewmember instead
of exercising the autopilot authorization. In other words, the
certificate holder elects not to conduct an IFR flight using the
single pilot with a functioning autopilot option, but rather
conducts an IFR flight using two qualified pilots. The two
pilots are then "required by the regulations under which the
flight is conducted", FAR 61.51(c)(3), and the assumption is that
the second pilot (SIC) will function as a required crewmember,
and SIC time may validly be logged. However, if for some reason
another qualified pilot "rides along" and does not function as a
crewmember, then second-in-command time may not be validly
logged.
This doesn’t say that the autopilot has to be inop. If you are trained and functioning as a crew member, SIC time is loggable under part 135 passenger carrying ops. The way I read it, 135.105 and A015 gives operators an “option” if the don’t have a second pilot on staff or available.
06-15-2018, 07:35 PM
#1852
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,469
Originally Posted by EMAW
Here is an excerpt.
Approval for single pilot operations with use of an operative
approved autopilot system under FAR 135.105 gives an operator an
additional option in the conduct of operations. It does not
mandate that all future flights be conducted in that manner. The
operator can elect to fly trips with two pilots, as is otherwise
required for flight in IFR conditions under FAR 135.101, using
the second in command instead of the autopilot.
Your second question asks if, under the circumstances given
above, the SIC can log time as SIC when the designated pilot in
command is flying the aircraft. The answer is yes, as long as
the certificate holder is using the SIC as a crewmember instead
of exercising the autopilot authorization. In other words, the
certificate holder elects not to conduct an IFR flight using the
single pilot with a functioning autopilot option, but rather
conducts an IFR flight using two qualified pilots. The two
pilots are then "required by the regulations under which the
flight is conducted", FAR 61.51(c)(3), and the assumption is that
the second pilot (SIC) will function as a required crewmember,
and SIC time may validly be logged. However, if for some reason
another qualified pilot "rides along" and does not function as a
crewmember, then second-in-command time may not be validly
logged.
This doesn’t say that the autopilot has to be inop. If you are trained and functioning as a crew member, SIC time is loggable under part 135 passenger carrying ops. The way I read it, 135.105 and A015 gives operators an “option” if the don’t have a second pilot on staff or available.
Approval for single pilot operations with use of an operative
approved autopilot system under FAR 135.105 gives an operator an
additional option in the conduct of operations. It does not
mandate that all future flights be conducted in that manner. The
operator can elect to fly trips with two pilots, as is otherwise
required for flight in IFR conditions under FAR 135.101, using
the second in command instead of the autopilot.
Your second question asks if, under the circumstances given
above, the SIC can log time as SIC when the designated pilot in
command is flying the aircraft. The answer is yes, as long as
the certificate holder is using the SIC as a crewmember instead
of exercising the autopilot authorization. In other words, the
certificate holder elects not to conduct an IFR flight using the
single pilot with a functioning autopilot option, but rather
conducts an IFR flight using two qualified pilots. The two
pilots are then "required by the regulations under which the
flight is conducted", FAR 61.51(c)(3), and the assumption is that
the second pilot (SIC) will function as a required crewmember,
and SIC time may validly be logged. However, if for some reason
another qualified pilot "rides along" and does not function as a
crewmember, then second-in-command time may not be validly
logged.
This doesn’t say that the autopilot has to be inop. If you are trained and functioning as a crew member, SIC time is loggable under part 135 passenger carrying ops. The way I read it, 135.105 and A015 gives operators an “option” if the don’t have a second pilot on staff or available.
"using the second in command instead of the autopilot."
"Instead", is the word that makes it ambiguous. If they said "instead of the autopilot authorization" or anything, it would've been more clear. Now it just says instead of autopilot. The way you can read it, and no-one knows what's the "right way" to read it, is that you cannot use the autopilot if you have an SIC.
This could also be confirmed by the next question:
"In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option". "functioning autopilot option" seems to be the only other option to using SIC. It does not allow for using both.
Also, this does not address the empty legs. Are they loggable? They are not passenger carrying operations, even if they are operated under part 135.
06-15-2018, 07:45 PM
#1853
Gets Weekends Off
Joined APC: Jul 2013
Posts: 460
Originally Posted by dera
That's the part that's open to interpretation. This is the key point:
"using the second in command instead of the autopilot."
"Instead", is the word that makes it ambiguous. If they said "instead of the autopilot authorization" or anything, it would've been more clear. Now it just says instead of autopilot. The way you can read it, and no-one knows what's the "right way" to read it, is that you cannot use the autopilot if you have an SIC.
This could also be confirmed by the next question:
"In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option". "functioning autopilot option" seems to be the only other option to using SIC. It does not allow for using both.
Also, this does not address the empty legs. Are they loggable? They are not passenger carrying operations, even if they are operated under part 135.
"using the second in command instead of the autopilot."
"Instead", is the word that makes it ambiguous. If they said "instead of the autopilot authorization" or anything, it would've been more clear. Now it just says instead of autopilot. The way you can read it, and no-one knows what's the "right way" to read it, is that you cannot use the autopilot if you have an SIC.
This could also be confirmed by the next question:
"In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option". "functioning autopilot option" seems to be the only other option to using SIC. It does not allow for using both.
Also, this does not address the empty legs. Are they loggable? They are not passenger carrying operations, even if they are operated under part 135.
06-15-2018, 07:51 PM
#1854
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,469
Originally Posted by EMAW
It does say "instead of using the autopilot authorization." As far as empty legs, I don't know.
Difficult question, that letter does not really answer that question either.
Can you use both a functional autopilot AND a second-in-command, while having the SIC as a required crewmember.
I'd say if anyone asks FAA for a legal interpretation, you better word the question damn well so you won't get an answer you won't like.
06-16-2018, 07:08 AM
#1855
New Hire
Joined APC: Oct 2016
Posts: 5
Originally Posted by EMAW
Here is an excerpt.
Approval for single pilot operations with use of an operative
approved autopilot system under FAR 135.105 gives an operator an
additional option in the conduct of operations. It does not
mandate that all future flights be conducted in that manner. The
operator can elect to fly trips with two pilots, as is otherwise
required for flight in IFR conditions under FAR 135.101, using
the second in command instead of the autopilot.
Your second question asks if, under the circumstances given
above, the SIC can log time as SIC when the designated pilot in
command is flying the aircraft. The answer is yes, as long as
the certificate holder is using the SIC as a crewmember instead
of exercising the autopilot authorization. In other words, the
certificate holder elects not to conduct an IFR flight using the
single pilot with a functioning autopilot option, but rather
conducts an IFR flight using two qualified pilots. The two
pilots are then "required by the regulations under which the
flight is conducted", FAR 61.51(c)(3), and the assumption is that
the second pilot (SIC) will function as a required crewmember,
and SIC time may validly be logged. However, if for some reason
another qualified pilot "rides along" and does not function as a
crewmember, then second-in-command time may not be validly
logged.
This doesn’t say that the autopilot has to be inop. If you are trained and functioning as a crew member, SIC time is loggable under part 135 passenger carrying ops. The way I read it, 135.105 and A015 gives operators an “option” if the don’t have a second pilot on staff or available.
Approval for single pilot operations with use of an operative
approved autopilot system under FAR 135.105 gives an operator an
additional option in the conduct of operations. It does not
mandate that all future flights be conducted in that manner. The
operator can elect to fly trips with two pilots, as is otherwise
required for flight in IFR conditions under FAR 135.101, using
the second in command instead of the autopilot.
Your second question asks if, under the circumstances given
above, the SIC can log time as SIC when the designated pilot in
command is flying the aircraft. The answer is yes, as long as
the certificate holder is using the SIC as a crewmember instead
of exercising the autopilot authorization. In other words, the
certificate holder elects not to conduct an IFR flight using the
single pilot with a functioning autopilot option, but rather
conducts an IFR flight using two qualified pilots. The two
pilots are then "required by the regulations under which the
flight is conducted", FAR 61.51(c)(3), and the assumption is that
the second pilot (SIC) will function as a required crewmember,
and SIC time may validly be logged. However, if for some reason
another qualified pilot "rides along" and does not function as a
crewmember, then second-in-command time may not be validly
logged.
This doesn’t say that the autopilot has to be inop. If you are trained and functioning as a crew member, SIC time is loggable under part 135 passenger carrying ops. The way I read it, 135.105 and A015 gives operators an “option” if the don’t have a second pilot on staff or available.
Pretty good explanation there. If I were an SIC at one of these operators, I wouldn't be worried.
For something to be inappropriate and/or illegal, there must be a law or regulation that specially prohibits such action. I don't see that here.
It's possible that in the future the FAA could come out with some rule that prohibits the logging of SIC time at 135 operators, but they would not do anything retroactively to the thousands of pilots who have upgraded to Captain and/or earned their ATPs. It would be herculean task to even think about it. And forcing a Captain to not use the autopilot so his poor SIC can log some time, safety issue alone would stop that.
By the way, I am not a lawyer, never attended law school, never been admitted to any state bar association. I assume this goes for everyone making legal interpretations here. Just saying we should all remind ourselves that.
Reading way back on this forum, I think Toddzilla would be the closest thing we have to a Supreme Court Justice as far Boutique Air goes. Toddzilla, will you please issue a final ruling on this matter so we can move on. Thanks.
06-24-2018, 06:17 PM
#1857
New Hire
Joined APC: Oct 2012
Posts: 5
Originally Posted by boutiquedair
Was looking at Controller and happened across two of Boutique's King Airs for sale. Wonder what that means for the King Air fleet and the company as a whole if they are selling off planes?
https://www.controller.com/listings/...t-king-air-350
https://www.controller.com/listings/...t-king-air-350
https://www.controller.com/listings/...t-king-air-350
https://www.controller.com/listings/...t-king-air-350
07-30-2018, 11:27 AM
#1859
Gets Weekends Off
Joined APC: Dec 2014
Posts: 117
Originally Posted by Jetmech2380
What’s going on with the hiring of first officers? Their jobs page only shows PIC. They probably had too many applicants?
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