You need a 135.297(g) check for that. Some operators don't do it.

 

Av8tr1: deadstick was trying to put you on the right track. The FAA doesn’t authorize single-pilot IFR under 135 by withdrawing an OpSpec. Rather they authorize it by ISSUING OpSpec A015. If Boutique is now doing this, it’s because they have an FAA authorization they didn’t have before.

 

BTQ has been flying single pilot IFR for years. Occasionally SICs were kicked off trips when W&B wouldn't work. I know two CSAs and several SICs who can attest to this.

 

You have worked for several "airlines" and still don't understand the regulations under which you flew??

A SIC is required for carrying passengers under IFR under Part 135. If an operator wishes to use an autopilot in lieu of a SIC, then the operator needs an operational specification authorization to do so, found in OpSpec A015.

The requirement for a SIC is found in 14 CFR 135.101:

§ 135.101 Second in command required under IFR.

Except as provided in § 135.105, no person may operate an aircraft carrying passengers under IFR unless there is a second in command in the aircraft.

https://www.ecfr.gov/current/title-1...ection-135.101



You will notice that an exception is provided in 135.105, which is that an autopilot may be used in lieu of a SIC. This is permissible if approved in the Operations Specifications (OpSpecs) issued by the FAA to that certificate holder.

There is no OpSpec requiring a SIC: 135.101 requires the SIC. An OpSpec is required to operate under IFR without the SIC. A second in command may be required by the aircraft type certification, or the rules under which the aircraft is operated. In this case, operations under IFR under Part 135, require a SIC, regardless of whether the aircraft is type certificated for one pilot or not. To get around this requirement, the operator must hold OpSpec A015. I'm surprised that you operated single pilot IFR operations for "three airlines" under Part 135 and do not fully understand this.

§ 135.105 Exception to second in command requirement: Approval for use of autopilot system.

(a) Except as provided in §§ 135.99 and 135.111, unless two pilots are required by this chapter for operations under VFR, a person may operate an aircraft without a second in command, if it is equipped with an operative approved autopilot system and the use of that system is authorized by appropriate operations specifications. No certificate holder may use any person, nor may any person serve, as a pilot in command under this section of an aircraft operated in a commuter operation, as defined in part 119 of this chapter unless that person has at least 100 hours pilot in command flight time in the make and model of aircraft to be flown and has met all other applicable requirements of this part.

(b) The certificate holder may apply for an amendment of its operations specifications to authorize the use of an autopilot system in place of a second in command.

(c) The Administrator issues an amendment to the operations specifications authorizing the use of an autopilot system, in place of a second in command, if -

(1) The autopilot is capable of operating the aircraft controls to maintain flight and maneuver it about the three axes; and

(2) The certificate holder shows, to the satisfaction of the Administrator, that operations using the autopilot system can be conducted safely and in compliance with this part.

The amendment contains any conditions or limitations on the use of the autopilot system that the Administrator determines are needed in the interest of safety.
https://www.ecfr.gov/current/title-1...ection-135.105

 

That’s only allowed if the have A015.

 

Did the CEO really write that “Dear United States FAA” letter? I hope not, but it would explain a lot about their current predicament.

 

He sure did

 

Is this summary correct?

1) they do have A015
2) apparently they never had a PDP
3) Fargo FSDO told them to get the FO’s out of the pilot seat, and…
4) all FO flight time from Day 1 is = 0.0 hours UNLESS
5) …the pilot took a checkride. That way nobody falsified flight time on an FAA document.



Thoughts…

1) Day-yum!
2) I’m assuming a 297/299 counted otherwise there’d be IFR 135 PICs without the required time.
3) Turn in A015. Problem solved.
4) How in the heck could any of the Part 119 people NOT know this wasn’t legit? Nichols 2009 LOI. This is why the PDP option was developed. Granted the idea is great but the final product is not, it’s what they had to work with. Management chose to ignore the rules.
5) Day-yum.

JohnBurke’s post is spot on, but that lesson should be taught during indoc. When operators take on a 600 hr pilot, they essentially have a blank canvas. “Well, what this opspec means is…” “It must be right or the FAA wouldn’t let us do it.” If it was changing FSDOs that triggered this, then that just reinforces the notion the FAA’s system is still broken, like rolling rest with a wink ‘n a nod.

 

The same way everyone else has been caught by this. I relied on the statements from my chief pilot and the training instructors. I am older and wiser now but at the time with my limited experience and knowledge I relied on those who I believed were more knowledgeable to interpret the FARs. I was repeatedly told at different organizations that letters of authorizations existed that I was not privy to, much like these poor kids at BTQ. Again I am older and wiser now and know to trust but verify. We've all be there in starting our careers. Yes I know I am still held accountable for what happens but like most young pilots we learn to do as we are told and not ask questions (one of the things I can't stand about 121) and here this latest situation with BTQ is a perfect example of why that is so bad. The FARs are written for lawyers not pilots. The FAA will say one thing in a FAR then a policy letter will say the exact opposite.

 

Show me.

"But someone told me" is a poor way to plead ignorance, and ignorance is never a relief from the law.

You're expected to know and understand the CFR. If you don't, you shouldn't be a pilot in command, and you're in the wrong business.

The regulation isn't that hard to understand, but your excuses seem to revolve around you having asked someone to explain it to you, instead of lifting a finger to help yourself.

Here's the fun part: you say (now) that you learned and wised up...yet just a post ago you told us something completely incorrect, and to back it up, said that it's how things were at previous "airlines."

You learned, yet you still don't understand or know? A post later you change your tune, and now you know, but it's the FAA's fault that you don't bother to read your operations specifications and regulations (your compliance is mandatory, and you're expected to know both). The blame-game will only get you so far, but at any given time, the concept of pilot in command means that YOU are responsible. As a crew member, even if you are not the pilot in command, YOU are responsible not only for knowing the regulation, but compliance. The concept of pilot in command is inherent in what we do as pilots: we take responsibility. We own what we do, and that ownership is total: we take ownership for our decisions, our compliance, and staying informed and abreast not only of performance and systems understanding, but the regulations, policies, and practices under which we operate. Every crewmember is responsible for this, as are you. To suggest that you can't be held responsible, or that you can't know, or that you can't understand, either because someone told you differently (can't read for yourself?) or the regulation is too hard to understand (how is it that others understand it, but not you?) smacks of ignorance and laziness.

No one expects you to lay your head on a copy of your OpSpecs or the CFR and absorb it by osmosis, but it is expected that you read it, know it, and practice it. There really isn't any excuse not to.