Boutique Air
11-11-2021, 03:55 PM
#2161
Gets Weekends Off
Joined APC: Jul 2014
Position: And hold
Posts: 311
Originally Posted by JohnBurke
or the regulation is too hard to understand (how is it that others understand it, but not you?) smacks of ignorance and laziness.
Yet I am not the only one who had it wrong. I even studied the law in college (but I am not a lawyer). Yet how many companies out there are misinterpreting the regulations? I know of at least 3 just in my own employment history, 4 if you count BTQ. Hell in my past employment history one company has a pilot flying without a commercial license for the class of aircraft he is flying. Still flying despite an investigation 2 years later. That is black and white. You either have a commercial certificate for the class of aircraft or you don't. Doesn't get any simpler than that and we are talking about a nation wide 135 who still has it wrong.
Another company hired a pilot who didn't have the correct certificates and it wasn't till he got to flight safety that it was noticed. This after being interviewed by 4 different pilots including the chief pilot, HR and various other people involved in the onboarding process. Another company Chief Pilot told me a test light not activating as required from the POH meant the aircraft was still airworthy. Even showing him in plan English, direct out of the POH that the aircraft should not fly without that light illuminating the airplane could not take off, he still argued with me the lowly line pilot.
So I am not the only one who misinterpreted the regulations. Based on the BTQ story the previous FSDO did too or they were not doing their job.
You are absolutely correct with everything you said above. Not disagreeing with you. The fact of the matter is our system is broken. This is happening at far too many companies. I don't need to give you examples because they were front page news over the last two years. The very regulation we are discussing is confusing. It clearly says a SIC is required, but then there is a exclusion that you can't find in the FARs. You have to go look elsewhere to do it. You don't think that ends up leading to misunderstandings? Apparently even the FAA didn't get it right.
Add to that pointing out the obvious incorrect interpretation of the regulation is grounds for termination in aviation (ask me how I know). If you are a young pilot just starting out are you going to speak up in the middle of ground school to tell the Chief their interpretation of the regulation is wrong? I did that once it got me fired, FAA did squat about it. Now imagine you are a brand new pilot with a thirty thousand dollar training contract just starting your career.
You are 100% correct we should know this stuff. But clearly since so many get it so wrong so often something is more wrong than one pilot who didn't read the regs enough for your liking.
11-11-2021, 04:47 PM
#2162
Disinterested Third Party
Joined APC: Jun 2012
Posts: 6,026
Originally Posted by Av8tr1
Yet I am not the only one who had it wrong. I even studied the law in college (but I am not a lawyer). Yet how many companies out there are misinterpreting the regulations? I know of at least 3 just in my own employment history, 4 if you count BTQ. Hell in my past employment history one company has a pilot flying without a commercial license for the class of aircraft he is flying. Still flying despite an investigation 2 years later. That is black and white. You either have a commercial certificate for the class of aircraft or you don't. Doesn't get any simpler than that and we are talking about a nation wide 135 who still has it wrong.
Now you're attempting to justify ignorance based on what an employer understands or misunderstands?
I've flown for a few more operators than you. Perhaps more than a few. I've never flown for a reputable operator that did not fully understand the regulation that applied to that operator, or that was allowed to operate outside the regulation. No, what we're talking about here is what you don't understand, and apparently didn't bother to try, for your last "few airlines" (by "airline," you appear to mean 135 operator).
It's pilot certificate. Not license. We don't issue pilot licenses in the USA.
You're claiming that a certificate holder (a "nation wide 135" certificate holder) utilized pilots that lacked the certification to fly? Are you referring to the case of a pilot who lacked a single engine land category and class rating on his commercial pilot certificate, to which you've alluded in other past posts? Which operator is this?
How many companies are "misinterpreting the regulation," as you put it, is irrelevant to whether or not you are required to know and abide it. Stop making excuses. The buck stops in the cockpit. Act like it.
Originally Posted by Av8tr1
Another company hired a pilot who didn't have the correct certificates and it wasn't till he got to flight safety that it was noticed. This after being interviewed by 4 different pilots including the chief pilot, HR and various other people involved in the onboarding process. Another company Chief Pilot told me a test light not activating as required from the POH meant the aircraft was still airworthy. Even showing him in plan English, direct out of the POH that the aircraft should not fly without that light illuminating the airplane could not take off, he still argued with me the lowly line pilot.
So I am not the only one who misinterpreted the regulations. Based on the BTQ story the previous FSDO did too or they were not doing their job.
So I am not the only one who misinterpreted the regulations. Based on the BTQ story the previous FSDO did too or they were not doing their job.
Originally Posted by Av8tr1
The fact of the matter is our system is broken. This is happening at far too many companies.
The system is not broken. You're simply ignorant of the regulation, and operations specifications, which is quite remarkable, given that you've flown for three or four "airlines."
Originally Posted by Av8tr1
. The very regulation we are discussing is confusing. It clearly says a SIC is required, but then there is a exclusion that you can't find in the FARs. You have to go look elsewhere to do it. You don't think that ends up leading to misunderstandings? Apparently even the FAA didn't get it right.
As I provided you, with links, the regulation very clearly states what is required. If operated under IFR, a second in command is required. If an approved autopilot is provided, and the certificate holder holds the appropriate Operations Specifications assigned to that certificate holder, then the autopilot may be used in lieu of a SIC. This is not a new regulation. This not not a recent change. This is spelled out very clearly in the regulation, as I posted, as you quoted, and as provided with links to the ecfr.gov website which contains it, and references to the Federal Register sections in which the regulation was published, and the reasons for the regulation, with arguments for and against, clearly explained.
You didn't know you could go to the Federal Register to gain an understanding of the regulation, did you? It's the primary source for interpretation of the regulation. The second will be the Chief Legal Counsel letters of interpretation. The third is the regulation itself. The fourth, which does not set precedent, are administrative law judge findings and board decisions. Neither a certificate holder, nor anyone at the FSDO level, is empowered, or authorized to interpret the regulation. This includes the POI. Do you not know this?
You do now.
Originally Posted by Av8tr1
Add to that pointing out the obvious incorrect interpretation of the regulation is grounds for termination in aviation (ask me how I know). If you are a young pilot just starting out are you going to speak up in the middle of ground school to tell the Chief their interpretation of the regulation is wrong? I did that once it got me fired, FAA did squat about it. Now imagine you are a brand new pilot with a thirty thousand dollar training contract just starting your career.
You say "the FAA did squat about it," as if the FAA has some obligation to plead for your job after you mouth off in ground school. That's not the FAA's job. That's not what the FAA does. Apparently you don't understand that, either. A clear picture is forming of your past, and present state.
Seeing as you brought it up, however, you've tossed out the carrot, so 'fess up. You corrected the chief pilot by telling him how to do his job, in class, in front of others, got fired, and what happened to your "thirty thousand dollar training contract?" Who do you suppose was responsible for that contract? The FAA? Other pilots? Other companies? Whom might one blame for your breach of etiquette?
Originally Posted by Av8tr1
You are 100% correct we should know this stuff. But clearly since so many get it so wrong so often something is more wrong than one pilot who didn't read the regs enough for your liking.
11-11-2021, 05:20 PM
#2163
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,469
Originally Posted by JohnBurke
As I provided you, with links, the regulation very clearly states what is required. If operated under IFR, a second in command is required. If an approved autopilot is provided, and the certificate holder holds the appropriate Operations Specifications assigned to that certificate holder, then the autopilot may be used in lieu of a SIC. This is not a new regulation. This not not a recent change. This is spelled out very clearly in the regulation, as I posted, as you quoted, and as provided with links to the ecfr.gov website which contains it, and references to the Federal Register sections in which the regulation was published, and the reasons for the regulation, with arguments for and against, clearly explained.
11-11-2021, 05:28 PM
#2164
Disinterested Third Party
Joined APC: Jun 2012
Posts: 6,026
A SIC is always required under IFR under 135. An authorization is required to fly with autopilot in lieu of a SIC, but not to fly with an SIC, as that's already a regulatory requirement. An operator may hold authorization to fly single pilot with autopilot, but is not required to do so. An operator to whom is issued A015 is not required to operate single pilot with an autopilot, and may operate with a SIC, if the company has a SIC program and a SIC-qualified pilot is available.
No additional authorization or special dispensation or operations specification is required to follow the requirement of the FAR, which is a SIC for operations under IFR.
There is no operations specification, or authorization, for the FAA to withdraw, which permits the operator to use the SIC, and there is no authorization to use a SIC in lieu of an autopilot. No authorization needed, or given, and no such OpSpec to withdraw, as the base regulation always requires the SIC. It's the authorization to operate single pilot with autopilot in lieu of an SIC, that the FAA can withdraw. Not the other way around.
We've established that quite clearly, with links, at this point.
No additional authorization or special dispensation or operations specification is required to follow the requirement of the FAR, which is a SIC for operations under IFR.
There is no operations specification, or authorization, for the FAA to withdraw, which permits the operator to use the SIC, and there is no authorization to use a SIC in lieu of an autopilot. No authorization needed, or given, and no such OpSpec to withdraw, as the base regulation always requires the SIC. It's the authorization to operate single pilot with autopilot in lieu of an SIC, that the FAA can withdraw. Not the other way around.
We've established that quite clearly, with links, at this point.
11-11-2021, 05:46 PM
#2165
Gets Weekends Off
Joined APC: Apr 2007
Posts: 867
JB—
The only point you made with which I disagree is regarding the FSDO system. This ordeal appears to have been triggered by a change in oversight. The old one was good with a wink-n-a-nod. The new one not so much. I know another area where the FSDO is cool with loose interpreations of 135.293 and 267.
The only point you made with which I disagree is regarding the FSDO system. This ordeal appears to have been triggered by a change in oversight. The old one was good with a wink-n-a-nod. The new one not so much. I know another area where the FSDO is cool with loose interpreations of 135.293 and 267.
11-11-2021, 06:31 PM
#2166
Gets Weekends Off
Joined APC: Apr 2007
Posts: 867
An operator may hold authorization to fly single pilot with autopilot, but is not required to do so. An operator to whom is issued A015 is not required to operate single pilot with an autopilot, and may operate with a SIC, if the company has a SIC program and a SIC-qualified pilot is available.
True, however in this case it’s the ability of that SIC to log the flight time IF A015 has been issued and the PIC has a 297(g) check.
The following excerpt is from the Nichols 2009 LOI and the reason the PDP was developed. IF an operator wanted to hold A015 (for operational flexibility), the development of a PDP was the solution…and apparently was ignored by management in this case. It’s not ambiguous. I’m pretty sure it was published before the company began flight operations. There’s no “oops” here. It was ignored. One last thought, do the PC12s have a CVR?
In your Part 135 operation example, you inquire whether an SIC may be utilized for an instrument flight rules (IFR) operation carrying passengers in an aircraft installed with an operativeapprovedautopilotsystem. Specifically,you ask whether the operator may elect to conduct the flight as a one-pilot or a two-pilot operation.
As a general rule, under 14 C.F.R. § 135.101, "no person may operate an aircraft carrying passengersunderIFRunlessthereisasecondincommandint heaircraft." Similartothe rule for a Part 91 operation, if the aircraft's type certification or the regulations under which the flight is being conducted do not require two pilots, a pilot designated as SIC for the Part 135 operation would not be a required flight crewmember and may not log SIC flight time. See Karch Interpretation (Mar. 9, 2000); Karch Interpretation (May 28, 1998).
….
Under sections 135.101 and 135.105, two pilots are required when carrying passengers under IFR unless an operative and approved autopilot system is installed, in which case one pilotisrequired. Althoughsection135.105allowssingle-pilotoperationswiththeuseofan operative approved autopilot system, it does not require that all future flights be conducted in that manner. See Tarsa Interpretation (Mar. 26, 1992). In other words, the operator can elect either to operate under IFR with one pilot using the autopilot system or with two pilots, with the second pilot acting as SIC, without using the autopilot system. See id. Provided the certificate holder elects before the IFR operation to not use the autopilot system, then two pilots are required by the regulations under which the flight is conducted, and the pilot designated as SIC may log SIC flight time. Ifthe autopilot system is used, then the pilot designated as SIC is not a required flight crewmember and may not log SIC time.
As a general rule, under 14 C.F.R. § 135.101, "no person may operate an aircraft carrying passengersunderIFRunlessthereisasecondincommandint heaircraft." Similartothe rule for a Part 91 operation, if the aircraft's type certification or the regulations under which the flight is being conducted do not require two pilots, a pilot designated as SIC for the Part 135 operation would not be a required flight crewmember and may not log SIC flight time. See Karch Interpretation (Mar. 9, 2000); Karch Interpretation (May 28, 1998).
….
Under sections 135.101 and 135.105, two pilots are required when carrying passengers under IFR unless an operative and approved autopilot system is installed, in which case one pilotisrequired. Althoughsection135.105allowssingle-pilotoperationswiththeuseofan operative approved autopilot system, it does not require that all future flights be conducted in that manner. See Tarsa Interpretation (Mar. 26, 1992). In other words, the operator can elect either to operate under IFR with one pilot using the autopilot system or with two pilots, with the second pilot acting as SIC, without using the autopilot system. See id. Provided the certificate holder elects before the IFR operation to not use the autopilot system, then two pilots are required by the regulations under which the flight is conducted, and the pilot designated as SIC may log SIC flight time. Ifthe autopilot system is used, then the pilot designated as SIC is not a required flight crewmember and may not log SIC time.
11-11-2021, 06:58 PM
#2167
Gets Weekends Off
Joined APC: Jul 2014
Position: And hold
Posts: 311
Originally Posted by JohnBurke
Good god.
Now you're attempting to justify ignorance based on what an employer understands or misunderstands?
I've flown for a few more operators than you. Perhaps more than a few. I've never flown for a reputable operator that did not fully understand the regulation that applied to that operator, or that was allowed to operate outside the regulation. No, what we're talking about here is what you don't understand, and apparently didn't bother to try, for your last "few airlines" (by "airline," you appear to mean 135 operator).
It's pilot certificate. Not license. We don't issue pilot licenses in the USA.
You're claiming that a certificate holder (a "nation wide 135" certificate holder) utilized pilots that lacked the certification to fly? Are you referring to the case of a pilot who lacked a single engine land category and class rating on his commercial pilot certificate, to which you've alluded in other past posts? Which operator is this?
How many companies are "misinterpreting the regulation," as you put it, is irrelevant to whether or not you are required to know and abide it. Stop making excuses. The buck stops in the cockpit. Act like it.
Blame other operators. Blame the FAA. Still doesn't absolve you of knowing what you're doing. Perhaps you'd be better served putting your nose in a book rather than someone else's business, and learning your business. Spend less time trying to justify your failing, and more time understanding the policies and regulations that govern what you can and cannot do, and the longevity of your ability to hold a pilot certificate (and not lose it due to enforcement action).
No, it isn't. You simply have no idea what you're talking about. You spent several posts in this thread trying to support bad information, were set straight, then continued by saying you realized how everything worked some time ago after flying for several "airlines," except that, of course, you didn't learn it very well...because in this very thread you've been espousing the exact opposite of the truth (and then trying to justify it by blaming everyone else).
The system is not broken. You're simply ignorant of the regulation, and operations specifications, which is quite remarkable, given that you've flown for three or four "airlines."
The FAA got it precisely right. The regulation is neither ambiguous, nor confusing. Your problem, it seems, is that you still don't know how an operations specification works, or how or why they're issued, or how they apply to you. Again, very remarkable, given that you've flown for three or four "airlines." You still don't understand Operations Specifications? How can this be?
As I provided you, with links, the regulation very clearly states what is required. If operated under IFR, a second in command is required. If an approved autopilot is provided, and the certificate holder holds the appropriate Operations Specifications assigned to that certificate holder, then the autopilot may be used in lieu of a SIC. This is not a new regulation. This not not a recent change. This is spelled out very clearly in the regulation, as I posted, as you quoted, and as provided with links to the ecfr.gov website which contains it, and references to the Federal Register sections in which the regulation was published, and the reasons for the regulation, with arguments for and against, clearly explained.
You didn't know you could go to the Federal Register to gain an understanding of the regulation, did you? It's the primary source for interpretation of the regulation. The second will be the Chief Legal Counsel letters of interpretation. The third is the regulation itself. The fourth, which does not set precedent, are administrative law judge findings and board decisions. Neither a certificate holder, nor anyone at the FSDO level, is empowered, or authorized to interpret the regulation. This includes the POI. Do you not know this?
You do now.
Sounds like you needed to learn to keep your mouth shut.
You say "the FAA did squat about it," as if the FAA has some obligation to plead for your job after you mouth off in ground school. That's not the FAA's job. That's not what the FAA does. Apparently you don't understand that, either. A clear picture is forming of your past, and present state.
Seeing as you brought it up, however, you've tossed out the carrot, so 'fess up. You corrected the chief pilot by telling him how to do his job, in class, in front of others, got fired, and what happened to your "thirty thousand dollar training contract?" Who do you suppose was responsible for that contract? The FAA? Other pilots? Other companies? Whom might one blame for your breach of etiquette?
Repeat that sentence again in English, and we'll talk.
Now you're attempting to justify ignorance based on what an employer understands or misunderstands?
I've flown for a few more operators than you. Perhaps more than a few. I've never flown for a reputable operator that did not fully understand the regulation that applied to that operator, or that was allowed to operate outside the regulation. No, what we're talking about here is what you don't understand, and apparently didn't bother to try, for your last "few airlines" (by "airline," you appear to mean 135 operator).
It's pilot certificate. Not license. We don't issue pilot licenses in the USA.
You're claiming that a certificate holder (a "nation wide 135" certificate holder) utilized pilots that lacked the certification to fly? Are you referring to the case of a pilot who lacked a single engine land category and class rating on his commercial pilot certificate, to which you've alluded in other past posts? Which operator is this?
How many companies are "misinterpreting the regulation," as you put it, is irrelevant to whether or not you are required to know and abide it. Stop making excuses. The buck stops in the cockpit. Act like it.
Blame other operators. Blame the FAA. Still doesn't absolve you of knowing what you're doing. Perhaps you'd be better served putting your nose in a book rather than someone else's business, and learning your business. Spend less time trying to justify your failing, and more time understanding the policies and regulations that govern what you can and cannot do, and the longevity of your ability to hold a pilot certificate (and not lose it due to enforcement action).
No, it isn't. You simply have no idea what you're talking about. You spent several posts in this thread trying to support bad information, were set straight, then continued by saying you realized how everything worked some time ago after flying for several "airlines," except that, of course, you didn't learn it very well...because in this very thread you've been espousing the exact opposite of the truth (and then trying to justify it by blaming everyone else).
The system is not broken. You're simply ignorant of the regulation, and operations specifications, which is quite remarkable, given that you've flown for three or four "airlines."
The FAA got it precisely right. The regulation is neither ambiguous, nor confusing. Your problem, it seems, is that you still don't know how an operations specification works, or how or why they're issued, or how they apply to you. Again, very remarkable, given that you've flown for three or four "airlines." You still don't understand Operations Specifications? How can this be?
As I provided you, with links, the regulation very clearly states what is required. If operated under IFR, a second in command is required. If an approved autopilot is provided, and the certificate holder holds the appropriate Operations Specifications assigned to that certificate holder, then the autopilot may be used in lieu of a SIC. This is not a new regulation. This not not a recent change. This is spelled out very clearly in the regulation, as I posted, as you quoted, and as provided with links to the ecfr.gov website which contains it, and references to the Federal Register sections in which the regulation was published, and the reasons for the regulation, with arguments for and against, clearly explained.
You didn't know you could go to the Federal Register to gain an understanding of the regulation, did you? It's the primary source for interpretation of the regulation. The second will be the Chief Legal Counsel letters of interpretation. The third is the regulation itself. The fourth, which does not set precedent, are administrative law judge findings and board decisions. Neither a certificate holder, nor anyone at the FSDO level, is empowered, or authorized to interpret the regulation. This includes the POI. Do you not know this?
You do now.
Sounds like you needed to learn to keep your mouth shut.
You say "the FAA did squat about it," as if the FAA has some obligation to plead for your job after you mouth off in ground school. That's not the FAA's job. That's not what the FAA does. Apparently you don't understand that, either. A clear picture is forming of your past, and present state.
Seeing as you brought it up, however, you've tossed out the carrot, so 'fess up. You corrected the chief pilot by telling him how to do his job, in class, in front of others, got fired, and what happened to your "thirty thousand dollar training contract?" Who do you suppose was responsible for that contract? The FAA? Other pilots? Other companies? Whom might one blame for your breach of etiquette?
Repeat that sentence again in English, and we'll talk.
FYI, I know you are the oracle of FARs but you might look up how the FAA defines "airline" it isn't "just" 121.
11-11-2021, 07:06 PM
#2168
Disinterested Third Party
Joined APC: Jun 2012
Posts: 6,026
There have been a number of cases in the past in which operators had a single pilot authorization, and put a SIC in the airplane and told the SIC to log not only SIC on "live" legs, but when sole manipulator, to log PIC.
The PDP exists for little more than allowing logging of time within a narrow set of circumstance. The regulatons already cover when a pilot is required or not, and what authorizations are available, or not. The PDP is a development meant for allowing the logging of time and the "training" of a SIC. In essence, it's a regulatory loophole opening up a space for those charging for the right seat, or using otherwise unqualified persons.
Those who are operating under this authorization should know it thoroughly, whether operating as PIC or SIC/trainee.
If an employee believes that an employer is operating outside the regulation and placing the employees certificate in jeopardy, it behooves the employee to protect his career; the option to report the operator exists, but the safest bet is to find other work.
Trying to explain to a chief pilot why he, and his company, are wrong or in violation of the regulation, in the first days of employment, are an outstanding way to lose one's job before it starts.
This is a lie: I said no such thing. Because you have consistently lied here, and continued to make excuses, and moreover insisted on blaming everyone but yourself for your errors, and given your grammar difficulties, there any further interaction with you is a waste of time. You're best placed on the ignore list.
FYI, I know you are the oracle of FARs but you might look up how the FAA defines "airline" it isn't "just" 121.
You may do well to absorb the concept that it's often to best to keep your trap shut and appear the fool, than open it and remove all doubt. You seem bent on the latter. If you believe that citing regulation and providing links makes one an oracle, it's little wonder that you've exercised such poor understanding of both regulation and your operations specifications, and no small surprise that you understand neither.
By all means, you keep insisting that your 135 experience at substandard operators is an "airline background." Don't let the laughter get you down. Ignore list, for you.
The PDP exists for little more than allowing logging of time within a narrow set of circumstance. The regulatons already cover when a pilot is required or not, and what authorizations are available, or not. The PDP is a development meant for allowing the logging of time and the "training" of a SIC. In essence, it's a regulatory loophole opening up a space for those charging for the right seat, or using otherwise unqualified persons.
Those who are operating under this authorization should know it thoroughly, whether operating as PIC or SIC/trainee.
If an employee believes that an employer is operating outside the regulation and placing the employees certificate in jeopardy, it behooves the employee to protect his career; the option to report the operator exists, but the safest bet is to find other work.
Trying to explain to a chief pilot why he, and his company, are wrong or in violation of the regulation, in the first days of employment, are an outstanding way to lose one's job before it starts.
Originally Posted by Av8tr1
According to you the very topic of discussion apparently has only happened to me.
Originally Posted by Av8tr1
FYI, I know you are the oracle of FARs but you might look up how the FAA defines "airline" it isn't "just" 121.
By all means, you keep insisting that your 135 experience at substandard operators is an "airline background." Don't let the laughter get you down. Ignore list, for you.
11-11-2021, 07:47 PM
#2169
Gets Weekends Off
Joined APC: Jul 2014
Position: And hold
Posts: 311
Originally Posted by JohnBurke
There have been a number of cases in the past in which operators had a single pilot authorization, and put a SIC in the airplane and told the SIC to log not only SIC on "live" legs, but when sole manipulator, to log PIC.
The PDP exists for little more than allowing logging of time within a narrow set of circumstance. The regulatons already cover when a pilot is required or not, and what authorizations are available, or not. The PDP is a development meant for allowing the logging of time and the "training" of a SIC. In essence, it's a regulatory loophole opening up a space for those charging for the right seat, or using otherwise unqualified persons.
Those who are operating under this authorization should know it thoroughly, whether operating as PIC or SIC/trainee.
If an employee believes that an employer is operating outside the regulation and placing the employees certificate in jeopardy, it behooves the employee to protect his career; the option to report the operator exists, but the safest bet is to find other work.
Trying to explain to a chief pilot why he, and his company, are wrong or in violation of the regulation, in the first days of employment, are an outstanding way to lose one's job before it starts.
This is a lie: I said no such thing. Because you have consistently lied here, and continued to make excuses, and moreover insisted on blaming everyone but yourself for your errors, and given your grammar difficulties, there any further interaction with you is a waste of time. You're best placed on the ignore list.
You may do well to absorb the concept that it's often to best to keep your trap shut and appear the fool, than open it and remove all doubt. You seem bent on the latter. If you believe that citing regulation and providing links makes one an oracle, it's little wonder that you've exercised such poor understanding of both regulation and your operations specifications, and no small surprise that you understand neither.
By all means, you keep insisting that your 135 experience at substandard operators is an "airline background." Don't let the laughter get you down. Ignore list, for you.
The PDP exists for little more than allowing logging of time within a narrow set of circumstance. The regulatons already cover when a pilot is required or not, and what authorizations are available, or not. The PDP is a development meant for allowing the logging of time and the "training" of a SIC. In essence, it's a regulatory loophole opening up a space for those charging for the right seat, or using otherwise unqualified persons.
Those who are operating under this authorization should know it thoroughly, whether operating as PIC or SIC/trainee.
If an employee believes that an employer is operating outside the regulation and placing the employees certificate in jeopardy, it behooves the employee to protect his career; the option to report the operator exists, but the safest bet is to find other work.
Trying to explain to a chief pilot why he, and his company, are wrong or in violation of the regulation, in the first days of employment, are an outstanding way to lose one's job before it starts.
This is a lie: I said no such thing. Because you have consistently lied here, and continued to make excuses, and moreover insisted on blaming everyone but yourself for your errors, and given your grammar difficulties, there any further interaction with you is a waste of time. You're best placed on the ignore list.
You may do well to absorb the concept that it's often to best to keep your trap shut and appear the fool, than open it and remove all doubt. You seem bent on the latter. If you believe that citing regulation and providing links makes one an oracle, it's little wonder that you've exercised such poor understanding of both regulation and your operations specifications, and no small surprise that you understand neither.
By all means, you keep insisting that your 135 experience at substandard operators is an "airline background." Don't let the laughter get you down. Ignore list, for you.
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