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Part 135 Part 135 commercial operators

Boutique Air

Old 06-12-2018, 06:37 PM
  #1821  
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Originally Posted by Toddzilla View Post
Log it however you want, but I personally wouldn't put a single second of PIC time into my logbook at Boutique if I were under 1200 hours and on a 135 leg. Tagging along on a repo? Knock yourself out.

Not worth having to discuss/explain the minute details of a reg to somebody in an interview in my opinion.
You're either going to have to explain 61.51(e) or 61.51(f).

The other one (SIC in PC12) is widely accepted but very grey area, the other (PIC as sole manipulator) is not as well known but 100% legal.

BTQ flies a lot with zero passengers. Do you log those hours as SIC?
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Old 06-12-2018, 08:04 PM
  #1822  
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Originally Posted by dera View Post
Passenger carrying ops _under IFR_ is what 135.101 says, not all passenger ops. Plenty of 135 VFR flying with no SIC. 135.105 allows for A015. Nothing mandates the use of autopilot in lieu of SIC (as the Tarsa letter says), but - and here's the important part - FAA has never said if the company has A015, you can use both - an SIC, required by 135.101, AND an autopilot, as allowed in 135.105.

I guess the point I'm trying to make here is, that the SIC in a single pilot ship is much murkier, than PIC as sole manipulator of controls.
Ok. So I didn't add the under IFR ops. But I assume that Boutique isn't going to cancel flights because it's cloudy. I also assume that they crew their airplanes planning for their flight crews to be able to operate IFR legally.
I also assume the FAA has never stepped in and said you can't operate with A015 and an SIC either. At least I've never seen anything. However, what's in the OPSPECs is an authorization of what you can do, not what you can't. I don't have A015 in front of me, but I don't think it says anywhere in there where you CAN't operate with an SIC. Correct me if I'm wrong, but it says if the pilot is rated and the aircraft type allows it with an appropriate autopilot, the operator MAY operate single-pilot. Paraphrasing of course.

I agree it's not explicitly stated, but that needs to be discussed with the company. The best thing would be to ask the FAA for their interpretation on whether or not A015 can be disreguarded if you have an SIC. I haven't ever seen an interpretatoin on that and I'd be interested in what they say. As always, I bet if you asked 2 FSDOs you'd get 2 different answers.

Of course all of this depends on whether the company puts you through single-pilot training and awards you a single pilot type rating.

Last edited by EMAW; 06-12-2018 at 08:15 PM.
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Old 06-12-2018, 08:11 PM
  #1823  
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Originally Posted by dera View Post
BTQ flies a lot with zero passengers. Do you log those hours as SIC?
I could justify this. The operator I fly for has a lot of empty legs, and the trip sheets are marked as 91 legs but only to show that they are reposition legs. EVERY leg is flown under 135 Regs. 0 issues logging SIC as assigned SIC on the flight.
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Old 06-12-2018, 08:21 PM
  #1824  
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Originally Posted by EMAW View Post
I could justify this. The operator I fly for has a lot of empty legs, and the trip sheets are marked as 91 legs but only to show that they are reposition legs. EVERY leg is flown under 135 Regs. 0 issues logging SIC as assigned SIC on the flight.
No no no no no NOOOOO!

If you mark the trip sheet as 91 leg, _IT IS FLOWN AS PART 91!!_
I cannot emphasize that enough. The part in the trip sheet that says it's Part 91 means it's Part 91. Not some pseudo-135. The fact that you fly in a 135 operation DOES NOT mean the empty legs are flown 135. Your trip sheet will say what regulations you follow. Part 91 does not just "show they are reposition legs", it means you are flying under Part 91 and 135 limitations and regs do not apply.

And continuing - why does an empty leg require an SIC? It is NOT passenger carrying operation.
Don't say "zero issues" when there are plenty.
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Old 06-12-2018, 08:25 PM
  #1825  
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Originally Posted by EMAW View Post
I also assume the FAA has never stepped in and said you can't operate with A015 and an SIC either. At least I've never seen anything. However, what's in the OPSPECs is an authorization of what you can do, not what you can't. I don't have A015 in front of me, but I don't think it says anywhere in there where you CAN't operate with an SIC. Correct me if I'm wrong, but it says if the pilot is rated and the aircraft type allows it with an appropriate autopilot, the operator MAY operate single-pilot. Paraphrasing of course.

I agree it's not explicitly stated, but that needs to be discussed with the company. The best thing would be to ask the FAA for their interpretation on whether or not A015 can be disreguarded if you have an SIC. I haven't ever seen an interpretatoin on that and I'd be interested in what they say. As always, I bet if you asked 2 FSDOs you'd get 2 different answers.
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.
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Old 06-12-2018, 09:38 PM
  #1826  
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Originally Posted by dera View Post
No no no no no NOOOOO!

If you mark the trip sheet as 91 leg, _IT IS FLOWN AS PART 91!!_
I cannot emphasize that enough. The part in the trip sheet that says it's Part 91 means it's Part 91. Not some pseudo-135. The fact that you fly in a 135 operation DOES NOT mean the empty legs are flown 135. Your trip sheet will say what regulations you follow. Part 91 does not just "show they are reposition legs", it means you are flying under Part 91 and 135 limitations and regs do not apply.

And continuing - why does an empty leg require an SIC? It is NOT passenger carrying operation.
Don't say "zero issues" when there are plenty.
Um no. Our OM says we always operate under 135 regs. Flight following, alternate weather requirements, operational control, et al does not change from leg to leg.

I, along with more than half of our pilots, are not single-pilot typed, we are an EOD operator, and we have no A015. So we always have SICs. Also everyone of our trip sheets has a PIC AND SIC designated.
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Old 06-12-2018, 09:44 PM
  #1827  
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Other than training and checkrides, I flew exactly one 91 leg at Boutique. I'm sure pilots in Denver and Dallas flew plenty more than that since they were maintenance bases, though.

And other than that one 91 leg and training flights, I flew three empty 135 legs in a year, and those were due to 12+ hour maintenance delays. Those empty legs still had 135 flight numbers and were counted toward EAS reliability stats, so it's not like you can just magically decide that they are 91 flights.

Like I said, log it however you want and be prepared to explain yourself in an interview, but from what I understand most airlines only want to see PIC time that has your signature for a flight attached to it. By all means split it up according to the regs, but that's a lot more work than I would be willing to do. You don't exactly need a bucket of PIC time to hop into a regional jet anymore. I guess it depends on what your next step is.
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Old 06-12-2018, 10:13 PM
  #1828  
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Originally Posted by EMAW View Post
Um no. Our OM says we always operate under 135 regs. Flight following, alternate weather requirements, operational control, et al does not change from leg to leg.

I, along with more than half of our pilots, are not single-pilot typed, we are an EOD operator, and we have no A015. So we always have SICs. Also everyone of our trip sheets has a PIC AND SIC designated.
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.
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Old 06-12-2018, 10:15 PM
  #1829  
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Originally Posted by Toddzilla View Post
Other than training and checkrides, I flew exactly one 91 leg at Boutique. I'm sure pilots in Denver and Dallas flew plenty more than that since they were maintenance bases, though.

And other than that one 91 leg and training flights, I flew three empty 135 legs in a year, and those were due to 12+ hour maintenance delays. Those empty legs still had 135 flight numbers and were counted toward EAS reliability stats, so it's not like you can just magically decide that they are 91 flights.

Like I said, log it however you want and be prepared to explain yourself in an interview, but from what I understand most airlines only want to see PIC time that has your signature for a flight attached to it. By all means split it up according to the regs, but that's a lot more work than I would be willing to do. You don't exactly need a bucket of PIC time to hop into a regional jet anymore. I guess it depends on what your next step is.
The 135 flight numbers but not carrying passengers did not require an SIC because they were not passenger carrying ops, they just were dispatched as 135 for flight duty requirements.

And again - I agree with you. Log what you want, just remember that the PIC time is "safe", and SIC time is not. I'm trying to say, log it as allowed, because all of your SIC time is an FAA signature away from being worthless.
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Old 06-13-2018, 02:56 AM
  #1830  
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Originally Posted by dera View Post
Nothing in Cato, Nichols, Tarsa etc letters are 100% relevant to this question, they merely touch it but don't directly answer this question. If a company has A015, Tarsa says it does not _mandate_ the operator to use it. But there is nothing in the legal interpretations that says you can use the autopilot while SIC logs SIC time as pilot not flying.

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.
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