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Acting as SIC in part 135. Advice?

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Old 12-03-2015, 04:07 PM
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Default Acting as SIC in part 135. Advice?

Hey everyone,

I fly for a part 91/135 operator somewhere way off the grid. US terrirory. Been here for a couple months.

I was hired under a contract to fly part 91 flights. However, the company also operates scheduled and non scheduled 135 on Navajos.

My problem is they are requiring me to act as SIC on these 135 flights without adding me to the 135 certificate. I act as a full crew member, in uniform, performing checklists and various parts of aircraft operation.

They tell me I am required to be there, (hasn't always been that way) and tell me I cannot log any of the hours. I have received no training or 135 checkride, yet they continue to operate with SICs like myself.

My fear is that I am doing something illegal here and the company is forcing us to do so or get fired.

Acting as SIC on the Navajo is not in my contract or job description. I certainly did not come all this way around the world to not log hours.

My contract does not bind me here. I can leave at will with no cost.

I'm at 387 TT and this is my first flying job. I would appreciate some direction here.

Thank you.
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Old 12-03-2015, 05:17 PM
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Are the flights IFR or VFR? If IFR, Is there an autopilot installed and operational? Do you know if the company has been issued Operations Specification A015 (Autopilot in lieu of SIC)?

Since the PA-31 is type certificated for single pilot, the only reason I can see them needing an SIC is 135 IFR, passenger carrying. To do that legally, you would need training and a 135.293 check. If no training or 135 check, you are essentially a passenger occupying the right front seat and legally cannot even touch the flight controls per 135 regs.

The burden is on the company, not you. However, If I were in hour shoes, I would not want to risk my pilot certificate...
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Old 12-03-2015, 06:22 PM
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Yeah, that sounds a little hinky. Our company has SICs that fly in our aircraft that are certified for single pilot. But they are given a 135.293 check ride. And per our ops specs we can make them required crew members because we have provisions for low visibility take offs that require two pilots. And they log the time.

Your situation sounds more like they are just trying to placate a customer by letting them see two "pilots" sitting up front, though it seems they really don't want you there as a pilot because then they would have to pay you.

As I said... Hinky.
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Old 12-03-2015, 07:33 PM
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The 135 op flys vfr and IFR if the PIC has done a 297 check. None of the pilots they use as SIC have undergone any 135 or PA-31 training whatsoever.

I believe you are correct in that the company just wants to please the customers with the image of two pilots, but doesn't want to actually pay for it.

Today I went the entire day in the right seat logging zero hours. I'm about to call it quits.
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Old 12-03-2015, 07:58 PM
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You should absolutely contact your local FAA office and ask them, give them the entire story. Ask them what they think. With the new compliance philosophy, they won't be looking to burn you at the stake. The new CP is intended for people that want to do the right thing.

Last edited by JamesNoBrakes; 12-03-2015 at 08:18 PM.
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Old 12-03-2015, 11:16 PM
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I'm tempted to call the FAA, but I am afraid I will somehow be implicated and get in trouble.

I almost don't want to risk it. What about making an anonymous phone call to the FAA?
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Old 12-03-2015, 11:28 PM
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Yes, the airplanes have functional AP. I'm not sure about our op specs. But I'm positive an SIC is not required by the company, insurance or anyone.

In the past, all our ops flew single pilot. The company using SICs is a relatively new thing. But the big boss was pretty serious about it. Sent out a company wide email about standardizing the roll of the "first officer".

In this email were a list of responsibilities for the FO, including all pre-flight duties, ensuring the proper fueling, baggage loading etc.

Basically they are requiring us to be crew members in the 135 legs, but here's where it gets sneaky. On the flight manifest, we are listed as " front passenger.". Not pilot or crew member.

I'm pretty sure this is how they get away with it. If the FAA were ever to question them, they can just tell them we are pax.

Seems to me I'm in a very difficult position with little leverage.

Obviously the company is lying about there operation and forcing their employees to illegally act as crew members. That's what I know for a fact.
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Old 12-04-2015, 04:55 AM
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Save/safeguard that e-mail! That shows "intent" by the company. On one hand, one has to commend them for wanting to add a level of safety (second crewmember). However, they need to comply with the 135 regs and properly train and qualify the SIC.

What if you get ramp checked? Will you be in uniform, but a passenger? How will you explain that?

You have several options:

-Talk to the Chief Pilot or Director of Operations. Cite 135.95, 135.99, 135.109, 135.113, 135.115, 135.245 and 135.293

-Call FSDO, ask to speak to the company's POI

-Make an annonymous hotline/whistleblower complaint
1-866-TELL-FAA

-Walk (run?) away
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Old 12-04-2015, 06:58 AM
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Check your OpSpecs. A025 is what you're looking for. If that is there, and they meet the requirements of that OpSpec and 135.105, you are not a required crew member. What they are doing would then be legal, but hanging in a grey area.

Legal or not, that is a load of crap and a good reason to find work elsewhere. Are you willing to move to find work?
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Old 12-04-2015, 09:14 AM
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Originally Posted by Awesomebob View Post
Yes, the airplanes have functional AP. I'm not sure about our op specs. But I'm positive an SIC is not required by the company, insurance or anyone.

In the past, all our ops flew single pilot. The company using SICs is a relatively new thing. But the big boss was pretty serious about it. Sent out a company wide email about standardizing the roll of the "first officer".

In this email were a list of responsibilities for the FO, including all pre-flight duties, ensuring the proper fueling, baggage loading etc.

Basically they are requiring us to be crew members in the 135 legs, but here's where it gets sneaky. On the flight manifest, we are listed as " front passenger.". Not pilot or crew member.

I'm pretty sure this is how they get away with it. If the FAA were ever to question them, they can just tell them we are pax.

Seems to me I'm in a very difficult position with little leverage.

Obviously the company is lying about there operation and forcing their employees to illegally act as crew members. That's what I know for a fact.

You're basically a seat warmer. You shouldn't be touching the controls at all under 135, but that is on the PIC.
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