Im trying to set up a deal where I fly out over the gulf dropping buoys for a research company.

I cant seem to figure out what far it would fall under

 

Not enough information is provided.

You may also fall under Part 137.

 

On one hand, to me this is like aerial photography. Where your primarily you are a photographer, just you happen to have to fly a plane to get the photos you want, and it's all part 91. I would think it could be argued that you are a research assistant of sorts, just placing sensors (bueys) that are needed for the purposes of research and the easiest way to place them is by air.

On the other hand, I think some FSDOs might see it as 135 because you are dropping bueys, and they may equate that to delivering cargo for compensation or hire. But if you are only working for say one researcher, and come up with some kind of contractual agreement for the operation, perhaps it would fall into private carriage and be part 91. Also, it might be viewed differently if the researcher or other lab assistant rides along to assist with buey dropping.

I'm really not at all familiar with the scope of the Ag regs, and JohnBurke definitely brings up a possibility.

I almost feel that your safest bet would be to call the FSDO where this is going to take place to get their official opinion. Or if you are a member of AOPA maybe call their pilot hotline to see if they have any precedence as to what kind of operation this is.

 

If it's a large aircraft, almost certainly a 125 certificate will be required, but if dispensing operations are involved, a 137 certificate may also be required. Again, not enough details are provided.

 

The aircraft would be no bigger than a seneca 2, It would be for one company. The dates are not scheduled it would be as needed basis usually once a month. Single pilot crew, and I hope to get a contract between us if I am to buy a plane to do this. If no contract I would just rent a plane.

Im not sure what other info one would need, I guess the best thing to do is to call the FSDO as said. I am just hoping I don't have to go through the 135 nightmare process in order to do this.

 

I've dropped sterile insects for pest control (which is specifically exempted from Part 137) under part 91, as a contractor for gov't program, tho' certain states require pilot to hold a state ag license.

I've dropped rabies vaccine baits over many states, and that was all done part 91 on contract, (but for govt. agencies - who have no interest in adding to their own paperworkload). Disperser is along to assure drops do not threaten persons or property.

 

Unless you're transporting persons or property from A to B for hire, you shouldn't have any requirement for a 135 operation, as there are no provisions in 135 that would allow you to do what you propose.

Dropping cargo and returning to base isn't a 135 operation. For a Seneca, Part 125 doesn't apply. Dropping buoys, if no chemical release is associated, likely won't have any need of a 137 certificate. The previous poster who dispensed economic poisons (baits) was exempted from Part 137 by 137.11(c), so long as using a public aircraft).

If instead, the flight also intends to transport persons or property from one base to another, the flight may fall under 135, unless it's a public use aircraft. In most cases, however, where a contracted airplane is used, the government insists on 135 certification if its personnel are carried aboard or transported.

 

Baits aren't economic poisons, they are made of fishmeal/molasses(?) or dog food, and contain packets of canine rabies oral vaccine.

 

thanks 727 gm, The buoys are just that. They are strictly tracking devices .