Part 135 pilot doing part 91 side work?

av8tr1

av8tr1

"Never tell me the odds!"
I just started working for a 135 scheduled operator. I also do flight instruction and helicopter rides for another company on the side. The company has approved me to do the part time part 91 work as long as it doesn't impact my ability to meet the 135 schedule.

I was told that I can't do any "paid or commercial" work that exceeds 120 hours a month (or 8 hour, 24 hour look back and 7 day rules). But I've heard from others that I can do all the Part 91 work I can handle and it doesn't count for my 120 hours in a calendar month as long as don't impact my duty rest?

I'd like to keep doing helicopter flight instruction while flying for the 135. But the 135 gets priority. Can I make this work or should I forget the heli stuff?
 
av8tr1 said:
I just started working for a 135 scheduled operator. I also do flight instruction and helicopter rides for another company on the side. The company has approved me to do the part time part 91 work as long as it doesn't impact my ability to meet the 135 schedule.

I was told that I can't do any "paid or commercial" work that exceeds 120 hours a month (or 8 hour, 24 hour look back and 7 day rules). But I've heard from others that I can do all the Part 91 work I can handle and it doesn't count for my 120 hours in a calendar month as long as don't impact my duty rest?

I'd like to keep doing helicopter flight instruction while flying for the 135. But the 135 gets priority. Can I make this work or should I forget the heli stuff?
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So now that you're flying 135 you need to learn really quick that you employer's interpretation of the regulations is quite often incredibly wrong. You cannot generally call the company and say, is X legal? If/when you get violated for something the CP or DO said was cool, I promise they will not have your back, and "but the CP said it was ok" is not a legal defense.
YMMV, and this may or may not apply to this situation.
 
You said in another thread that lines were being constructed at 100-116 hours of flying.

Part 135 max is 120. How much time does that leave for Part 91 flying?

Furthermore, as someone who has flown right to the monthly limit, you're not going to want to see, let alone fly on your time off. You will want what little time you have to rest and spend with your family.
 
So what I am hearing from different places is 91 does not count for the 120 a month. Even in ground school something was said to the effect of we can fly you part 91 all day. I would have to go back to my notes, which aren't with me to be sure.

This obviously doesn't make sense.

I've looked over the reg and it seems pretty clear, nothing over 120 period.dot in a calendar month. So with both the company and some other pilots I know saying there is some wiggle room I came to you guys.

Yes, we are running lines that are 100-116 a month. But not all of them. Its all in how you bid. Since I am not a time builder I will probably be bidding for the lower time routes. Those could be as low as 80-100 a month leaving me plenty of time for other commercial flying activities. Mainly our hog hunts (for the fun) and fair rides (for the women, giggity).
 
Also, just because you bid for a low time line doesn't mean that you will get awarded that line. Swaps and trades can be near impossible, plus (unless things have changed) there is no rhyme or reason behind new schedules. You could plan for something weeks in advance and have another bid come out that messes you up.
 
av8tr1 said:
So what I am hearing from different places is 91 does not count for the 120 a month. Even in ground school something was said to the effect of we can fly you part 91 all day. I would have to go back to my notes, which aren't with me to be sure.
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They CAN fly you part 91 all day. You can also go fly part 91 all day. However, any flight you do under part 135 looks at your total flight time for the month (under any FAR part) and that number can not exceed 120 hours.

Clear as mud?
 
The reg is pretty clear. Under 135 thou shalt not partake in any commercial flying over the limits in 135.265. That means that at any point that you are operating an airplane under 135, your time in ALL commercial flying whether 135, 121, or 91 cannot exceed the maximums. 91 has no such rule so you could in theory fly 120 hours of 135 in a month then fly 10 more hours 91 before the end of the month and be legal. Or fly 1200 hours 135 by November 30th and then fly 100 hours of 91 commercial in December. And of course you can fly 91 personal as much as you want. But for them to make the blanket statement that any amount of 91 flying is fine, is so blatantly incorrect that I suspect you either misheard or misinterpreted what was said.
 
BobDDuck said:
They CAN fly you part 91 all day. You can also go fly part 91 all day. However, any flight you do under part 135 looks at your total flight time for the month (under any FAR part) and that number can not exceed 120 hours.

Clear as mud?
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Yep, that's what I was seeing. I can fly 720 hours part 91 but the minute I fly 135, I am limited to no more than 120 hours in that calendar month.

So as long as I do my 120 hours next month first. I should be able to go and fly the Part 91 stuff after?
 
Roger Roger said:
The reg is pretty clear. Under 135 thou shalt not partake in any commercial flying over the limits in 135.265. That means that at any point that you are operating an airplane under 135, your time in ALL commercial flying whether 135, 121, or 91 cannot exceed the maximums. 91 has no such rule so you could in theory fly 120 hours of 135 in a month then fly 10 more hours 91 before the end of the month and be legal. Or fly 1200 hours 135 by November 30th and then fly 100 hours of 91 commercial in December. And of course you can fly 91 personal as much as you want. But for them to make the blanket statement that any amount of 91 flying is fine, is so blatantly incorrect that I suspect you either misheard or misinterpreted what was said.
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I'm sure I misinterpreted it. Hence my question here.
 
av8tr1 said:
So as long as I do my 120 hours next month first. I should be able to go and fly the Part 91 stuff after?
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Yes. As long as you don't fly any 135 while you are over 120 hours you are legal. That's the benefit of still being on a calendar month system, unlike under 117 where it is rolling.
 
av8tr1 said:
Yep, that's what I was seeing. I can fly 720 hours part 91 but the minute I fly 135, I am limited to no more than 120 hours in that calendar month.

So as long as I do my 120 hours next month first. I should be able to go and fly the Part 91 stuff after?
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It will take you all month to fly the 120 hours of 135 time.

If you really, really, really want to do the hog hunts (wouldn't push my luck with the fair rides), I would suggest talking with the CP/DO well in advance and explain the situation and see if they can block out a few hours that particular month. If they agree... get everything in writing (and signed)!
 
He knows, and is actually planning to come take a ride with me.

I don't have it in writing though and doubt I will get it. The 135 has priority so if it looks like I am going to impact the schedule I wont do the heli work. I am the back up pilot for the heli company so not a big deal if I can't do rides one weekend. Its rare we go over 10 hours of rides.
 
av8tr1 said:
He knows, and is actually planning to come take a ride with me.

I don't have it in writing though and doubt I will get it. The 135 has priority so if it looks like I am going to impact the schedule I wont do the heli work. I am the back up pilot for the heli company so not a big deal if I can't do rides one weekend. Its rare we go over 10 hours of rides.
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If you can't get it in writing... don't do it.

If something goes wrong/you bust flight hours/cancel a flight/etc. after doing outside commercial flying -- management will hang you out to dry.
 
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