Logging time in a PC-12

[Looking4Lower]

You cannot "dispatch" an aircraft that is not carrying revenue passengers or cargo as a Part 135 flight. You can follow all the procedures that you normally follow when dispatching a Part 135 flight - but the flight is Part 91.

Well, I've seen both "methods" firsthand.

When I flew 121 Supplemental Cargo, the first leg was normally considered a 121 leg (if an empty leg, i.e. to go pick up freight). I fly 135 Pax now for a different company, and our GOM specifically states that that first empty leg is considered 91.

 

[CFIse]

Well, I've seen both "methods" firsthand.

When I flew 121 Supplemental Cargo, the first leg was normally considered a 121 leg (if an empty leg, i.e. to go pick up freight). I fly 135 Pax now for a different company, and our GOM specifically states that that first empty leg is considered 91.

With all sure respect you haven't seen both methods. Your Part 121 company "considered" the first leg to be part 121 - and I'm sure you operated in all aspects as if it was Part 121 - but it was a Part 91 flight in the eyes of the FAA.

Your GOM can state that all flights will be conducted with a pink elephant riding shotgun - doesn't make it a regulation, just makes it a company policy (albeit approved by the FAA for your company).

 

[CFIse]

You've got it backwards, hoss. You dispatch 135 (or 121), and then you have the option of going 91 if you're empty. There is also a question of whether you're on demand or scheduled, which would probably make an impact on this discussion.

I thought you flew for Mesa eh?

It has nothing to do with on-demand, scheduled, domestic or any regulation, because there is no regulation that requires an empty flight to be Part 135 or Part 121 - therefore it is a Part 91 flight.

You don't have to dispatch an "empty" leg - that your company chooses to is to make it easier on the pilots and they presume safer in the operation (since that is the whole point of Part 135 and Part 121, to provide an additional layer of safety for the uneducated public).

I'm sorry - I've spent a lot of time working in this area, I know what I'm talking about. If you've just seen it from the pilot's point of view then it's easy to understand how you can be confused - because most companies that have millions of dollars tied up in aircraft decide that in the interests of safety they'll apply their operating certificate rules to empty legs. So to the pilot it looks like a Part 135 leg, smells like a Part 135 leg, and as far as they can tell is a Part 135 leg - but believe me when I tell you that to the FAA it's a Part 91 leg. They won't write you up for passing the FAF without visibility minimums, they won't write you up if you have exceeded the Part 135 duty and flight time maximums, they won't write you up if you haven't left a manifest at the departure etc. etc. They won't write you up because even if the pilot swears on the holy bible it's a Part 135 flight, they know the difference.

 

[CFIse]

This has been argued to death. Whether or not you can is really irrelevant in this situation. If you show up for an interview with a couple of hours of Pilatus time without a high altitude endorsement, they're probably going to grill you on it if they catch it.

Not really - if you show up for an interview with that time in your logbook it will show that you have a good understanding of the regulations as they pertain to logging time. You should not claim any particular expertise in the aircraft and they won't expect you to have any expertise in the aircraft.

A lot of people seem to be confused that professional flying jobs take your logbook and the way it categorises time as gospel. Believe me when I tell you that they do not. They all categorize their time in different ways, and one of the things most of them want to know is your PIC time when you were ACTING as PIC (often know as having "signed for the airplane") - and of course you could not include this time in that category. If you did that, then you should expect a "grilling".

 

[jtrain609]

I'm still waiting for a reference. The word of CFIse doesn't mean much to me. 135 regs trump 91.

It has nothing to do with on-demand, scheduled, domestic or any regulation, because there is no regulation that requires an empty flight to be Part 135 or Part 121 - therefore it is a Part 91 flight.

You don't have to dispatch an "empty" leg - that your company chooses to is to make it easier on the pilots and they presume safer in the operation (since that is the whole point of Part 135 and Part 121, to provide an additional layer of safety for the uneducated public).

I'm sorry - I've spent a lot of time working in this area, I know what I'm talking about. If you've just seen it from the pilot's point of view then it's easy to understand how you can be confused - because most companies that have millions of dollars tied up in aircraft decide that in the interests of safety they'll apply their operating certificate rules to empty legs. So to the pilot it looks like a Part 135 leg, smells like a Part 135 leg, and as far as they can tell is a Part 135 leg - but believe me when I tell you that to the FAA it's a Part 91 leg. They won't write you up for passing the FAF without visibility minimums, they won't write you up if you have exceeded the Part 135 duty and flight time maximums, they won't write you up if you haven't left a manifest at the departure etc. etc. They won't write you up because even if the pilot swears on the holy bible it's a Part 135 flight, they know the difference.

 

[fishrichard]

So when I blast off in the morning empty, to pick up pax, my duty clock and flight time clock starts rolling because it is DISPATCHED 135. Under your examples 135 duty shouldn't start until pax are onboard. I have to agree with jtrain. On the other hand, we can finish off a 13 hour duty 8hour flight day and be released from a flight. If we decide, as a crew, to fly a 4 hour leg home it is completely legit because of the before mentioned release from duty, therefor the flight is considered 91. Just two ways empty flights can be differrent.

 

[EatSleepFly]

I'm sorry - I've spent a lot of time working in this area, I know what I'm talking about.

Clearly, you don't.

they won't write you up if you have exceeded the Part 135 duty and flight time maximums, they won't write you up if you haven't left a manifest at the departure etc. etc.

OH YES, they will! That is absolutely 100% incorrect, at least in some cases. Perhaps it depends on the POI, I don't know. At my last job, the first leg of every trip went out empty, but because it was at the behest of the customer, we were required to operate it under 135. No if's, and's, or but's. That the aircraft is empty had nothing to do with it.

What exactly IS your background with this?

 

[CFIse]

Clearly, you don't.



OH YES, they will! That is absolutely 100% incorrect, at least in some cases. Perhaps it depends on the POI, I don't know. At my last job, the first leg of every trip went out empty, but because it was at the behest of the customer, we were required to operate it under 135. No if's, and's, or but's. That the aircraft is empty had nothing to do with it.

What exactly IS your background with this?

You don't have an FAA regulation or an FAA interpretation or anything from your POI in writing that says you had to "operate it under 135". You may have chosen to operate it, but it was a Part 91 flight.

You, like another poster, may be confusing the requirements related to commercial flight time and their effect on duty and rest requirements.

 

[CFIse]

So when I blast off in the morning empty, to pick up pax, my duty clock and flight time clock starts rolling because it is DISPATCHED 135. Under your examples 135 duty shouldn't start until pax are onboard. I have to agree with jtrain. On the other hand, we can finish off a 13 hour duty 8hour flight day and be released from a flight. If we decide, as a crew, to fly a 4 hour leg home it is completely legit because of the before mentioned release from duty, therefor the flight is considered 91. Just two ways empty flights can be differrent.

You are confusing flight and duty time limitations based upon commerical flight time and the requirement that rest be free from a requirement to be present or available.

The first leg is commercial flight time, because you are being paid, and it is duty because it is not rest, but it is not a Part 135 flight despite your delusion about how you were dispatched. The subsequent Part 135 regulations require lookback to find required rest and to ensure the appropriate daily/between rest periods flight time is not being exceeded - any commercial flight time counts.

Commercial flight time can be accrued under Part 91 or Part 135 (and of course Part 121) but it has absolutely nothing to do with the presence of an operating certificate.

 

[jtrain609]

Don't anybody listen to what this guy has to say unless you're interested in getting violated.

 

[CFIse]

I'm still waiting for a reference. The word of CFIse doesn't mean much to me. 135 regs trump 91.

I cannot give you a reference that specifically states that a flight that does not contain revenue passengers or cargo is a Part 91 flight. All I can do is refer you to Part 119 and Part 135 where the requirements for operating under Part 135 are spelled out. If you have revenue passengers or cargo you must operate under Part 135 - absent either of those conditions you default to operating under Part 91. That's he way the FAA regulations work.

Now - you need to find me a reference that says a flight that does not have revenue passenger and cargo aboard must be operated under Part 135 (don't look to long, you won't find one).

 

[CFIse]

Don't anybody listen to what this guy has to say unless you're interested in getting violated.

It doesn't matter to me if you listen to me or not. There's no harm is pretending you're operating under Part 135 when you are really operating under Part 91. There would be harm if it was the other way around.

You will be happy and safe under the delusion that you are operating under Part 135 regulations - I'm just trying to educate you and the onlookers about your actual correct status. One day this may help you keep you job, because you'll find that your employer will want you to fly a leg and you will say that you cannot because you cannot meet a requirement of Part 135 and your employer, who is smarter than you, will eventually give up arguing with you and just fire you and hire a smarter pilot.

 

[jtrain609]

Stick with 121 regs bro, you don't have a clue in this arena.

If you're all on demand, which almost EVERY freight company is (even if they have "scheduled" runs), and your customer requests that you go to X airport empty to pick up their cargo, you're still acting on their behalf. They're paying you to operate that flight empty, and because you are engaged in common carriage you are hence operating as a 135 flight, no matter what's in the back.

 

[jtrain609]

I take it all back boss. The two 135 training captains and two 135 line pilots that have weighed in on this one don't have a clue. I'm glad a Mesa pilot could enlighten us all.

I hope nobody is listening to you.

It doesn't matter to me if you listen to me or not. There's no harm is pretending you're operating under Part 135 when you are really operating under Part 91. There would be harm if it was the other way around.

You will be happy and safe under the delusion that you are operating under Part 135 regulations - I'm just trying to educate you and the onlookers about your actual correct status. One day this may help you keep you job, because you'll find that your employer will want you to fly a leg and you will say that you cannot because you cannot meet a requirement of Part 135 and your employer, who is smarter than you, will eventually give up arguing with you and just fire you and hire a smarter pilot.

 

[zmiller4]

Not really - if you show up for an interview with that time in your logbook it will show that you have a good understanding of the regulations as they pertain to logging time.

I don't know who you work for or who you've interviewed with, but the airlines I've interviewed with took a very close look at PIC time logged (except Mesa: they said "minimum times--check, pulse--check, $50 application fee...class date!!). American Eagle, for example, WILL NOT accept any time you logged both dual received and PIC time (i.e. working on instrument, commercial, etc). By the regulatory definition you can definately log both dual received and PIC, but Eagle really doesn't give a crap because you're not really PIC.

You should not claim any particular expertise in the aircraft and they won't expect you to have any expertise in the aircraft.

Really, if you log pilot-in-command time in an aircraft, you're saying that you do have at least some knowledge of the systems and operations of the thing.

If you don't have a HA endorsement and you're flying a Pilatus, you're not PIC. You're a student at best.

They all categorize their time in different ways, and one of the things most of them want to know is your PIC time when you were ACTING as PIC (often know as having "signed for the airplane") - and of course you could not include this time in that category. If you did that, then you should expect a "grilling".

OK, so on your resume, do you have an "acting as PIC" column and a "logging PIC" column? Or do you only include the "acting as PIC"? If so, then why on earth are we even having this conversation? What's the point of logging time that you're afraid to show?

 

[SteveC]

OK, so on your resume, do you have an "acting as PIC" column and a "logging PIC" column? Or do you only include the "acting as PIC"? If so, then why on earth are we even having this conversation? What's the point of logging time that you're afraid to show?

I don't have one on my resume, but my logbook has a column for "PIC", and another one that I added for "Part 61 PIC". In the "Part 61 PIC" column I log time that I am sole manipulator of the controls of a jet that I have a type rating for, but my company has designated me as SIC for the flight(s). I do this because some companies will accept this PIC time towards their requirments, while others (most???) do not. I have absolutely no problem explaining my method of logging to a prospective employer, no matter which way they want to see the PIC time. It is not a matter of being "afraid to show" that PIC time, but a realization that different employers may want to see different things.

 

[jtrain609]

True enough Steve, but you're in the corp/frac world, where CFIse and zmiller4 are both working for regionals. An airline will laugh you out of the interview to log the time as CFIse has described, where a corporate flight department might be more interested in figuring out a way to sneak you into the company and work with the insurance company, so with your situation the time can help eh?

 

[zmiller4]

I don't have one on my resume, but my logbook has a column for "PIC", and another one that I added for "Part 61 PIC". In the "Part 61 PIC" column I log time that I am sole manipulator of the controls of a jet that I have a type rating for, but my company has designated me as SIC for the flight(s). I do this because some companies will accept this PIC time towards their requirments, while others (most???) do not. I have absolutely no problem explaining my method of logging to a prospective employer, no matter which way they want to see the PIC time. It is not a matter of being "afraid to show" that PIC time, but a realization that different employers may want to see different things.

I completely understand, and I think your method is excellent, honest answer to a pretty complicated problem. I did the same thing interviewing at Eagle--noted that the difference in PIC time between the logbook and their time grid reflected how their definitions varied from the FAR's.

Your situation, though--being typed in the airplane--is pretty different from what we're discussing above, though. There's no question that you're completely capable of acting as PIC in the plane, while in the PIC in the PC-12 situation above it's clear that the guy wouldn't be able to act as PIC. I know a lot of people who log really dubious PIC time and push the limit of the FAR definitions.

 

[SteveC]

jt and zm, you guys are right, I was getting a little off track. I took the comment about having a separate column for "acting PIC" at face value rather than taking it in context of the whole thread.

 

[zmiller4]

jt and zm, you guys are right, I was getting a little off track. I took the comment about having a separate column for "acting PIC" at face value rather than taking it in context of the whole thread.

You brought up a good solution, though. I'm about to go eat dinner with a guy who's just getting typed in the Lear, even though he'll mostly be SIC--I'm going to discuss your method with him.