Part 91 jet ops and “open write ups”

Say what? Let’s play a game called never have I ever.

I’ll start.

Never have I ever wanted to do charter /135


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Well in most senses of the statement I agree wholeheartedly!
I like the structure provided by the OpsSpecs, and once it’s on 135 it will also brings covered by the MEL.

I’m not working for a place that’s trying to force my hand, and if they do I won’t fly it. I’ve done 135 ops before. I’m just happy to have a flying job, and hope to be back to 121 when the time comes.
 
Well in most senses of the statement I agree wholeheartedly!
I like the structure provided by the OpsSpecs, and once it’s on 135 it will also brings covered by the MEL.

I’m not working for a place that’s trying to force my hand, and if they do I won’t fly it. I’ve done 135 ops before. I’m just happy to have a flying job, and hope to be back to 121 when the time comes.

We took our plane off the 135 certificate when I took over, the only change for us was the need to make sure we didn’t accidentally do operator things. We have LOA’s that cover everything that we had as opsepcs in 135. Having a 135 op manage the plane makes some stuff easier, make sure you pick a good one though, because the penalties for mistakes goes up significantly. ( I.e FSI messes up a pilots training and then pilot flies, 10k per leg on a 135 guy, 91 Guy the penalty mostly ends up at the school house. 135 is supposed to audit training and ensure compliance. )


We’re 91, however we pretty much stick to our “135” days I.e sin every 6 months, full perf flight planning+ dispatch and flight following. Re: the other stuff all of our pilots can, and are encouraged to reject a flight if it’s not safe. Boss has never complained when we say no, as they understand that we don’t say no for arbitrary reasons.

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Never have I ever turned down a broke-ass airplane. Then had to explain to a CP how an MEL worked, and why it was we could not legally fly the plane. Then had a DO concur that the plane was not legal. Then, an hour later the same day, had the plane I turned down dispatched with another pilot with no Mx having occurred.

Funny. In my 121 days I was DH in the back of one of our airplanes. On the way in oil came pouring out of the right engine. (Mega dash, easy view). Called the crew from the FA phone, let them know what I was seeing. Uneventful landing - crew asked me to stick around while they relayed to mx control. MX control had a mechanic come by and check the prop grease (which of course was fine) and sign it off. I ended up calling the DO and telling him flat out, that I was going to wait at the airplane, if the next crew showed up and took the airplane, that I would pull them both off the line (was an LCA at the time). Crew showed up, I told them exactly the same. Massive oil leak, no repairs. If you take the plane I *WILL* remove you from duty. They called DO gave them “ I’ve got an LCA here who says they will pull me off the line if I accept the plane, and that there’s an oil leak?”

Turns out the prop shaft had a leaking main seal, airplane was grounded for a while. Nobody got pulled off the line (which was good because I didn’t actually know if I could arbitrarily do that).

91 gig now is a few orders of magnitude less shady than the 121 carrier, which is nice.


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I’ve been out of the D.O. position for only eight months, so I’m pretty confident that you just send the FSDO a letter requesting an LOA D095 to use the MMEL as an MEL. Provide your source for M&O procedures (most manufacturers provide this) and you should be good to go. Not a difficult process at all.

Guidance (scroll to Part 91 section)

Most MMEL’s hosted FSIMs have the m&o - if you are not altering the MMEL you can also pull it from there.

Kind of silly you can’t just point the FAA to their own document though.


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Most MMEL’s hosted FSIMs have the m&o - if you are not altering the MMEL you can also pull it from there.

Kind of silly you can’t just point the FAA to their own document though.


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Indeed.

But...

Much, much worse than "silly".

Reason destroying...
Trust reducing...
Cognitive Dissonance inducing...
Insubordination inciting...
Hate building...
Crazy making...

Civilization ending... ... ...
 
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