Reclear flight plans under Part 135


Foxtrot Tango Whiskey
I have been trying to find some guidance in relation to the legality of filing and flying a reclear flight plan under part 135. Under part 121 opspec BO-44 is required as per 8900.148.pdf
but under 135 there is no such opspec.

FSIMS states that
"1267. FAR PART 135 EXTENDED OVERWATER OPERATIONS. Although FAR Part 135 does not specifically address the requirements for extended overwater operations, FAR 135.21(a)requires that each operator develop a manual establishing the policies and procedures for operations that are acceptable to the FAA Administrator. One means, but not the only means, that a FAR Part 135 operator may use to develop acceptable extended overwater operations procedures is to show compliance with those portions of FAR Part 121 that correspond to the operation conducted.

A. Flight Planning and Navigation. Flight planning and navigational requirements do not differ from those of Part 121 operators conducting operations in the same airspace (see sections 1 and 4 of this chapter and section 8 of chapter 8 in this volume).

B. Fuel Planning. The operator must provide adequate procedures for compensating with the limitations of forecast winds. One acceptable means an operator may use is to comply with the requirements of FAR 121.641 for reciprocating or turbopropeller aircraft and with the requirements of FAR121.645 for turbojet aircraft. These FAR provide for appropriate en route reserves.

C. Engine-Out En Route Performance Limi t s . The operator must develop procedures to comply with the engine-out performance limitations of FAR Part 135, Subpart I. The operators analysis must show compliance at the most critical point on the route. Under most conditions, engine-out operations require driftdown procedures. Inspectors must ensure that the operators analysis considers how oxygen and aircraft systems are affected by engine loss (see volume 4, section 3)."

Which applies to ETOPS and refers to said 121 guidance, which states...

"(b) For any certificate holder conducting flag or supplemental operations outside the 48 contiguous United States and the District of Columbia, unless authorized by the Administrator in the operations specifications, no person may release for flight or takeoff a turbine-engine powered airplane (other than a turbo-propeller powered airplane) unless, considering wind and other weather conditions expected, it has enough fuel -

(1) To fly to and land at the airport to which it is released;

(2) After that, to fly for a period of 10 percent of the total time required to fly from the airport of departure to, and land at, theairport to which it was released;

(3) After that, to fly to and land at the most distant alternate airport specified in the flight release, if an alternate is required; and

(4) After that, to fly for 30 minutes at holding speed at 1,500 feet above the alternate airport (or the destination airport if no alternate is required) under standard temperature conditions."

But this doesn't apply to Reclear flight planning contingencies. Any enlightenment as to the legalities of this would be much appreciated.