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Part 135 Autopilot Question

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iflyjets4food

R.O.N. at home
Joined
Nov 22, 2005
Posts
211
Ok, here's the autopilot question. Our operation flies a 310 under the autopilot exemption. Currently, that autopilot is inop and has been removed from the airplane for service. We don't have any provisions in our ops specs for a SIC. Our DO says that if we put two PIC qualified guys up front in the 310, we can operate that 310 without the autopilot. We have a split though within the company as most of us believe that this is illegal since we don't have anything in our ops specs that cover this. How would you handle it???

This is posted in the Part 135 section as well.
 
The way I understand it is that you need something in your GOM saying that a PIC is dual qualified as a SIC. Shouldn't take much to blast the in there!
 
Unless your operations specifications authorize you to operate with a SIC in lieu of an autopilot, you may not do it. Additionally, you must have had this qualification on your 8410...you can't simply jump in the airplane and go fly, even though it's a single pilot airplane. If your company doesn't have an approved SIC training program, and the person acting as SIC hasn't been given a right seat/SIC qualification, then you aren't authorized to use that person.

Additionally, unless you're operating under the provisions of a MEL for the inoperative and missing autopilot (and unless your weight and balance documentation has been altered to reflect the missing autopilot), then you're not legal.

Your boss is like so many others who are either igorant of the regulation, or simply elect to diregard it in favor of economy, at your expense.

If your training program is designed around single pilot operations and has not addressed cockpit coordination and CRM with a two pilot crew, simply throwing a second crewmember into the mix is contrary to safety, not legal, and inappropriate.

Ask to see it in writing on an approved document...it's got to be in your OpSpecs and should be clearly outlined in your GOM.
 
Unless your operations specifications authorize you to operate with a SIC in lieu of an autopilot, you may not do it. Additionally, you must have had this qualification on your 8410...you can't simply jump in the airplane and go fly, even though it's a single pilot airplane. If your company doesn't have an approved SIC training program, and the person acting as SIC hasn't been given a right seat/SIC qualification, then you aren't authorized to use that person.

Additionally, unless you're operating under the provisions of a MEL for the inoperative and missing autopilot (and unless your weight and balance documentation has been altered to reflect the missing autopilot), then you're not legal.

Your boss is like so many others who are either igorant of the regulation, or simply elect to diregard it in favor of economy, at your expense.

If your training program is designed around single pilot operations and has not addressed cockpit coordination and CRM with a two pilot crew, simply throwing a second crewmember into the mix is contrary to safety, not legal, and inappropriate.

Ask to see it in writing on an approved document...it's got to be in your OpSpecs and should be clearly outlined in your GOM.

This was my interpretation. After my last checkride, I asked about that. He said that all he has to do is put on the 8410 that I've been checked in both seats and I'm good to go. I haven't read anywhere where it says that I or he can do that.

How would you handle this if you were assigned a trip in the airplane with another pilot? I've got to say that I think I'd have to refuse on the grounds that the airplane doesn't have a weight and balance that reflects the current configuration of the aircraft and that we don't have the paperwork to reflect a crew of two in the airplane.

It makes me angry because I've never had a problem with this company before. I've always felt like they were an 'above average' 135 operator and that I was lucky to work here. When I squawked the autopilot, the Director of Maintenance got all huffy and acted kinda vindictive about it, i.e. "We'll have to send it off and it'll take forever for them to get it fixed, all over the little thing you wrote it up for." I really don't like the idea that this could be the new norm.
 
Unless your operations specifications authorize you to operate with a SIC in lieu of an autopilot, you may not do it. Additionally, you must have had this qualification on your 8410...you can't simply jump in the airplane and go fly, even though it's a single pilot airplane. If your company doesn't have an approved SIC training program, and the person acting as SIC hasn't been given a right seat/SIC qualification, then you aren't authorized to use that person.

Additionally, unless you're operating under the provisions of a MEL for the inoperative and missing autopilot (and unless your weight and balance documentation has been altered to reflect the missing autopilot), then you're not legal.

Your boss is like so many others who are either igorant of the regulation, or simply elect to diregard it in favor of economy, at your expense.

If your training program is designed around single pilot operations and has not addressed cockpit coordination and CRM with a two pilot crew, simply throwing a second crewmember into the mix is contrary to safety, not legal, and inappropriate.

Ask to see it in writing on an approved document...it's got to be in your OpSpecs and should be clearly outlined in your GOM.

I agree with the idea, but the wording is backwards. If you are operating under 135 for passenger-carrying operations under IFR you MUST have a properly trained SIC, unless you have the Op Spec A015 (Autopilot in Lieu of Required Second-in-Command) authorizing use of the autopilot in leiu of an SIC and the SIC has the autopilot signoff on his 8410 (as previously mentioned).

Since the autopilot has been removed, the Ops Specs mean nothing because an SIC is required. If the autopilot was still installed, then the MEL would be another issue. Our BE58 MEL lists a bunch of procedures including something like "May be inoperative provided a current and qualified SIC is assigned to the flight".

I'm not sure that using two PICs would work, but it sounds like a quick call to the FSDO would straighten that out. Avbug is right that this info should be in the GOM or Training Program.
 
If you're flying a single pilot aircraft that doesn't require a SIC, then you aren't authorized the use of a SIC unless your Operations Specifications include such an authorization, and provide for a training program to qualify the SIC. Yes, the 8410 can be annotated to show qualification in either seat...in fact, it must be if you're to fly either way...but you need to have completed approved training, and for this there must be an approved training program.

If the autopilot is to be removed, paperwork must reflect that, including an ammended weight and balance. If the aircraft is to be operated with the autopilot removed, a MEL will be required. Even if the MEL dictates that the autopilot may be inoperative if a SIC is used, this still doesn't authorize th use of a SIC...the Operations Specifications must do that.

The specific use of a SIC is found in 135, where a SIC is required for passenger operations under IFR, unless the operator and pilot is authorized to conduct single pilot operatiosn with an autopilot in lieu of a SIC. The basic use of the SIC isn't what's required via your opspecs and ops manual...the SIC is already required by Part 135...but what is central to the issue is w(h)eather or not you have a SIC training program that's appoved.

When I'm on the road, I use a single disc with all my references on it, and that disc recently got mangled. I'm not where I can quickly order another...so I'm limited on the quotes I can provide...else I'd give you a lot more. Open your GOM...it's all right there, and it will tell you exactly what you can and cannot do. Reference 14 CFR 13...it's all there, too.

As far as the DoM getting huffy...be polite up until that point. If he wants to test you, tell him you were willing to play nice until pushed, and now it's a writeup. He has no choices. When pushed, be polite, then push back harder and firmer, giving up no ground. The proverbial inch given will quickly become a mile, and you don't want that.
 
We solved the issue. Nowhere in our manual or ops specs do we mention having an SIC, let alone an SIC training program for the airplane. The DO had no choice but to ground the airplane for 135 ops until the autopilot is reinstalled. As far as our Dir. of Maint. is concerned, I think he knows where I stand. If it's broken, it will be written up. There is a minimum equipment list that handles it from there. If the FAA is ok with it being broken, we'll be able to defer it. If the FAA has a problem with it being broken, it will shorten the length of time we can defer it. I think it is rediculous to play the role of the MEL myself and determine how long I'll wait to write something up. I don't have near enough experience in aviation (nor will I ever) to be able to determine all the possible problems that could happen in my time of deference on writing something up. I'll write it up. Maintenance will deal with it. Problem solved. Let's just call it job security for maintenance.
 

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