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Part 135 Extended Overwater Ops. (Ops. Spec B045)

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I think you have to read Para c. 6. It says if you cannot maintain VHF comm., you must ensure your SLRCS works properly and that you monitor the SLRCS continuously. I read that as if you fly a route with 30 min or less VHF comm. loss, you don’t have monitor your SLRCS, that is how we do it. Think about why would you even have B45 if you could not use your SLRCS?
 
Well, I've considered that, but I read Paragraph 6 as a separate issue from Paragraph 5. If you're in that allowed 30 minute gap, you have to monitor your SLRCS continuously.

I do see your point, though. I just wish our bosses would make it clear.
 
After doing some research on my company's ops specs, I found the letter from the NY western atlantic oceanic control (or whatever they're called) that approves our company to operate outside the 30 minute gap. The only condition is that we have a contingency on file with them as to what we would do in the event of a SLRCS failure. Our letter states that in that instance, we'll utilize SATCOM or relay through other aircraft on 121.5. Pretty silly if you ask me, I thought that this would be standard procedure if anyone lost SLRCS.
 
Yeah, we have that too. Everyone is supposed to have that. It's required by Paragraph 4. I still don't see how that cancels out Paragraph 5. That would imply that an air traffic control facility has some jurisdiction or authority over our ops specs, which can't be true.
 

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