repositioning legs

[hawkercpt]

In a 135 operation, are the repositioning legs indeed under 135 as well? If you are positioning to do a revenue leg then would it not be considered under 135?

 

[vclean]

Depends on how you are dispatched.

 

[pilotyip]

If you are flying into a 135 revenue, leg all the time and duty must count toward 135 flight and duty. If you have no revenue on board, you may operate under certain 91 rules. I.e. Op. Spec C-64 (approved source of weather) need not apply to land at the airport. On tail end, ferries accepted by the crews where fight time or duty has been exceeded can only operate under part 91.

 

[Canucit]

I thought that if it was a non rev flight it was Part 91 unless your op specs says different

 

[pilotyip]

Yes you can operate under 91 on non-rev legs. However all flight time and duty on a 91 leg flying into a revenue leg has to be counted towards 135 limits.

 

[User546]

I second what PilotYip said. That's the way our 135 operates as well.

Saves lots of paperwork on our end doing it that way.

 

[WMUSIGPI]

also when flying internationally (at least at my company) we operate all legs 135 because customs considers us a commercial operation both directions even if we only flew pax one way

 

[soarby007]

part 135 legs

We consider all legs part 135. The customer is usually paying for the whole trip, not just one leg, at least in our operation that is the case. I think it is a little shaky to call it a part 91 leg because no passengers are on board. The key, is 'revenue', and I have been told that if the customer is paying for all legs, then it is revenue. Our DO says we are a part 135 operator, not 91 and to save any confusion, all legs are part 135, unless the owner is flying.

 

[Daveman]

I'll third what the PilotYipper has said. Though we all know of the sinister operators.

 

[Chest Rockwell]

Hawkercpt,

This is another issue that may vary from fed to fed. I have heard inspectors say if the flight is dispatched by the certificate holder or operates under the company call sign, it is 135. I have heard it interpreted as if your job title is as a 135 SIC, then everything you fly for-hire with that company is 135. Others may take a more "common sense view". I suggest calling your FSDO or POI and asking them.

CR