Want to fly under part-135 regs?

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Joined: Mon Jun 23, 2014 3:12 pm
Location: San Francisco, CA

Want to fly under part-135 regs?

Post by RISCfuture »

Anyone else trying to fly these under part 135 regs instead of part 91, like a real charter operator would?

There's a lot of part-135 regs that wouldn't apply in PilotEdge-land, such as training requirements, manual requirements, hiring requirements, drug testing, etc. etc. (though you're welcome to pee in a cup at home for ultimate realism), but I've made a list below of the regs that could apply:

135.304: VFR minimum altitudes. Same as part 91, but also you can't be lower than 500 feet AGL.

135.205: VFR visibility requirements. Same as part 91, but also visibility must be at least 2SM if ceilings are below 1,000.

135.209: VFR over-the-top. Can't do it unless the forecast allows one of the following: a VFR descent and landing at the destination (up to 1 hour past ETA), VFR down to the initial approach point where an IFR approach can be made (and weather is good enough for the approach), or the route allows for an engine failure and descent in VFR conditions.

135.229: Airport requirements at night. No night operations from an airport unless that airport has a lighted wind indicator (or other means of determining the winds), and lighted runways. (Hard to believe this isn't required in part-91 too!)

135.217: IFR takeoff minimums. If weather is too low to allow a return and approach back at your departure airport, you need a takeoff alternate within 1 hour's flying time.

135.225: More IFR minimums. Can only make approaches to airports with a working ATIS/AWOS (lots of PilotEdge airports don't have that!). If your destination does not have a working ATIS/AWOS, you will need an alternate that does, and the approach must allow for you to get your altimeter setting from another nearby airport. Can't start the approach unless the ATIS/AWOS indicates weather above minimums (unless you're past the FAF already).

135.225: Takeoff minimums. You have to abide by the takeoff minimums specified for the airport, or if none are specified, takeoff minimums are the same as part-91 (1 mile for singles and twins, 1/2 mile for 3+ engines). Your OpSpec may require even higher takeoff minimums. You can also takeoff with less than that visibility if there is a straight-in approach with lower minimums, and winds favor the use of that runway, and your OpSpec has approved you for this (or if you have an OpSpec-approved EFVS).

135.219: IFR destination minimums. Can't take off unless the forecast predicts weather will be above minimums at your destination.

135.223: IFR fuel requirements. Same as part 91 with some changes to the 1-2-3 rule. Now it's 1 hour before and after, the ceiling must be at least 1500 above the lowest circling MDA, and visibility must be at least 3 miles or 2 miles greater than the lowest visibility requirement (whichever is higher). If there's no circling MDA, use 1500 feet above the lowest straight-in minimums or 2000 feet AAE, whichever is higher.

135.215: IFR operations. Can't depart IFR from any class-G airport that doesn't have an IFR approach. Can't operate outside controlled airspace without approval (except as necessary to depart from or arrive at a class-G airport).

135.213: Weather sources for IFR. Must be official (from the NWS). No "I checked The Weather Channel this morning."

135.227: Icing. No flying into known or forecast light or moderate icing unless there's anti-ice equipment for the wings, windshield, propellers, control surfaces, instruments, etc.

135.89: Lowered altitudes for oxygen requirements. Supplemental oxygen is required above 10,000 feet for over 30 minutes, and above 12,000 feet at all times. For pressurized aircraft, you have to wear the mask above 25,000 feet unless you have a quick-don mask, and at all times above 35,000 feet. (Those of us who fly the Hot Start TBM, we do fortunately have quick-don masks.) If your copilot gets up to go to the bathroom above 25,000 feet, you have to put your mask on until they are back.

135.93: Minimum autopilot altitude. This is complex. I'll try to summarize it:

(b) Taking off: The highest of 1) the minimum engagement altitude in the AFM, 2) double the autopilot engagement altitude loss specified in the AFM, 3) whatever's in your OpSpec, or 4) 500 feet AGL. So if your AFM specifies these numbers, you can use those, but most of us will just say "no autopilot on until reaching 500 feet AGL."

(c) Enroute: The highest of 1) double the autopilot engagement altitude loss specified in the AFM, 2) whatever's in your OpSpec, or 3) 500 feet.

(d) Lowest altitude during approach when you can use the autopilot: The highest of 1) MDA/DH + twice what the AFM says the altitude loss for autopilot disengagement is, 2) 50 feet above MDA/DH, 3) 50 feet AGL, 4) whatever's on your OpSpec. If your AFM has an autopilot disengagement altitude loss figure, and you have the runway in sight, you can fly down to that altitude + 50 feet on autopilot.

(e) Go-arounds: If you started the go-around on autopilot, that's fine. But if not, you can't turn the autopilot back on until you are above the takeoff minimum altitude.

Some other stuff that's more company specific, but you can attempt to simulate it if you want:

135.78: You can't just make an IFR approach anywhere. It has to be somewhere your certificate holder's OpSpecs have been approved for. So if your OpSpec is only approved for the ILS at KABQ, you can't fly the RNAV. And you can't go fly any approach at KEMT unless it's on your OpSpecs. Of course, we don't have a copy of Sky High's OpSpecs, so we'll have to make it up. The OpSpecs might also specify higher minima (e.g., 500 ft for ILS approaches).

And lastly, some non-flying procedures you can simulate if you want:

135.117: Passenger briefing. Usually the first officer does this on smaller 135 charters. You have to cover smoking, safety belts, seat backs, doors, survival equipment, (overwater) ditching and floatation, (above 12K) emergency oxygen, fire extinguishers.

135.225. When flying a jet, increase minimums by 100 feet and 1/2 mile until you have 100 hours time in type.
Tim "Stretch" Morgan
ATP (B737, SF50), CFII

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