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10 Answers

Logging dual on a 135 flight?

Asked by: 4789 views , ,
Commercial Pilot, FAA Regulations, Flight Instructor, Student Pilot

This situation is concerning riding right seat in a single pilot jet. The type rated ATP can give dual instruction in the jet, regardless of CFI status. The question: can the dual can be given, and legally logged as 'dual received' toward a certificate, on 135 legs? (As far as the FAA is concerned)

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10 Answers

  1. Mark Kolber on Apr 23, 2015

    No. The ATP’s authority to instruct applies only to instruction “in air transportation.” That means the ATP is giving instruction to a trainee, all within the confines of a Part 135 or 121 operator’s training program. It is not a general authorization to instruct toward Part 61 certificates and ratings.

    See this FAA Chief Counsel opinion: http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/creech%20-%20(2010)%20legal%20interpretation.pdf

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  2. jeff on Apr 24, 2015

    The ATP rated can NOT give instruction in the jet regardless of CFI status. mark is correct. not only that, but the ATP in the 135 environment has be approved bythe FSDO who governs the 135 operation and what he/she can instruct is approved in advance. In addition, Part 135 regulations prohibit a passenger from sitting in the copilots seat with few exceptions. Another pilot is prohibited from sitting in the copilots seat unless that pilot is employed by the 135 operation. So even if the ATP pilot was a CFI, he could not instruct another pilot sitting in the right seat during 135 operations, because another non employee pilot cant sit there.

    The only other “instruction” an ATP pilot can give, is that training necessary to prepare a pilot under part 91 and part 61 for the duties of second in command in an aircraft whcih requires an SIC. There is alot of mis information regarding ATP pilots instructing. I dont believe there are any circumstances where they can instruct except those 2 particluar instances above.

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  3. jeff on Apr 24, 2015

    BTW. This question was addressed in some previous threads, you may want to look at. http://www.askacfi.com/author/neil-hoy

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  4. Nibake on Apr 24, 2015

    I’m new to this subject but it sounds like there is a prohibition against giving dual instruction while making part 135 flights. However, I am currently looking at a job flying “SIC” for a part 135 to build hours for 135 IFR minima. Two pilots are not required by TC (C208). How then would that time be logged? SIC is not required and I wouldn’t be acting as PIC.

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  5. Wes Beard on Apr 24, 2015


    That time cannot be logged under any circumstances. You will have to find another way to build time.

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  6. Kris Kortokrax on Apr 25, 2015

    Nibake and Wes,

    Yes, you can log SIC time under a certain set of circumstances. See the Nichols interpretation.


    You can log SIC time if one is required by the regulations. 135.101 requires an SIC when carrying passengers under IFR. If the company elects to use an SIC, then you can fulfill that role. The only caveat in the interpretation is that you may not use the autopilot in this scenario.

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  7. Kris Kortokrax on Apr 25, 2015

    Let’s dispel the mystique surrounding an ATP instructing.

    A 300 hour newly minted CFI has more instructing privileges than a 25,000 hour ATP.

    An ATP who holds no CFI certificate can only instruct in air transportation. This means that he can only instruct for the company he works for and can only provide instruction to pilots employed by the same company he works for (unless contracted by another company as provided for in 135.324(a) and the relationship is documented in OpSpec A031). The only instruction he can give is that outlined in the operator’s training program (typically initial equipment, transition, upgrade, recurrent or requalification for the type of aircraft he is rated for).

    Now, take a look at 135.338(b). It requires an instructor to hold the airman certificate and ratings required to serve as PIC in the operation. What this means is that if the 135 operator uses an Aztec, or Cessna Caravan or a helicopter, the PIC only needs a Commercial certificate. If the operator wants to designate an instructor for these aircraft, that person is only required to hold a Commercial pilot certificate in order to instruct in air transportation.

    Not only can a Commercial pilot instruct in air transportation, he can also become a Check Airman. 135.337(b)

    There is nothing magic about holding an ATP as far as instructing goes.

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  8. Kris Kortokrax on Apr 25, 2015

    Oops, one other thing.

    If you look at 135.337(b) & (c), there is a requirement for a check airman to be approved by the Administrator (FSDO).

    There is no such requirement in 135.338(b) & (c). Instructors do not need to be approved by the Administrator (FSDO).

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  9. Mark Kolber on Apr 25, 2015

    Adding to Kris’ Yes, you can log SIC time under a certain set of circumstances, there is also the possibility of logging PIC time toward FAA certificates, ratings, privileges and currency for the times you are sole manipulator of the controls (assuming you have the proper aircraft ratings).

    [Before someone starts yelling about Part 135 rules about qualifications and assignments of PIC, what potential employers “count,” yadayadayada, remember that who =is= the PIC on a flight is completely unrelated to who may =log= PIC toward FAA requirements under 61.51)]

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  10. Kris Kortokrax on Apr 26, 2015

    In the question posed at the beginning of this thread, Cody asked specifically about logging time on a 135 leg. Unless he is employed by the certificate holder and properly qualified, he may not touch (manipulate) the controls. It would be impossible for him to log PIC under any scenario in 61.51(e) or SIC under 61.51(f).

    That kind of makes the 135 rules relevant.

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