Single pilot IFR question

[jakeandelwood]

Hey, I have a question regarding the requirements for an autopilot when single pilot IFR which is coming down to what defines the difference between a commercial flight and a private flight. Basically the question is can a commercial aircraft (702) with only the pilot on board fly single pilot IFR on a non revenue flight such as a reposition. I know it used to be only if passengers on board but I think it has changed. Thanks for any help.

[digits_]

This will/should be defined in your ops manual. It might be more restrictive than just the cars.

I don't think there's anything preventing you from doing that flight single pilot without autopilot.

[jakeandelwood]

This will/should be defined in your ops manual. It might be more restrictive than just the cars.

I don't think there's anything preventing you from doing that flight single pilot without autopilot.

I'll check there, thank you

[1759]

Worked for a 705 carrier a long time ago, we operated a D-8 for 5 days across Canada with no autopilot.

[Tbayer2021]

Worked for a 705 carrier a long time ago, we operated a D-8 for 5 days across Canada with no autopilot.

Did you miss the part about single pilot IFR? Since when is the Dash8 single pilot?

[jakeandelwood]

I know it was allowed in the past, and I have done it, but I've heard the rule has changed. The CARS say no, but it doesn't say anything about an exemption for "non revenue" flights, which seems silly to me as why would anything be more or less safe if the flight was revenue or not. The argument my employer has is they think the flight is considered private if there is no revenue being made on the flight. The aircraft is commercially registered and being flown to an airport to work out of making money.

[Otta]

Your operator is likely correct if you're not doing anything 702 then the flight can be operated privately under part 6 of the CARS. Do NOT mistake this for operating under 604 - If you're at a 604 company then that will be in your COM.

A good example is a survey company flies under 702 since their operators are considered "persons other than flight crew members". When not carrying an operators on board the flight can be conducted under private regs.

[digits_]

I know it was allowed in the past, and I have done it, but I've heard the rule has changed. The CARS say no, but it doesn't say anything about an exemption for "non revenue" flights, which seems silly to me as why would anything be more or less safe if the flight was revenue or not. The argument my employer has is they think the flight is considered private if there is no revenue being made on the flight. The aircraft is commercially registered and being flown to an airport to work out of making money.

Which cars rule are you referring to?

[jakeandelwood]

702.43 and 704.65

[jakeandelwood]

Your operator is likely correct if you're not doing anything 702 then the flight can be operated privately under part 6 of the CARS. Do NOT mistake this for operating under 604 - If you're at a 604 company then that will be in your COM.

A good example is a survey company flies under 702 since their operators are considered "persons other than flight crew members". When not carrying an operators on board the flight can be conducted under private regs.

That's exactly what is being done, your example. thanks though for the clarification

[goldeneagle]

The CARS say no, but it doesn't say anything about an exemption for "non revenue" flights, which seems silly to me as why would anything be more or less safe if the flight was revenue or not.

The regs for commercial operators were written to protect paying clients who are not knowledgeable about the industry or the risks in a given situation. There is an underlying assumption that those operating the aircraft are aware of the risks in a given situation, so allows leeway for informed people to make their own choices if not exposing the paying public to those risks.

[SE7EN]

Check the COM & Aircraft Registration. Operators operating under multiple Parts or Subparts will have it explicitly stated in the COM. CARs 202.17 differentiates between "commercial" & "Private" aircraft registration documents. 202.17 (4)(a) tells you that because your company operates under a 702 AOC, it must have commercial registration.

If your registration document says commercial, the company has to comply with Part 7. If there is no private registration on board the aircraft, you can't operate under part 6 / private registration. TC publishes an Air Operator Certification Manual, Volume 2, under 2.3.2 "Ability To Operate Aircraft Under Part VII & Part VI" has more info.

[jakeandelwood]

Check the COM & Aircraft Registration. Operators operating under multiple Parts or Subparts will have it explicitly stated in the COM. CARs 202.17 differentiates between "commercial" & "Private" aircraft registration documents. 202.17 (4)(a) tells you that because your company operates under a 702 AOC, it must have commercial registration.

If your registration document says commercial, the company has to comply with Part 7. If there is no private registration on board the aircraft, you can't operate under part 6 / private registration. TC publishes an Air Operator Certification Manual, Volume 2, under 2.3.2 "Ability To Operate Aircraft Under Part VII & Part VI" has more info.

That to me makes the most sense, thank you

[jakeandelwood]

The CARS say no, but it doesn't say anything about an exemption for "non revenue" flights, which seems silly to me as why would anything be more or less safe if the flight was revenue or not.

The regs for commercial operators were written to protect paying clients who are not knowledgeable about the industry or the risks in a given situation. There is an underlying assumption that those operating the aircraft are aware of the risks in a given situation, so allows leeway for informed people to make their own choices if not exposing the paying public to those risks.

That still doesn't really make sense in this case, makes sense in a passenger situation. There is one pilot in the plane in this case, no one else. Its the same if its revenue or non revenue

[TeePeeCreeper]

The CARS say no, but it doesn't say anything about an exemption for "non revenue" flights, which seems silly to me as why would anything be more or less safe if the flight was revenue or not.

The regs for commercial operators were written to protect paying clients who are not knowledgeable about the industry or the risks in a given situation. There is an underlying assumption that those operating the aircraft are aware of the risks in a given situation, so allows leeway for informed people to make their own choices if not exposing the paying public to those risks.

That still doesn't really make sense in this case, makes sense in a passenger situation. There is one pilot in the plane in this case, no one else. Its the same if its revenue or non revenue

I’d opine; “What does the type certificate have to say”.

TPC

[oldncold]

Cars 401.05( 3)

Boom mike , currency and functioning auto pilot regardless if revenue vs no revenue if single pilot ifr > min equipment commercal ops may require more extensive training ie sim

[SE7EN]

Check the COM & Aircraft Registration. Operators operating under multiple Parts or Subparts will have it explicitly stated in the COM. CARs 202.17 differentiates between "commercial" & "Private" aircraft registration documents. 202.17 (4)(a) tells you that because your company operates under a 702 AOC, it must have commercial registration.

If your registration document says commercial, the company has to comply with Part 7. If there is no private registration on board the aircraft, you can't operate under part 6 / private registration. TC publishes an Air Operator Certification Manual, Volume 2, under 2.3.2 "Ability To Operate Aircraft Under Part VII & Part VI" has more info.

That to me makes the most sense, thank you

You bet!

You could also go based on the definitions in the Aeronautics Act & CARs!

hire or reward means any payment, consideration, gratuity or benefit, directly or indirectly charged, demanded,received or collected by any person for the use of an air-craft;

commercial air service means any use of aircraft for hire or reward;

air operator certificate means a certificate issued under Part VII that authorizes the holder of the certificate to operate a commercial air service;

401.30(1)(c) lets you engage in commercial air services as PIC or SIC

Logic goes, if you’re getting paid for flight time, you’re engaging in a commercial air service.

The only exceptions I’m aware of is
401.28, which doesn’t apply to you since you’re not the owner of the aircraft, employed for purposes other than flying, a not for profit or a farmer dispersing products.