Part 135 needed just for cargo?

[nickmatic]

Probably a dumb question, but I can't seem to find anything definitive. I have a plane and am thinking about getting a CPL and offering to fly personal items around for money (no passengers). Do I need to be Part 135 certified for that? Are there exceptions?

 

[dell30rb]

Believe it or not, cargo is considered 135 charter. In the case of a single pilot/airplane operation, I do believe its easier to get a 135 certificate in that case. You'll need at least 1200 hrs to fly IFR, only 500 VFR.

There might be some workarounds available if you only have a limited number of regular customers. That would probably require a lawyer and some paperwork. But for 'the public', its 135

 

[Ted]

Cargo is 135.

Single plane/pilot 135s are easier to get. However, easier does not constitute easy. It will mostly depend on your FSDO.

 

[taters]

You would need a single pilot certificate. Although you only need a Letter of Compliance..it is NOT a piece of cake. I have been through most of the process.
Here is the general outline of what has to be done. Remember the FSDO is a referee of sorts...they cannot really help you on what to write...etc.


-FAA FSDO VIDEO and meet and greet

-PASI form Pre-Application Statement of Intent

- Formal Statement of Intent

-Letter of Compliance

-Aircraft Maint. program

- Random Drug Program for you and your maint. shop

-Hazmat program since you will carry I assume.

-Aircraft Conformance Inspection (this ones a *****) but cargo only you might be able to waive TBO to some degree other wise its within TBO and 12 calander years SMOH on your plane

-Pilot proficiency check P135


PM me if you want to see any of my stuff that was all accepted.

 

[nickmatic]

Thanks all, I was afraid of that. I've looked at the requirements and it does seem like a daunting process, even Single Pilot.

Thanks Taters for the offer. I may contact you down the road, but at the moment I'm over 300 hours short. That should change quickly, though, as I just bought a Mooney 252. Woohoo!

 

[Tom-D]

Loop hole in the regulations.

When the aircraft belongs to a company, and every one that ships on the aircraft is a partial owner of the company.

But I'll bet that isn't what you had in mind.

 

[nickmatic]

Loop hole in the regulations.

When the aircraft belongs to a company, and every one that ships on the aircraft is a partial owner of the company.

But I'll bet that isn't what you had in mind.

Thanks Tom- Could you explain a little more? I'm not opposed to setting up a company and transferring ownership of the plane to it. Would that mean I can fly cargo without Part 135???

 

[JeffDG]

Loop hole in the regulations.

When the aircraft belongs to a company, and every one that ships on the aircraft is a partial owner of the company.

But I'll bet that isn't what you had in mind.

So, set up a "Cargo Club"!

 

[Tom-D]

Thanks Tom- Could you explain a little more? I'm not opposed to setting up a company and transferring ownership of the plane to it. Would that mean I can fly cargo without Part 135???

Talk to your local FSDO.

Corporate is what you are trying to do.

you must set up a corporate company and sell shares to each and every shipper. and when it looks like a duck walks like a duck, the FAA will think it is a duck.

Boeing ships their parts of their aircraft, and they are neither a part 135 operator or a 121.

or you can buy each package and resell it at the other end.

 

[Tom-D]

So, set up a "Cargo Club"!

I can see your humor, but explain how that would work.

 

[weilke]

Thanks Tom- Could you explain a little more? I'm not opposed to setting up a company and transferring ownership of the plane to it. Would that mean I can fly cargo without Part 135???

What you would have to set up is a company owned by all your shippers that owns the aircraft. That way, each shipper transports 'his merchandise' in 'his aircraft' using 'his pilot' (you).

The rub is that each shipper now becomes the operator of the respective flights and has to deal with the liability implications of doing so. Given the ease and availability of overnight shipping services from providers like UPS and Fedex, you will find that the market of people willing to put up an investment to have on-demand shipping capability available will be very small.

 

[Tom-D]

You could also give flight lessons, who cares what baggage the student carries?

 

[weilke]

I can see your humor, but explain how that would work.

I think he is referring to the 'vacation clubs' in the 60s that tried to skirt 121 regulations by having every customer of the vacation charter company become a shareholder of that company. The FAA didn't like it and found a way to shut it down.

 

[Tom-D]

What you would have to set up is a company owned by all your shippers that owns the aircraft. That way, each shipper transports 'his merchandise' in 'his aircraft' using 'his pilot' (you).

The rub is that each shipper now becomes the operator of the respective flights and has to deal with the liability implications of doing so. Given the ease and availability of overnight shipping services from providers like UPS and Fedex, you will find that the market of people willing to put up an investment to have on-demand shipping capability available will be very small.

There were several small companies that owned a 172 each company made small shipments each week. it worked for them until the price of gas went thru the roof.

 

[weilke]

There were several small companies that owned a 172 each company made small shipments each week. it worked for them until the price of gas went thru the roof.

You are on an island, right ? I can see how this could work for a group of companies rather than dealing with the ferry system or local air charter outfits.

 

[nickmatic]

Talk to your local FSDO.

Corporate is what you are trying to do.

you must set up a corporate company and sell shares to each and every shipper. and when it looks like a duck walks like a duck, the FAA will think it is a duck.

Boeing ships their parts of their aircraft, and they are neither a part 135 operator or a 121.

or you can buy each package and resell it at the other end.

Oooohhh that makes sense. Seems a little too much to have each shipper be a shareholder for my case. But the buy/sell loophole might work. Very clever!

 

[KSCessnaDriver]

You could also give flight lessons, who cares what baggage the student carries?

If it walks like a duck and sounds like a duck

 

[Jim Logajan]

If it walks like a duck and sounds like a duck

then it is probably the mascot for the University of Oregon.

 

[Tom-D]

If it walks like a duck and sounds like a duck

Yep… that whole house of cards comes down when the student bitc--- about the price of instruction.

 

[dell30rb]

Thanks Tom- Could you explain a little more? I'm not opposed to setting up a company and transferring ownership of the plane to it. Would that mean I can fly cargo without Part 135???

Something like that... that's why I mentioned some workarounds are possible with an attorney. If you can keep it to a select few customers, chances are good that you can work something out. Otherwise you are holding out to the public and you're going to need a 135 certificate.

 

[Tom-D]

Oooohhh that makes sense. Seems a little too much to have each shipper be a shareholder for my case. But the buy/sell loophole might work. Very clever!

I almost got busted for this way back when I was chasing parts at BFI, with my 170. I used the big FBO there for parking. and walked across the street to get parts that I bought over the phone.

When I came back thru the FBO I was asked if I were going to OKH, I said yes, then was asked if I could deliver a package to the airline there. I called the airline at OKH what they were expecting, they said we have no packages there waiting or we would pick them up.

When I got off the phone I told the guy that I didn't know what was going on, and decline the offer. As I loaded up, was the only time I have gotten the third degree from a FSDO employee, they wanted to see who bought and paid for the stuff I was loading, I did have a CC slip showing my card, then they were OK with it.

It simply didn't smell right, FBO's do not normally ask pilots to deliver stuff.

 

[nickmatic]

Something like that... that's why I mentioned some workarounds are possible with an attorney. If you can keep it to a select few customers, chances are good that you can work something out. Otherwise you are holding out to the public and you're going to need a 135 certificate.

Yeah seems like these work-arounds might work only with a few close customers but not for everyone.

 

[RotorAndWing]

Talk to your local FSDO.

Corporate is what you are trying to do.

you must set up a corporate company and sell shares to each and every shipper. and when it looks like a duck walks like a duck, the FAA will think it is a duck.

Boeing ships their parts of their aircraft, and they are neither a part 135 operator or a 121.

or you can buy each package and resell it at the other end.

Boeing operates under Part 125..

 

[Tom-D]

Boeing operates under Part 125..

Maybe…

Their freighter ops are here
125.23 Rules applicable to operations subject to this part.
Each person operating an airplane in operations under this part shall—

(a) While operating inside the United States, comply with the applicable rules in part 91 of this chapter; and

(b) While operating outside the United States, comply with Annex 2, Rules of the Air, to the Convention on International Civil Aviation or the regulations of any foreign country, whichever applies, and with any rules of parts 61 and 91 of this chapter and this part that are more restrictive than that Annex or those regulations and that can be complied with without violating that Annex or those regulations. Annex 2 is incorporated by reference in §91.703(b) of this chapter.

 

[RotorAndWing]

Maybe…

Their freighter ops are here
125.23 Rules applicable to operations subject to this part.
Each person operating an airplane in operations under this part shall—

(a) While operating inside the United States, comply with the applicable rules in part 91 of this chapter; and

(b) While operating outside the United States, comply with Annex 2, Rules of the Air, to the Convention on International Civil Aviation or the regulations of any foreign country, whichever applies, and with any rules of parts 61 and 91 of this chapter and this part that are more restrictive than that Annex or those regulations and that can be complied with without violating that Annex or those regulations. Annex 2 is incorporated by reference in §91.703(b) of this chapter.

It's not a "maybe" Tom. Boeing has a Part 125 operation.


And Part 121 also uses similar language in those regulations as well. Go read the whole section of Part 125 as well as 119.

 

[weilke]

When I came back thru the FBO I was asked if I were going to OKH, I said yes, then was asked if I could deliver a package to the airline there. I called the airline at OKH what they were expecting, they said we have no packages there waiting or we would pick them up.

It's a trap !

 

[Tom-D]

It's not a "maybe" Tom. Boeing has a Part 125 operation.


And Part 121 also uses similar language in those regulations as well. Go read the whole section of Part 125 as well as 119.

Boeing ha several devisions and several different operation, their dream lifter is a 91 operation, their corporate ops may or may not be a 125.

Take the tour, and ask the tour guide, I did.

 

[Tom-D]

It's a trap !

I didn't know that at the time, I didn't put it together until much later.

I simply didn't want to fool with it that day.

 

[RotorAndWing]

Boeing ha several devisions and several different operation, their dream lifter is a 91 operation, their corporate ops may or may not be a 125.

Take the tour, and ask the tour guide, I did.

You don't know what you're talking about.

Boeing has a Part 125 certificate to cover all of their operations, at least they did when I saw their certificates and OpSpecs. During training at the Academy in the course on certification for Parts 135/121/125 the example used for 125 was Boeing, due to the diversity of the operation and how 125 applied. We looked at the OpSpecs and discussed the various provisions.

I doubt the "tour guide" is a credible source.

 

[bbchien]

Anybody here ever wonder why the agency is hard a__ed about this? Just read this string. No wonder!

 

[RotorAndWing]

Anybody here ever wonder why the agency is hard a__ed about this? Just read this string. No wonder!

Yep, always someone looking for a "work around".

 

[TMetzinger]

Or a "reach around"

To be fair, at some FSDOs I understand that even a "simple" single pilot/airplane 135 operation can take multiple years to get approved.

In my opinion it should take less than 90 days once an operator has their paperwork filed. Now you can all tell me why I'm being unreasonable in my expectations.

 

[weilke]

In my opinion it should take less than 90 days once an operator has their paperwork filed. Now you can all tell me why I'm being unreasonable in my expectations.

Should be one of those deals where it is approved unless they get around to write a detailed disapproval within 90 days.

What makes this so aggravating is that you can be in two neighboring FSDO districts and in one it takes 3 months from initial interview to conformance inspection, on the other side of the river it takes two years with the expectation that the process will never be concluded.

I understand that each inspector can have only X certificates of a set complexity under his supervision. Staffing levels at the FSDOs are pretty much carved in stone restricting any growth in the supervised industry. There should be a mechanism to farm the processing of one-pilot and 5-pack applications to an outside entity on a fee-basis, similar to the way how checkrides are farmed out to DPEs.

 

[RotorAndWing]

Or a "reach around"

To be fair, at some FSDOs I understand that even a "simple" single pilot/airplane 135 operation can take multiple years to get approved.

In my opinion it should take less than 90 days once an operator has their paperwork filed. Now you can all tell me why I'm being unreasonable in my expectations.

Tim,

When I was there it was a multiple headed hydra. The FSDO's didn't want to do additional 135 certification because HQ wouldn't allocate additional manpower to the FSDO's.

When an Inspector is assigned X number of operators as a POI it determines his pay grade. An Inspector gets assigned too many operators and he becomes eligible for a FG-14 pay grade. However Region can only approve so many FG-14's per office. So the FSDO manager refuses additional certifications due to lack of man power.

Government at its finest.

 

[RotorAndWing]

Should be one of those deals where it is approved unless they get around to write a detailed disapproval within 90 days.

What makes this so aggravating is that you can be in two neighboring FSDO districts and in one it takes 3 months from initial interview to conformance inspection, on the other side of the river it takes two years with the expectation that the process will never be concluded.

See above.

 

[TMetzinger]

Tim,

When I was there it was a multiple headed hydra. The FSDO's didn't want to do additional 135 certification because HQ wouldn't allocate additional manpower to the FSDO's.

When an Inspector is assigned X number of operators as a POI it determines his pay grade. An Inspector gets assigned too many operators and he becomes eligible for a FG-14 pay grade. However Region can only approve so many FG-14's per office. So the FSDO manager refuses additional certifications due to lack of man power.

Government at its finest.

Ah... now that I'm back taking uncle's dime again... I understand perfectly.

 

[Tom-D]

You don't know what you're talking about.

Boeing has a Part 125 certificate to cover all of their operations, at least they did when I saw their certificates and OpSpecs. During training at the Academy in the course on certification for Parts 135/121/125 the example used for 125 was Boeing, due to the diversity of the operation and how 125 applied. We looked at the OpSpecs and discussed the various provisions.

I doubt the "tour guide" is a credible source.

Did they have the dream lifter then?
IAW the pilot neighbor down the street the dream lifter is a part 91 operation. He should know he flys as crew on it.

 

[RotorAndWing]

Did they have the dream lifter then?
IAW the pilot neighbor down the street the dream lifter is a part 91 operation. He should know he flys as crew on it.

 

[Tom-D]

Well he is a real person that I trust, He is an Boeing Pilot, He is a friend and a customer who i have known for many years way back to our active duty days.

him I trust, you not so much, simply because there is no proof you are real, or that you are, what you say you are.

 

[Tom-D]

Probably a dumb question, but I can't seem to find anything definitive. I have a plane and am thinking about getting a CPL and offering to fly personal items around for money (no passengers). Do I need to be Part 135 certified for that? Are there exceptions?

If you are looking for a Cherokee 6 300 that just came out of a 135 op, and should pass any FAA compliance inspection let me know, it is cheap.