A letter of interpretation in response to Mayo Aviation’s question about Part 135 single-pilot IFR operations has generated confusion among FAA inspectors about the applicable regulations, with the Boston FSDO issuing and then rescinding an order that Fly Advanced of Philadelphia cease flying its King Air under IFR. Mayo asked the FAA for “an interpretation of the flight recorder requirements of §135.15l(a)” in March 2013.

This regulation requires a cockpit voice recorder (CVR) for turbine multiengine aircraft with passenger seating for six or more and that require two pilots “by certification or operating rules.” FAR 135.105 allows operation with one pilot if there is an autopilot. According to the letter of interpretation, “A CVR is required for IFR operations,” because 135.151 specifies “certification or operating rules” and “the ability to operate under the exception in 135.105 using an autopilot system instead of a second pilot does not negate the need for a [CVR].”

Mayo’s five King Airs have not been grounded, according to director of operations Bill Landis, who requested the interpretation. However, “[the] response was not what we expected,” he said. “We’re working with our FSDO right now.” NBAA’s Regulatory Issues Advisory Group is also meeting with the FAA’s Chief Counsel tomorrow about this issue. Fly Advanced director of operations Ben Hollander praised the efforts of the Boston FSDO to keep the company’s King Air B100 flying.