Timebuilder said:I am certain that you are aware that any interpretation of regs on the FSDO level means nothing. Nada. Zip.............
True. If it is a matter of operational procedure, get it in writing and have the FSDO approve it. Then you are fine. They control the oversight for your certificate.
....If you can show that the SIC was indeed required under the ops specs for the carrier, then you can justify this time from a more firm position.
Under the Basic level of operator, except for the Ops Spec for Autopilot in lieu of SIC I have never seen an Ops Spec refer to or "authorize" an SIC. Our FAA Training Program does. Its in the regs of course. Our Single Piot-in-Command operator status did list authorized PIC and SICs. Which specific (give example) Ops Spec authorizes SICs? Just curious.