logging multi time

[Timebuilder]

If the operator assigns a SIC to the flight, they become a required crewmember and therefore may log the flight time as appropriate. And this is according to FAA Legal. There have been several legal interpretations issued by FAA Legal stating that. It has no effect on this why the SIC is assigned.

I think I do see what you are saying.


The carrier MAY assing an SIC for the flight.

The carrier MUST train and check the SIC, issuing an 8410.

Therefore, you are saying that this fosters and brings into play an environment of "the regulations under which the flight is conducted." This isn't so in the Airnet program, and we don't know if the person in the original post, asking about the logging of multi time, has been trained, ie:

hi a friend of mine is a first officer on a cessna 402.

The Airnet information makes no mention of the FO logging SIC time, only "flight" time and PIC time when manipulating the controls, even though the company meets the requirements to do so from "FAA legal." Why?

Now I'm not trying to be argumentative, but I wonder how the desire of a carrier to add an SIC to an airplane rises to the level of fostering "the regulations under which the operation is conducted." Is there a link to this legal interpretation, perhaps on DOC's website?

Is a customer's desire to have an SIC on board equal to a carrier "assigning" an SIC? Does that also change the "regulations under which the operation is conducted?"

Can the Airnet FO logging "flight time" during which they are NOT logging SIC time OR PIC time correctly log this as "multi" time?

 

[Bandit60]

Rick 1128

I could not have said it any better. That is exactly what i was trying to point out.

 

[Timebuilder]

Bandit 60

Since you agree with Rick, maybe you can set me straight on this part of his post:

The regs allow the operator to conduct IFR operations without a SIC if the aircraft and PIC are single pilot/autopilot authorized. The operative word in the regs and the OpSpec is MAY. It does not require the operator to conduct single pilot operations. If the operator assigns a SIC to the flight, they become a required crewmember and therefore may log the flight time as appropriate.

Are you agreeing with the idea that the assignment of an SIC therfore creates an environment of "the regulations under which the flight is being conducted?"

My point is that the regulation that covers SIC time makes no mention of an "optional" SIC, according to the desire of the carrier or customer.

While a carrier "MAY" sign an SIC, does that become a required crewmember, or an optional crewmember?

I know that sounds sarcastic. It is. So, if there is a link to a letter from the office of chief counsel that clearly explains how a crewmember who is not otherwise required by regulation becomes "required" due to assignment alone, I am happy to agree with both of you.

Nothing contradictory surprises me when it come to government doubletalk.



Secondly, what does this SIC time appear to be to interviewers? Is it regarded with the same attitude as part 61 PIC time versus Part 1 PIC time, or is it seen as having the same value as a type certification required SIC?

In other words, do airlines regard this SIC time "differently?"

 

[Bandit60]

As is stated before, I am not talking about and optional sic. Under 135 operations, if the person who hires the flight wants two pilots for that flight, the second person must have a 8310 checkride in order to even touch the radios.

Remember 135 refers to "aircraft for hire" Therefore the operation of that flight requires a second in command if the person doing the hiring needs to have a second pilot.

As far as interview and what it means. I dont care about interview, i care about a pilot getting good experience and flying like that is great experience for that pilot. You, as a CFI log time while your not "at the controls" but the things you learn as a CFI are non replaceable. You cant tell me that you dont learn from your students.

I'm not telling you that people should log all type of silly time.
but, if the time is legit then why not log it.

 

[Timebuilder]

I think we agree on many points, particularly what you can learn as a CFI.

I do wonder though, since most of the pilots who would be logging this time are doing so with at least an intent of having a professional career, I'm foced to wonder if someone who logs time under this arrangement is doing themselves a disservice at interview time.

I'm wondering if, when only "flight time" can be logged by, say for instance, an Airnet SIC, if not manipulating the flight controls, as mentioned in the Airnet article above, what is the impact when a captain on a hiring board sees "multi time" logged without either a PIC or an SIC position being served?

I'm going to have to search around and see if I can find a clear set of guidelines for determining "the regulations under which the flight is being conducted."

 

[iflyabeech]

give it a rest

Yes you can log it. No it doesn't hurt you. Yes it is flight time. Yes we are all tired of your useless and argumentative posts on this subject. Give it a rest! Mind your own business!

 

[Timebuilder]

Tell ya what. I'll post.

You ignore.

Deal?

 

[Timebuilder]

I found this on Doc's website.

Another example of a situation in which an SIC is required is illustrated in the many posts on the Propilot BBS concerning various air cargo companies which employ SICs to fly small airplanes (Beechcraft Barons, for example).


Although the SIC may not be required by 135.101, as passenger-carrying operations are not being conducted, there are other kinds of operations which may impose a requirement to use an SIC.


If the operation requires two pilots under FAR 135.267 because the flight time will exceed 8 hours, then the SIC is required and he/she may log all flight time. The time may be logged as SIC when not flying. It may be logged as PIC (or SIC, if desired) when the SIC is the sole manipulator of the flight controls. See FAR 61.51 (e)(1) and (f)(2).

Similarly, when lower-than-Category I takeoffs are accomplished (less than 1800 RVR) under FAR 135, Operations Specifications (OpSpec) paragraph C57(e) requires the SIC to be aboard. OpSpecs carry the same weight as the FAR, since compliance with them is mandatory under FAR 119.5(g). Again, the SIC may log SIC time when not flying; and may log PIC time (or SIC, as desired) when the SIC is the sole manipulator of the flight controls.

Doc's site does not address the SIC time when an SIC is assigned outside of the above mentioned requirements. Doc does give a legal interpretation from the FAA regarding SIC's.

In part:

Approval for single pilot operations with use of an operative approved autopilot system under FAR 135.105 gives an operator an additional option in the conduct of operations. It does not mandate that all future flights be conducted in that manner. The operator can elect to fly trips with two pilots, as is otherwise required for flight in IFR conditions under FAR 135.101, using the second in command instead of the autopilot.

Your second question asks if, under the circumstances given above, the SIC can log time as SIC when the designated pilot in command is flying the aircraft. The answer is yes, as long as the certificate holder is using the SIC as a crewmember instead of exercising the autopilot authorization. In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option, but rather conducts an IFR flight using two qualified pilots. The two pilots are then "required by the regulations under which the flight is conducted", FAR 61.51(c)(3), and the assumption is that the second pilot (SIC) will function as a required crewmember, and SIC time may validly be logged. However, if for some reason another qualified pilot "rides along" and does not function as a crewmember, then second in command time may not be validly logged.

This interpretation has been prepared by Arthur E. Jacobson, Staff Attorney, Operations Law Branch, Regulations and Enforcement Division; Richard C. Beitel, Manager. It has been coordinated with the Manager, Air Transportation Division, and the Manager, General Aviation and Commercial Division, Flight Standards Service.

We hope this satisfactorily answers your questions.

Sincerely,


Donald P. Byrne
Assistant Chief Counsel
Regulations and Enforcement Division

This is all I could find on the subject. The letter makes no reference to logging "flight time" when not able to log PIC time as sole manipulator, or SIC time when not under the IFR provisions.

 

[joelo88]

i had to put in for this one because i myself am in the middle of this whole situation and have been for the past two years. i'm at a SP 135 op and i'm basically a living life insurance policy for some of our customers. i'm not 293'd (cheap bastards) so the only time i log is PIC (or dual in the B350) when no pax are onboard (part 91) and i fly the ship from the left or right seat (whatever i feel like). yes it really does suck flying in a plane for 6 hrs and only logging 3 especially when you're doing a ton of work and you have more time in type than the new captain who just started flying 135 last week! At least i get paid.

no matter how you look at it, it's great experience. especially in the northeast where the weather often sucks and the airports can be very busy(ACK,MVY,TEB, BOS,HPN, ect). it's all about what you put into it. if you just go along for the ride, than you're not going to get much out of this type of thing, but if you take advantage of the situation and hand fly till you're ready to die (there's no excuse if no pax onboard), do flight planning, think like a capt., it will put you way ahead of the game.

 

[Timebuilder]

That's how I view all of the Navajo time that I could not log. Hard work, great experience, a little extra money.

ONLY the PIC time where I flew the plane (no pax, part 91) is in my logbook.

I always tried to make the most of all of my experience.

 

[Timebuilder]

According to a note I got from Doc, "flight time" is pilot time under FAR 1.1. If flight time is being logged as a required flightcrew member, it would be as PIC, SIC, or FE.

He told me, in essence, that he knows of no FAA legal opinion that allows someone who is assigned to an SIC position in an aircraft that does not require an SIC, or falls under the regulatory requirements where an SIC is mandated as discussed above, to log any time except the part 61 sole manipulator time when trained to meet the 135 requirements for a pilot under the stipulations of the carrier certificate. Under the conditions where an SIC IS required, all of the SIC time may be logged.


Apparently, in the situation we have been discussing, logging SIC time (a kind of pilot time) can only be done when the aircraft requires one, or the regulations under which the flight is being conducted requires one. What I get from the discussion is that merely "assigning" an SIC does not rise to the level of "requiring" an SIC, or create an environment where the regulations require an SIC either.

Of course, if anyone has that elusive FAA legal opinion available, post it here, and I will send it along to Doc to include on his website. Such a document may indeed exist, but neither of us has seen a copy.

 

[some_dude]

To put this to rest, if you are talking about a 135 passenger carrying operation, the opinion you cited above shows that you can, in fact, log SIC time if you are qualified in the aircraft under 135 (i.e. have complied with all the training requirements of 135 and completed a 135.293 check in the aircraft).

My company uses SICs in some of our turboprop operations (air ambulance, mostly) and they absolutely can log the time.

The only time a qualified SIC could not log SIC time would be in either a VFR operation or a cargo-only (non-passenger carrying) operation.

 

[Timebuilder]

Well, I'm sure a pax op is a different aninmal.

Can you share the reg that allows an SIC under the idea of "or the regulations under which the flight is conducted" so others can have a better understanding?

 

[some_dude]

Certainly. Look at 14 CFR 135.101, titled "Second in Command Required under IFR."

"Except as provided in 135.105, no person may operate an aircraft carrying passengers under IFR unless there is a second in command in the aircraft."

135.105 goes on to say that "a person *may* operate an aircraft without a second in command" if various conditions are met.

Note my emphasis on the word "may."

Clear enough?

 

[some_dude]

Also, you may be looking for 14 CFR 61.51(f)(2), which states that a person may log second in command time for the flight time during which that person:

"Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted."

BTW, this quote and the one from my previous post is from my (ancient) 1999 FAR/AIM (all I had lying around the house), so I apologize if the wording has changed at all since then.

 

[Timebuilder]

Well done.

My regs book is buried somewhere. The regs CD is no doubt somewhere near the book.

While most operators of aircraft which do not require an SIC by type and who carry passengers under IFR often opt for the alternate "may" option by using an autopilot, they certainly can assign a properly trained and approved SIC. For those situations, the phrase "or the regulations under which the flight is being conducted" is certainly in force.

So far, without the low IFR conditions mentioned earlier, or pax on board, there is only the part 61 sole manipulator PIC time left for those hauling freight in a plane that is certified for single pilot ops.

 

[iflyabeech]

You sure are persistent. Can you just deal with the fact that it is legal to log the time, and it doesn't matter whether its VFR, IFR, PAX or cargo? Yes, that is if you have a current 135 ride. Geez, It is so annoying to see someone beating a mute point to death. Give it up already!

 

[Timebuilder]

You sure are persistent. Can you just deal with the fact that it is legal to log the time, and it doesn't matter whether its VFR, IFR, PAX or cargo? Yes, that is if you have a current 135 ride. Geez, It is so annoying to see someone beating a mute point to death. Give it up already!

I have to guess that you have a dog in this, so if you do, just present the evidence that supports your point. According to Doc, and the FAA legal opinions, there are very specific ways in which SIC time may be logged in an aircraft not certified for two pilots, since the only other way is that "regulations" phrase.

According to what we have seen so far, your contention "it doesn't matter whether its VFR, IFR, PAX or cargo" simply isn't correct. If it was, a LOT of us would have more time in our logbooks.

What I'm trying to do here is to help clarify a vague area for new pilots, and help them to avoid an embarassing, if not career-changing moment before a hiring board.

Sorry you find the process annoying. This is valuable information for these pilots.

 

[iflyabeech]

Actually I have 0 SIC time. However I have copilots that fly every day and they log SIC everyday and it counts. (In a caravan) Like I said they have a current 135 checkride on the airplane and they particpate in flying the aircraft in all phases of the flight. I don't know what you think but they are always moving up to other jobs because of the experience that they get flying right seat with us. They get some good hard IFR and real world time. However, they do not get all the benefits that they would otherwise building hours as a CFI. As for proof, the regs, 500 FSDO inspectors, and numerous companies hiring these guys can't be wrong! I have never heard of anyone questioning this time, ever, except you. Maybe you should be a FED, you nitpick enough about stupid stuff!

 

[Timebuilder]

Well, that's an interesting attitude. Can't say that it surprises me, since I knew all the answers when I was your age.

First, I should remind you that the only entity that can legally interpret a reg is the office of chief counsel. That's a fact. We have seen one such interpretation posted in this thread, and no others that allow for SIC time in a non-pax operation unless the conditions (low IFR, as decribed in the regs) allow for such a position.

The value of the experience in the caravan isn't in dispute. I'm sure the real world expereince is wonderful. I have a bunch of such expereince in a Navajo. None of that, however, is legal SIC time. If it was, it would be in that logbook, trust me. Only my PIC time, allowed under the regs, and as supported in the Airnet article in this thread, is in my logbook. Clarification: I do not and have never worked for Airnet. I have talked to Craig a few times, but I had a jet job when he called me.

But, I digress.



Let's look at something you wrote:

As for proof, the regs, 500 FSDO inspectors, and numerous companies hiring these guys can't be wrong!

Regs? The SIC can be assigned according the the operations being conducted, and the stipulations seem very clear. They are all here in this thread, unless someone has additional legal opinions to post which are unknown to us.

500 FSDO inspectors? That's like asking 500 economists for an interpretation: you will get many different opinions. The shame of it is that NONE of those opinions have any regulatory impact, as noted in the reminder above about the office of chief counsel.

As for the numerous companies, they are, of course free to hire whomever they want. They merely have to be assured that you meet the minimum time requirements for PIC for 135 for example, or hold an ATP where required, or whatever other stipulations may be made to legally hire the pilot. I know of no position that requires SIC time at all, unless you are presenting SIC time as aircraft experience in a type rating scenario to upgrade to PIC.

Much of the success you have as a pilot is based upon how well you understand your rights and responsibilities. If you are hired for your caravan experience in the right seat, it will be because the company has chosen to recognize that experience as being valuable, not because it is FAA-legal SIC time.

When in the situation where you can fit the narrow determinations discussed in this thread, by all means, log the time. I'd be cautious, though, to keep a separate column for SIC time by certification or by regulation. Why? If a company can reject part 61 PIC time for their purposes in favor of part 1 PIC time, they can certainly choose to reject some kind of SIC time, as well. At least you will be prepared to articulate the difference in a discussion with the hiring board, and show that you understand the requirements.

Is that more clear?