logging multi time

[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?