logging multi time

[Timebuilder]

Alright, then. We agree that certain conditions allow for an SIC.

If FAA legal allows the time to be logged by the Airnet SIC as "flight time," what flight crewmember position, under the regulations that govern SIC and PIC (discussed above), is filled in by the logging pilot with regard to the crewmember position he served on that flight?

The only answer I can come up with is "none." If it is none, then you are not a required crewmember.

If you meet the specific requirements of this set of circumstances, ie:

there are conditions under 14 CFR 135 operations which do require two pilots regardless of the aircraft type. Examples include takeoffs below 1,800 RVR, carrying passengers in IFR conditions without an autopilot, and whenever the flight crew is being assigned to more than eight hours of flight time.

Then you certainly CAN log that time as a required SIC.

The likelihood of those operations being conducted, even by an on-time carrier like Airnet, is described:

In most cases, even these requirements do not apply to operations at AirNet, therefore, the SIC logs pilot in command time while being the sole manipulator of the flight controls and logs total time only, when not manipulating the flight controls. (emphasis added)

This still leaves us with the question of how this time can be "sensibly" logged when neither type of crew position is being served by the second pilot, ie, when not logging PIC time as sole manipulator?

 

[iflyabeech]

SIC's

We have FO's in our Caravans. They are on every flight and log time as SIC. This is 100% legal SIC time, not PIC though.

 

[Bandit60]

Here is the way i look at it. If the FAA requires a pilot to have a 135 sic check, (have worked for a company which the faa said that if the customer requires a sic then the sic must have a sic checkride) then you must be able to fly second in command at some point.

 

[Timebuilder]

If by "the FAA" you mean the local FSDO in the normal conduct of business regarding a carrier, I would not bet my logbook on it. Remember, ONLY the office of chief counsel can interpret regulations.

While requiring an SIC check may certainly be an act of prudence, the necessity of an SIC is spelled out in the regs.

That necessity does not cover "customer requirements."

If it did, I would have some more time to add to my logbook.

So would a lot of people.

 

[Rick1128]

Timebuilder, I think you may be missing the point. A SIC is a required crewmember on Part 135 passenger flights conducted under IFR. Not IMC. There is a difference. 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. 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.

The SIC most meet all the applicable requirements of 14 CFR Part 135, incluidng training and have sucessfully passed a 135.293 checkride in the aircraft.

 

[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.