logging right seat in a twin cessna?

[minitour]

That wasn't the question - I just wanted to know where it said cargo operators need no autopilot. Me thinks flying single pilot with no autopilot in a 1900/Merlin is crazy nuts and would significantly shorten any pilots life span - but darn good experience none-the-less.

~wheelsup

135.101 specifies that carrying passengers IFR requires an SIC or (acc'd to 135.105) an approved autopilot in place of an SIC.

-mini

 

[wheelsup]

135.101 specifies that carrying passengers IFR requires an SIC or (acc'd to 135.105) an approved autopilot in place of an SIC.

-mini

Yep, got it from imacdog, but thanks .

~wheelsup

 

[minitour]

Yep, got it from imacdog, but thanks .

~wheelsup

im a little..............................................slow























sometimes

-mini

 

[midlifeflyer]

FAR 135.

Can you be more specific? Like the sentence that says so?

 

[midlifeflyer]

That wasn't the question - I just wanted to know where it said cargo operators need no autopilot.

Same answer: you don't need a regulation to say that you =don't= have to have an autopilot. Unless the equipment is required, say by type certificate, manufacturer equipment list, or a regulation (like 135.105), you'd need a regulation to say that cargo operators =do= need one.

 

[j41driver]

Can you be more specific? Like the sentence that says so?

Sorry, no.

I went through aircraft specific training at my company on the C340, C421 and C441. At the completion of that training I had to go to AGC (Allegheny FSDO) for Part 135 SIC checkrides for each airplane. I had an oral (each time) with an FAA Inspector (happened to be our POI) and then I had a flight check in each aircraft. At the completion of the flight checks the FAA Inspector filled out some paperwork (not sure of the name or doc number) that stated that I satisfied all requirements to be an SIC on a C340 (or C421 or C441). Not sure why anyone would go through that and not log any of it....

 

[Lil Jon]

thanks for all the replies. i learned a bit more about 135 regs.

 

[wheelsup]

Same answer: you don't need a regulation to say that you =don't= have to have an autopilot. Unless the equipment is required, say by type certificate, manufacturer equipment list, or a regulation (like 135.105), you'd need a regulation to say that cargo operators =do= need one.

The horse is dead already....no need to keep beating it lol.


~wheelsup

 

[minitour]

The horse is dead already....no need to keep beating it lol.


~wheelsup

huh huh...."beating it" huh huh....

 

[midlifeflyer]

Not sure why anyone would go through that and not log any of it....

Perhaps when the FAA doesn't authorize it and might consider it logbook falsification?

 

[j41driver]

Perhaps when the FAA doesn't authorize it and might consider it logbook falsification?

Did you even read any of my post?? The FAA DID authorize it...actually required it. Like I said before, you have to have the proper FAA checkride to log the time as SIC...without the checkride you should not log the time. That's what I've been saying all along.

 

[midlifeflyer]

Sorry. With "thread creep" it's sometimes hard to know whether a post is on the "don't log unless there's a regulation that says so" or "don't log legitimate time because some company might not like it" subgroup.

 

[avbug]

The FAA doesn't have to issue an authorization for it. The FAA issues you personally an authorization to act as SIC under 135, either by proxy through a check airman, or directly from your Inspector/POI. If you're carrying passengers under 135, under IFR, you must have an SIC, or an authorization to use an autopilot in lieu of the SIC. Even where such an authorization is granted, one may still fall back to the provision of 14 CFR 135.101:

§ 135.101 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.

The exception to this rule is 135.105, which is granted individually to an operator and to each pilot specifically, allowing use of an autopilot in lieu of a SIC. This is stated in the regulation as follows:

§ 135.105 Exception to second in command requirement: Approval for use of autopilot system.
(a) Except as provided in §§ 135.99 and 135.111, unless two pilots are required by this chapter for operations under VFR, a person may operate an aircraft without a second in command, if it is equipped with an operative approved autopilot system and the use of that system is authorized by appropriate operations specifications. No certificate holder may use any person, nor may any person serve, as a pilot in command under this section of an aircraft operated in a commuter operation, as defined in part 119 of this chapter in passenger carrying operations unless that person has at least 100 hours pilot in command flight time in the make and model of aircraft to be flown and has met all other applicable requirements of this part.
(b) The certificate holder may apply for an amendment of its operations specifications to authorize the use of an autopilot system in place of a second in command.
(c) The Administrator issues an amendment to the operations specifications authorizing the use of an autopilot system, in place of a second in command, if -
(1) The autopilot is capable of operating the aircraft controls to maintain flight and maneuver it about the three axes; and
(2) The certificate holder shows, to the satisfaction of the Administrator, that operations using the autopilot system can be conducted safely and in compliance with this part.
The amendment contains any conditions or limitations on the use of the autopilot system that the Administrator determines are needed in the interest of safety.

Accordingly, where a SIC is required by the regulation, logging time as SIC is NOT inappropriate. Stipulating otherwise is nothing more than a misunderstanding of the regulation.

One who flies a 421 under 135 as SIC and logs it as such, when 135.101 has authorized it, is doing nothing "shady." This is not questionable, it's not a grey area. It's not difficult to understand. That the aircraft is type certificated for one pilot is not relevant, because the relevant regulation to the operation is 135.101, which requires a second in command.

If said 421 is being operated by a company that has been issued operations specifications permitting use of an autopilot in lieu of a SIC, the company still has the option of using a SIC under authority of 135.101, provided all the training requirements are met. By doing so, the operator is not doing anything questionable, or illegal. The autopilot may still be used, but the option of using the SIC is always there.

Anybody who tells you differently does not understand the regulation. Further, logging SIC time in a 421 or Navajo, or any other similiar aircraft, is not improper. The truth is that most any aircraft, including most large airplanes, can easily be flown single pilot...but that's really quite irrelevant. A SIC is required by regulation...which might be the regulation under which the aircraft has received it's type certificate, or other regulation. In this case, the aircraft is being operated under Part 135, and Part 135 requires a SIC.

It's that simple.

 

[A Squared]

Perhaps when the FAA doesn't authorize it and might consider it logbook falsification?

Ahhh, Mark, there you go, throwing around the "F" word

 

[A Squared]

This is not questionable, it's not a grey area. It's not difficult to understand.

Respectfully, Avbug, it *is * a grey area, and stipulating that it isn't doesn't make it so.

Let's back up a step and examine what is *not* a grey area.

If you're flying passengers IFR under 135 in a baron with no autopilot, an SIC is clearly required, no discussion.

If you are flying cargo IFR under 135 in a baron, the SIC is clearly *not* required, and you are *not* allowwed to log SIC time. To do so is clearly falsification, no matter how many checkrides you hve had. Airnet used to sell thier right seat for this purpose. They don't any more and on thier website you will now find an oblique admission that it really wasn't legal. My money is that it's a result of a little legal action from the FAA, but I digress.

So, we know when it *is* and it *isn't* legal. Let's examine the middle ground.

We're flying passengers in a baron with a functioning autopilot IFR under 135. the operator had authorization to use an autopilot in lieu of an SIC.

Is the SIC required by "the regulations under which the flight is conducted"?

That's the crux. whether you're *authorized* to act as SIC or how many checkrides you've taken is all completely irrelevant.

The only thing that counts is:

Is the SIC required by "the regulations under which the flight is conducted"?

That is the question.

There are 2 views on the matter.

One is that the SIC is still "required" by 135.101, even though the operator is authorized to operate without one, therefore it is legal to log SIC time.

The other view is that the SIC is not reqired by the regulations. This position is best summed up by the question, "can the PIC leglly make the flight if the SIC doesn't show up?" IF the answer is Yes (as it would be in our hypothetical) than the SIC is *not* required, and SIC time may not be logged.

Personally, I find the second much more compelling. It is simple and straightforward, and it doesn't depend on taking to word "required" to mean something other than it's plain, everyday dictionary meaning, and it doesn't involve placing greater emphasis on one regulation and essentially ignoring another.

So, is it a grey area? yes, without a shadow of a doubt. The FAA has never clarified this with a legal interpretation, nor has there been an NTSB decision regarding this issue. Personally I can't imagine a judge ignoring the simple, obvious test of "can the PIC legally make the flight without the SIC" but that's my *opinion* and stranger things have happened. The reality is that it is a grey area and no-one knows for sure which way a judge will decide. But without question, logging SIC time when the PIC may prefectly legally make the flight without you is treading on the very boundary of what is legal.

The fact that one has passed one, or two, or a dozen, 135 SIC checks is completely irrelevant.