Logging SIC time......

[Flying Illini]

DO you really want to know why? or do you just want to complain about how mean the regulations are?

If you allowed insurance policies to dictate the legitimacy of SIC time, as sure as god made little green apples, you'd have a bunch of places get insurance policies on thier C-150's which required an "SIC" and start selling timebuilding packages with 2 people in a 150 building time for thier CPLs and ATPs. Presumably you are astute enough to grasp that having ATP applicants with 300 hours of PIC and 1200 hours of C150 SIC time is an undesirable situation?

Look, drawing the line at SIC's who are required by the regulations is a reasonable, common sense place to draw the line. It may be currently inconvenient for you, but it makes a great deal of sense.

I was curious, I don't think the regs are "mean." I never looked at it the way you described. Probably because I wasn't looking for a way to "cheat the system." I didn't consider all possibilities, thanks for bringing it up.
Still, as "ignorant" as it is, I'm sure that abuse of the reg could be prevented by insurance companies only providing this type of insurance to pax/charter operators of large twins (maybe restrict it to certain types of aircraft to prevent abuse?). Something along those lines. Look, I'm not trying to write the reg, I just posted an honest question. I had one answer and one attack. Whatever.
I see that in the FAA's eyes, an SIC isn't required but My "ignorant" question still remains: How is an SIC not considered a required crewmember if the airplane can't fly without one?
If you just read the regs, then yes, it's a stupid question, now try explaining this situation to someone not familiar with the regs and I'm sure they'll say that since an SIC is required for the airplane to fly, then an SIC is a required crewmember.
And just for the record...I only log my BE20 PIC time.

 

[bigD]

How is an SIC not considered a required crewmember if the airplane can't fly without one?

The only reason the airplane isn't flying is because the insurance company says it can't. As far as the FAA is concerned, the plane can be flown. Think of it this way, if the owner of the plane said that it can only fly if a third pilot was riding in the back as a backup, should that guy be a required crewmember in the eyes of the FAA? After all, the plane doesn't fly without him.

 

[midlifeflyer]

I see that in the FAA's eyes, an SIC isn't required but My "ignorant" question still remains: How is an SIC not considered a required crewmember if the airplane can't fly without one?

Sure it can. It will be uninsured but it can certainly legally fly.

I think that may have been A Squared's point. The insurance company is making a safety determination in deciding what kinds of things it will cover. Of course it has greater influence over business operations, but it's really no different than, say, a company deciding that it will only fly with two pilots on board even if the FAA and an insurance company say it's okay. A lot of those fake "SIC" programs are directly based on that concept.

I even once saw a post in which someone said that they were planning a trip in a 172 that was going to cross a substantial part of open water and wanted to have a copilot on board. Wanted to know if the co-pilot could log SIC time. Great idea - having extra hands and eyes on board for a higher-risk trip - exactly the same kind of determination an insurer makes, and in may ways an even better one.

But no. Since the only purpose of the Part 61 logging rules is to show that a pilot has the qualifications to apply for an FAA certificate, rating or currency, the FAA decided that the rules about what time could be use had to be uniform. So it takes the simple stance that in order to log time as SIC that can be used to show qualification for certificates, ratings or currency, the extra pilot must be required by regulation. Not personal choice (even wise ones), company policy (even good ones), or insurance dictates.

If you think the =experience= is valuable, set up a clearly identified non-Part 61 "Co-Pilot" column in your log book. You can't use the time to count for an FAA certificate, but perhaps your next employer will look at it as a gauge of experience.

 

[nosehair]

There are lots of King Airs flying around out there by personal owners with only one pilot. They are probably paying a higher insurance rate. Would you want it to be a regulation to have a co-pilot on your personal airplane?

 

[Lead Sled]

Sure it can. It will be uninsured but it can certainly legally fly.

Midlifeflyer hit it square on...
Remember, it's not the FAA that determines what you can fly, it's the insurance companies. All an FAA certificate means is that you had the financial resources and the "stick-to-itness" to get a particuliar license, rating, or type-rating. The insurance companies set the standards of experience and operational conditions that you must meet in order to exercise them in the real world. In the case of a KA200 with two pilots - sure, it's legal with one; but the insurance company is saying that if you want it to be insured when it's flown, there's going to have to be two pilots with a stated amount of experience up front. That's all well and good, but even though the insurance company requires it, as far as the FAA is concerned, that extra guy is just a passenger with a front row seat.

Lead Sled

 

[wings421]

The only reason the airplane isn't flying is because the insurance company says it can't. As far as the FAA is concerned, the plane can be flown. Think of it this way, if the owner of the plane said that it can only fly if a third pilot was riding in the back as a backup, should that guy be a required crewmember in the eyes of the FAA? After all, the plane doesn't fly without him.

BigD - Thanks for making my point clear for Flying Illini

 

[Flying Illini]

Sure it can. It will be uninsured but it can certainly legally fly.

I think that may have been A Squared's point. The insurance company is making a safety determination in deciding what kinds of things it will cover. Of course it has greater influence over business operations, but it's really no different than, say, a company deciding that it will only fly with two pilots on board even if the FAA and an insurance company say it's okay. A lot of those fake "SIC" programs are directly based on that concept.

I even once saw a post in which someone said that they were planning a trip in a 172 that was going to cross a substantial part of open water and wanted to have a copilot on board. Wanted to know if the co-pilot could log SIC time. Great idea - having extra hands and eyes on board for a higher-risk trip - exactly the same kind of determination an insurer makes, and in may ways an even better one.

But no. Since the only purpose of the Part 61 logging rules is to show that a pilot has the qualifications to apply for an FAA certificate, rating or currency, the FAA decided that the rules about what time could be use had to be uniform. So it takes the simple stance that in order to log time as SIC that can be used to show qualification for certificates, ratings or currency, the extra pilot must be required by regulation. Not personal choice (even wise ones), company policy (even good ones), or insurance dictates.

If you think the =experience= is valuable, set up a clearly identified non-Part 61 "Co-Pilot" column in your log book. You can't use the time to count for an FAA certificate, but perhaps your next employer will look at it as a gauge of experience.

I seem to have really gotten myself wrapped around the axel on this one. Thanks to midlifeflyer and the rest of you with the constructive responses, I see the error in my thinking.

 

[A Squared]

Look, I'm not trying to write the reg, I just posted an honest question.

Ummm, no, you expressed an opinion, specifically the opinion that the reg should be changed. Yeah, there was a question mark thrown in there someplace, at the end of a rhetorical question, but read what you wrote. it's a statement of opinion, and you caught some heat for it.

 

[midlifeflyer]

I seem to have really gotten myself wrapped around the axel on this one. Thanks to midlifeflyer and the rest of you with the constructive responses, I see the error in my thinking.

Wait a minute. You're not necessarily wrong. Of course it's frustrating to be flying second seat in an airplane which, for all practical business purposes, has to be flown that way in order to make it economically feasible for the operator (that second pilot probably costs the operator less than insuring the aircraft for single pilot ops, if it's even possible), and not be able to use the time for FAA purposes.

I think that changing the logging reg to allow FAA logging to be based on rules that are not the FAA's may be the wrong way. It's probably unworkable anyway.

But what about this? (You folks who know Part 135 and 121 jump in here. I'm on thin ice in 121 and 135 once I get much past their relationship to Part 91 operations).

There's already FAA "precedent" for changing a regulation based on practical realities - the multi "pseudo-solo" comes to mind immediately.

What if 61.51 were changed to permit logging SIC time when a second pilot is required by FAA-approved OpSpecs? Then a Part 135 operator could try to convince the FAA of the wisdom of using a second pilot and get the FAA's blessing for it's SIC program. The FAA maintains control of logging and the operator and the pilot both win.

you guys in the know... Workable?

Excuse me while I duck.

 

[nosehair]

yeah, Midlife, what you said. Actually, I thought that was what was happening with "pay-for-a-copilot-seat" operations around the country in airplanes that don't require one. That was what I was told by some students who have left our school with their commercial, then buy 100 hours of right-seat time in something like an Aero Commander. The operator was telling them they had a special provision in their "Ops-Spec" which required them to always have a co-pilot. But, I have seen other comments on these boards which say *B.S.*, and I'm inclined to believe the latter. I don't know - maybe someone has specific knowledge. That would be the way to go, if it is possible.

 

[MacGyver]

Nosehair,

I flew with that company in their commanders...bought 200 hours of SIC time and they have a letter in their ops specs about having SIC's in their planes, even though a commander doesn't require one. Their SIC program has been in place for many years and I have yet to hear of someone having problems with the time logged in the SIC column. (not to say it hasn't happened, I just haven't heard of any problems.) I logged PIC only when I was sole manipulator and only on the part 91 flights, and when I was sole manipulator on the 135 flights, I created a new column in pencil and called it "Part 61 PIC" hoping that it will be looked upon favorably in an interview. This seems to be a sore subject with many people, and can only hope that I haven't made a mistake. All I aspire to do is become a better pilot, and my experience flying SIC helped to that. I learned quite a bit from the experience and developed a much better instrument scan.

 

[midlifeflyer]

It's pretty clear that in order to log SIC, a second pilot must be required by regulation. AFAIK, although the issue has been danced around, there's never been a formal FAA Counsel Opinion or NTSB/Court ruling on whether Ops Specs rise to the level of a federal regulation. The "dances" involve Opinions and enforcement actions over violating some part of an Ops Spec in which the question is whether the FAA can take certificate action against a pilot for operating contrary to an Ops Spec.

They go every which way, with FAA Legal Opinions generally saying that a pilot cannot be violated for it (some suggesting that this means that Ops Specs do not rise to the level of "regulation") to a few NTSB decisions saying that a pilot can be violated for operating contrary to one (suggesting to some that they =might= be regulatory).

 

[A Squared]

Nosehair,

I flew with that company in their commanders...bought 200 hours of SIC time and they have a letter in their ops specs about having SIC's in their planes, even though a commander doesn't require one.

Oh yeah, the old "magic letter" which makes it OK to log SIC in a single pilot airplane.

I've been hearing about these "magic letters" for years. Each time a "magic letter" is mentioned, I offer the same challenge: Show us the letter, preferrably, show us the letter together with the name and FSDO of the person signing the letter.

In years of doing this, time and time again, you know how many letters I've seen? Exactly one. You know what that letter said?

It said that XXXX had approval to designate SIC's in single pilot aircraft in Part 135 ops, provided that the SIC was fully qualified as a 135 pilot by XXXX's training and cheking program.

Ummmmm, yeah, no kidding, if you put somone through your pilot training program sucessfully they can fly as a non required SIC. That's a no-brainer, you don't need a letter to tell you that,

What the letter *didn't* say is much more important. It *didn't* say that the SIC was required. And it *didin't* say it was legal for the SIC to log time.


The thing is, there is no place in the Operations Specifications for a "magic letter"

Operations Specifications are specific, numbered authorizations for specific operations or procedures.

For example,

Operations specification C63 is to " Conduct airplane approach operations using an area navigationsystem. "

Operations specification A14 is to " Conduct IFR operations in uncontrolled airspace." ​

Operations specification C56 is to "Conduct operations using lower than standard takeoff minimums under Part 121."​

And so on. There's a list of them, if it's not on the list, it doesn't exist. There is no Operations Specifications A999 "require an SIC in an airplane which does not require an SIC"​

Look, it's real simple. The FAA's Chief Counsel has issued an interrpetation on this subject. It's beem posted here over and over. the short answer is:​

Yes it is legal to sell the right seat, yes it is legal to put somone in the right seat, provided they are properly qualified under the operator's training program. No, it is *not* legal for them to log SIC time.​

That's from the office of chief counsel, the top. I can assure you that can't be overruled by some bogus letter that some inspector in some FSDO writes as part of a buddy deal with a dirtbag operator.​

 

[A Squared]

Midlife,

Operations Specifications *are* regulatory There is a very clear and well defined regulatory mandate to comply with the operations specifications. There doesn't need to be an chief counsel opinion.

There is a differnece between Operations Specifications which are regulatory, and a company's "operations manual" which is not regulatory (but required to exist.) Further confusing the point is that typically the ops specs and the ops manual are combined into one physical book.

 

[wings421]

Whats funny about the pay for SIC time programs is this. Most of the aircraft are still flown single pilot! If this were in the Op Specs, this would be a clear violation. However it isn't and an SIC IS NOT required and can't log SIC time in a single pilot aircraft. A Squared made this point clear.

However, if you are flying 135 with passengers and no autopilot, or 135 with passengers and the PIC doesn't have an autopilot authorization, then you can log SIC time in the airplane because you are a required crewmember. Or, if you were to fly 135 and had to fly over 8 hours in a day, you would have to operate as a two pilot crew all day and then the SIC would be required.

As far as a win/win for the operator having an SIC required, I DISAGREE! Unless the operator is having the SIC pay for the seat, there is no point to look at this option as it will only add to training and pilot pay costs.