Logging SIC time......

[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.