Logging SIC time......

[JohnnyP]

If a company owned a jet certified for single pilot operations, but the insurance company required that it be flown by a crew of two, could the right seat guy log it as SIC time even though the aircraft doesnt require one?

 

[flx757]

Probably the single most asked and answered question on this forum.

You can log whatever you want. It's your logbook. However, CFR 61.51(f) clearly states when it is legal to log SIC time. First, you must have the training specified in 61.55. Additionally, more than one pilot must be required either by the aircraft's type certificate or the regulation under which the flight is conducted.

Nowhere is "insurance requirement" mentioned.

 

[bobbysamd]

SIC time

If a company owned a jet certified for single pilot operations, but the insurance company required that it be flown by a crew of two, could the right seat guy log it as SIC time even though the aircraft doesnt require one?

Not legally, pursuant to flx757's 14 CFR 61.51(f) citation, above:

(f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:

(1) Is qualified in accordance with the second-in-command requirements of §61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or

(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted.


The FARs rule in this case, not the insurance company. Hope that helps a little more.

 

[midlifeflyer]

You can log whatever you want. It's your logbook.

Not to put too fine a point on it, it's not entirely "your" logbook. It is an official record of flight activity to be presented to the FAA to prove that you meet certificate, rating and currency requirements. Unless you make it =absolutely= clear that you are witting it in for some other purpose, the only numbers that should be recorded are the numbers permitted by 61.51.

And, as you said, "the insurance company wants another pilot" doesn't rise to the level of being required by the =regulations= under which the flight is conducted.

 

[JohnnyP]

Thanks for the info, basically I guess I cant log SIC because im only a required crew member based on insurance stipulations, not by FAR's. And the FAR's come out on top in this case. I dont really know a whole lot about aviation insurance plans, what they specify and allow you to do, etc, but im guessing an insurance requirment cannot add onto or take the place of an FAR even if it is more restrictive.

 

[xdashdriver]

The FAA doesn't give a rats behind about insurance requirements. If the FAA requires you to be in the airplane, it's loggable. If they don't, then you can't.

By the way, the FAA does not require you to log anything other than what you count towards gaining a certificate or rating or to show compliance with the regulations (i.e. 3 T/O LDG within 90 days, Flight Reviews, IPCs, 6 approaches in 6 months etc.). So if you're not counting it towards a new cert or rating or to prove currency, you can pretty much do whatever you want.

Ray

 

[A Squared]

So if you're not counting it towards a new cert or rating or to prove currency, you can pretty much do whatever you want.

Bad advice, really really bad advice. I thought that midlife covered this, but maybe he wasn't clear enough.

If you have bogus time in your logbook, and the FAA finds out about it they will revoke your certificates. It doesn't matter if you don't need it for currency, it doesn't matter if you don't need it for a rating, it doesn't matter if you never put that time on an 8710. I've seen NTSB decisions where the "I never used it so it doesn't matter if it's in my logbook" defense was used. It didn't work.

 

[Ralgha]

The FAA doesn't give a rats behind about insurance requirements. If the FAA requires you to be in the airplane, it's loggable. If they don't, then you can't.

If that were true, then schools couldn't get away with the "supervised solo" bit in a twin where it counts for their solo time for a private certificate though the instructor is in the airplane at the time.

**CENSORED****CENSORED****CENSORED****CENSORED** insurance companies are running the world. Students would get worlds more benefit if they actually got to solo the airplane.

 

[midlifeflyer]

If that were true, then schools couldn't get away with the "supervised solo" bit in a twin where it counts for their solo time for a private certificate though the instructor is in the airplane at the time.

The FAA =still= doesn't give a rat's ass about insurance requirements. But it =does= care about pilots being able to get their multi-engine ratings.

 

[xdashdriver]

Bad advice, really really bad advice. I thought that midlife covered this, but maybe he wasn't clear enough.

If you have bogus time in your logbook, and the FAA finds out about it they will revoke your certificates. It doesn't matter if you don't need it for currency, it doesn't matter if you don't need it for a rating, it doesn't matter if you never put that time on an 8710. I've seen NTSB decisions where the "I never used it so it doesn't matter if it's in my logbook" defense was used. It didn't work.

Ok, if clarity is what we're after then the REGULATIONS (which is what midlife was referring to...61.51) only talk about time logged for the purposes previously described.

If an NTSB judge and the FAA have been adding to the rules again outside the scope of the rulemaking process, then that's another thing.

I personally wouldn't log any bogus time. But, the regulations are right there, and so are the obscure, relatively unobtainable interpretations and case law for everyone to research to make up their own minds as to what they're going to do.

 

[A Squared]

Ok, if clarity is what we're after then the REGULATIONS (which is what midlife was referring to...61.51) only talk about time logged for the purposes previously described.

If an NTSB judge and the FAA have been adding to the rules again outside the scope of the rulemaking process, then that's another thing.

I personally wouldn't log any bogus time. But, the regulations are right there, and so are the obscure, relatively unobtainable interpretations and case law for everyone to research to make up their own minds as to what they're going to do.

A couple of responses:

1) Regulations and statutes are only part of the story, The case law is the rest of the story, in all law, not just FAA administrative law.

2) This is administrative law, not statutory law. If a cop collars some thug hanging around a deserted parking lot at 0200 with a slim jim in his pocket, there's no case. Yeah, we all know that he's there to steal a car, the slim-jim, confirms out suspicions, but still ther's no case. He claims he was on his way home and that's just a piece of spring steel he uses for a back scratcher. The DA has to prove otherwqise, and they can't. Unless there's trespassing charges or something else, they guy will walk. Contrast that with Administrative law: The FAA catches someone with a couple of pages of P-51 time, yeah the guy may claim he was never planning on using that time for any official purpose, but the differnce is, the NTSB judes are required to accept the FAA's spin on the situation (within certain limits)

3) 1 and 2 aside, there *is* a specific regulation which addresses this. 61.59 (a): no person may make or cause to be made : (2) Any fraudulent or intentionally false entry in any logbook, record, or report that is required to be kept, made or used to show compliance with any requirement for the issuance or excercise of the privileges of any certificate, rating or authorization, under this part.

Is a "LOGBOOK" specifically required? no, not exactly, but you are required by 61.51 to record experience to show compliance, so a record (acceptable to the administrator) is required.

Now, does it say that only the entries actually used have to be honest, but the unneccessary ones can be bogus? nope, it says you may not make *ANY* false entry.

If they didn't care what you put in the logbook, the regulation would read:

"............Any fraudulent or intentionally false entry that is used to show compliance with any requirement for the issuance or excercise of the privileges of any certificate, rating or authorization, under this part in any logbook, record, or report."

Read it and think about the difference in the wording between that and the way the regulation is actually worded. If wer'e after clarity, it doesn't get much cleaer than *Any fraudulent or intentionally false entry in any logbook*

You might *think* there's some wiggle room in there, but the FAA says that there is not, and the NTSB is bound by law to agree with the FAA.

 

[bigD]

You might *think* there's some wiggle room in there, but the FAA says that there is not, and the NTSB is bound by law to agree with the FAA.

I agree with all you're saying, A^2, but just to play devil's advocate, why would the FAA include "...that is required to be kept, made or used to show compliance with any requirement for the issuance or excercise of the privileges of any certificate, rating or authorization, under this part." if 61.59 prohibited ANY false entry in a logbook? Why not just say, "Any fraudulent or intentionally false entry in any logbook, record, or report." and leave it at that?

 

[A Squared]

why would the FAA include "...that is required to be kept, made or used to show compliance with any requirement for the issuance or excercise of the privileges of any certificate, rating or authorization, under this part." if 61.59 prohibited ANY false entry in a logbook? Why not just say, "Any fraudulent or intentionally false entry in any logbook, record, or report." and leave it at that?

A regulation which specified "Any fraudulent or intentionally false entry in any logbook, record, or report." would include areas which the FAA has no jurisdiction: Anything you write your personal diary, your mariner's logbook, your tax records, virtually everything you ever write in your life. "any logbook, record, or report" covers just about everything. The FAA doesn't care what lies you write in your diary about the fish you catch, nor do they have jurisdiction. I suspect that a regulation which purports to regulate things outside the FAA's jurisdiction might be open to legal challenge, invalidating the entire regulation. That last part is just speculation, i'd be interested in commentary on that from someone more knowledgable, but at any rate, the law is pretty clear: If an inspector walks up to you as you get out of an airplane you've just landed, and asks you to show that you're legally current, you're required to show him something (not that instant, but sooner or later) and whatever you show him has to be truthful, all of it.

 

[English]

However, CFR 61.51(f) clearly states when it is legal to log SIC time. First, you must have the training specified in 61.55. Additionally, more than one pilot must be required either by the aircraft's type certificate or the regulation under which the flight is conducted.

Nowhere is "insurance requirement" mentioned.

Flx757 is right on.

Which jet are we talking about here? If it is a CJ, then yes, there are some circumstances under which you can be a legal SIC.

Share with us which airplane, and I'll give you more info if it applies.

 

[JohnnyP]

It would be a CJ2.

 

[JungleJetFO]

If a company owned a jet certified for single pilot operations, but the insurance company required that it be flown by a crew of two, could the right seat guy log it as SIC time even though the aircraft doesnt require one?

If you're rated for the jet, you know you can log PIC in it though right? Anytime you have sole manipulation of the controls.
Since you have nothing to lose , I would write to the FAA and get clarification. If you're going to fly in this jet, it's worth the effort to get the flight time to count. SIC can get you your next job and it seems pretty sad that you are flying for a living and can't count any of it as flight time.

 

[JungleJetFO]

Now, does it say that only the entries actually used have to be honest, but the unneccessary ones can be bogus? nope, it says you may not make *ANY* false entry.

I think there's a big distinction here and this gets into the spirit of the law. It says you may not make any *INTENTIONAL* false entry. What you are saying is including unintentional false entries. The point of this section about logbooks is to stop someone from intentionally falsifying his logbook by filling it with flightime he did not fly, which is a criminal act. If you log SIC because you were under the impression you could (from a fellow pilot, the FSDO, etc.) but really can't, I don't believe falls under an intentional false entry.

 

[A Squared]

I think there's a big distinction here and this gets into the spirit of the law. It says you may not make any *INTENTIONAL* false entry. What you are saying is including unintentional false entries. The point of this section about logbooks is to stop someone from intentionally falsifying his logbook by filling it with flightime he did not fly, which is a criminal act. If you log SIC because you were under the impression you could (from a fellow pilot, the FSDO, etc.) but really can't, I don't believe falls under an intentional false entry.

That's a good point, but on the other hand there's always that old axiom that ignorance ofhte law is no excuse. At any rate, my comments were not really directed at the original question of whether you could log SIC in a Citation , but rather at the commonly held notion expressed by 2 posters here that you can put anything you want in your logbook, it's not a violation till you put it on an 8710 or use it to fulfil some other Part 61 reqirement.

You're right, there is *some* room for honest mistakes, but I can't say how much. Far better to know hte regulations well and follow then to the best of your ability, than to take a shot in the dark and hope that the FAA will consider it an innocent honest mistake.

There's an NTSB decision wihich sheds some light on the FAA's willingness to consider something an honest mistake. http://www.ntsb.gov/O_n_O/docs/AVIATION/4044.PDF

Very briefly, a pilot was in hte preocess of geting checked out in a Navajo of which he was a part owner nad was already on a part 135 certificate. He was updating his logbook by having his girlfriend read from the aircraft flight records, and he wrote into his logbook. He had to leave to take his mother to the hospital and while he was away his girlfriend filled in some flights in his lobgook herself. She listed as dual received several flights which were not actually dual received, and the pilot didn't catch the mistaken entries. Someow this came to the attention of the FAA. Ultimately, the pilot prevailed in his appeal to the NTSB, as he did in the initial NTSB hearing, it shold be noted that not only did hte FAA bring an Emergency revocation against this guy, but when it was struck down by the NTSB judge, the FAA appeled to the full board.

To me that speaks volumes about the FAA's willingness to consider something a harmless mistake.

On a different note, there are also aspects of this case which may be skirting some grey areas in part 135 charter. One of the things this docket illustrates is how far the FAA is willing to go to find stuff to hang you if they think that you've been playing fast and loose with charter regulations.

 

[JungleJetFO]

I'm really curious to know why this guy was investigated in the first place. Was it a mishap? Once you have an investigation , everything is under scrutiny and all of a sudden things that seem trivial become magnified under the microscope.

 

[bart]

Personally, I wouldn't log any of the time in it unless you are typed. It is a huge red flag in an interview for Citation or CJ SIC time that is not Part 135. I am sure the pilot you are flying with is typed for single pilot operations, and so no SIC required. The only way around it for the type is:

1) The PIC is not rated for single pilot operations (Highly Unlikely)

or

2) The aircraft is operated under Part 135 with no waiver in the Op Specs for Single Pilot Operation (More likely).

Get them to type you at school, that will solve alot of your problems. They are sending you to school, right?

 

[JohnnyP]

I dont have this position yet. I just know of an operation around where I live that owns a few bizjets, one of them a CJ2. And once and a while theyll let a lower time guy like myself come ride right seat and end up getting (and logging from what ive heard from the person I have been speaking with) a few hundred hours of jet time. In my talks I have not heard any mention of sending a person off to school, so there are still some details I would have to find out. I was just curious as to how this time could be logged legally if the person isnt rated for the aircraft, aircraft doesnt require a second in command, and the insurance states two people are required in the cockpit. But from what i understand insurance doesnt really come into play when it comes to logging flight time.

 

[psysicx]

How do fractionals log king air of cj time since they are part 91.

 

[dolphinjazz]

Why not 2 logbooks?

I think there's a big distinction here and this gets into the spirit of the law. It says you may not make any *INTENTIONAL* false entry. What you are saying is including unintentional false entries. The point of this section about logbooks is to stop someone from intentionally falsifying his logbook by filling it with flightime he did not fly, which is a criminal act. If you log SIC because you were under the impression you could (from a fellow pilot, the FSDO, etc.) but really can't, I don't believe falls under an intentional false entry.

Something I've wondered about in passing... not advocating this... just asking:

Reading this thread and a couple of others in this forum, it occurs to me that if one perceived threat "in general" is that an overzealous inspector will find something to nitpick in your logbook... and cause you a LOT of grief... well, help me out here... why not have *two* logbooks.

Now, don't go nuts on me (yet)... let's presume that a pilot already has all the ratings and certificates he/she wants... is not looking to present a fat logbook to the FAA for consideration for any more ratings (already been there, done that).... well, then log *only* that time that shows currency... that's all that is needed as per the regulations, right? Fly 1000 hours per year, but log only the 10 hours that show (iron-clad) your currency. Pick and choose those "currency flights" wisely. Give the ramp check inspector the skinny book with only two pages in it... and let him go eat cake.

Save the second logbook for interviews... put everything you want in there. (Don't lie) I'm saying log everything you can log legally.

Sleep well at night... keep your "FAA Logbook" with you to prove up currency. And there will be no threat of getting beat up for something inadvertent... or for a minor mistake... or for a misinterpretation. Just short cut all that crap!!

Please keep the flame throwers on low setting... only asking a question here. In fact, it wasn't me asking... I channeled it!!

Is the idea completely nuts??

 

[A Squared]

I'm really curious to know why this guy was investigated in the first place. Was it a mishap? .

I don't know, I wasn't able to glean that bit of information from the docket.

Once you have an investigation , everything is under scrutiny and all of a sudden things that seem trivial become magnified under the microscope.

Yeah, exactly. Whatever they were sniffing around for initially might pan out to be nothing, but in the meantime they've found some completely unrelated discrepancies to go after.

DOlphinjazz,

Yeah, you can do that I know of at least 2 pilots who do. They start a logbook with a BFR, log only the flights they need to show currency, throw the book away and start another when the next flight review is due.

Neither will ever pursue flying as a career. They don't care about time logged, and they feel no need to keep a record that might someday bite them. I'm not sure how you show that you've had those one time endorsemsnts Hp, complex retract, and such. I suppose that you could have the flight instructor re-endorse you at every flight review.

In the situation you describe, where the pilot is developing a career in aviation with an eye toward flying for an airline, the FAA is gonna *know* that there's another logbook. Career minded pilots (other than those who have the job they expect to retire from) don't not log time. What can hte FAA do about it? I don't know, but it might make them look extra hard for something to enforce.

 

[Erlanger]

If your company has an approved FAA SIC program in place then it is legal SIC time. It would be just like any regional or major airlines' SIC program with some ground time and either sim or it can be just going up in the airplane for a certain amount of time and than a checkride. If your company doesn't have something like this in place than it ain't SIC time and don't be logging it!

 

[A Squared]

>>>>>>>>>>If your company has an approved FAA SIC program in place then it is legal SIC time.

Uhhh, no, another aviation urban myth. In order to log SIC the SIC must be *required* by the aircraft type certificate or regulations. It's that simple.

It doesn't matter what sort of program the company has. There's always someone claiming that there's some "letter" from some FSDO which makes it all ok. Whenever someone says this, my response is, let's see the letter. No-one ever shows the letter. I've seen exactly one letter, and all that it stated was that the SIC program in question was in compliance with the appropriate regulations. Nothing even hinted that it allowed SIC logging when the SIC was not required.

Airnet used to claim that you could log SIC in thier airplanes and they sold the oppotunity to so to low time pilots. You go to thier website now and they concede that you actually cannot log SIC time legally. why the change? Perhaps because the FAA brought it to their attention that it was not legal?

Here's an FAA legal counsel interpretation which makes it pretty clear that a non-required SIC may *NOT* log SIC time.

>>>>It would be just like any regional or major airlines' SIC program

No, it's nothing like that, becaure generally the airlines use aircraft in which an SIC is required by type certificate, and even wheh it's not, the SIC is required by Part 121.


Mr. Jeff Karch
P.O. Box 5791
Lynnwood, WA 98046-5791

Dear Mr. Karch:

This is in response to your letter dated August 26, 1996, to the Office of the Chief Counsel, Federal Aviation Administration (FAA), concerning the logging of pilot-in-command (PIC) time. Additionally, your letter raises questions regarding the qualifications of pilots designated as second in command (SIC) by part 135 (14 CFR part 135) operators.

In your letter you present the following scenario: A pilot, wishing to advance his or her career, pays a part 135 operator to fly in the right pilot seat during part 135 operations. The part 135 operator designates this pilot as second in command (SIC) and allows him or her to manipulate the controls. The aircraft being flown during these operations is not required by type certification to have more than one pilot and the part 135 operation being conducted does not require more than one pilot. You ask whether the above pilot can log PIC time during those portions of the flight when he or she is the sole manipulator of the controls and whether a pilot may be considered the SIC for the part 135 operation if he or she is paying the part 135 operator to conduct the flight. The answers to these questions are discussed below.

The logging of flight time is governed by section 61.51 of the Federal Aviation Regulations (14 CFR part 61.51). That section requires the logging of aeronautical experience used to meet the requirements for a certificate or rating, flight review, or the recent flight experience requirements of 14 CFR part 61. The FAA does not require the logging of other flight time, but it is encouraged.

Logging of SIC flight time is governed by section 61.51(f), which provides, in pertinent part, that a person may log SIC time only for that flight time during which that person acts as SIC of an aircraft on which more than one pilot is required by the aircraft’s type certificate or the regulations under which the flight is conducted.

If a pilot designated as SIC is not required by either the aircraft type certificate or the regulations under which the operation is being conducted (e.g. 14 CFR part 135.103), as is the case in the scenario above, then the pilot designated as SIC may not log flight time as SIC. Although the flight time cannot be logged as SIC time, the pilot designated as SIC may be able to log part or all of the flight time as PIC in accordance with section 61.51(e).

Section 61.51(e) provides, in pertinent part, that a private or commercial pilot may log PIC time only for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated, or is acting as the PIC of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

Accordingly, a pilot designated as SIC may log as PIC time all of the flight time during which he or she is the sole manipulator of the controls of an aircraft for which that individual is rated. Although the pilot designated as SIC in the scenario you provided in your letter may be properly logging flight time pursuant to section 61.51(e), the more important issue raised in your letter concerns whether or not this individual is properly qualified to be designated as SIC and to manipulate the controls of the aircraft.

Section 135.95 of the Federal Aviation Regulations (14 CFR part 135.95) provides, in pertinent part, that no certificate holder may use the services of any person as an airman unless the person performing those services holds an appropriate and current airman certificate and is qualified, under this chapter, for the operation for which the person is to be used. (Emphasis added)

Section 135.115 of the Federal Aviation Regulations (14 CFR 135.115) governs who may manipulate the controls of an aircraft being operated under part 135. This section states, in pertinent part, that no person may manipulate the flight controls of an aircraft during a flight conducted under part 135 unless that person is a pilot employed by the certificate holder and qualified in the aircraft. (Emphasis added)

As a result, a part 135 operator may only designate a pilot as SIC and allow that individual to manipulate the controls of the aircraft if that pilot is "qualified" in the aircraft and "employed" by the certificate holder. In order to be "qualified" in the aircraft for the operation for which the person is to be used, a pilot designated as SIC must meet all applicable regulatory requirements including the eligibility requirements under section 135.245 (14 CRF part 135.245) and the initial and recurrent training and testing requirements under section 135.293 (14 CFR part 135.293).

Section 135.245 provides, in part, that a certificate holder may not use any person, nor may any person serve, as SIC of an aircraft unless that person holds at least a commercial pilot certificate with appropriate category and class ratings and an instrument rating.

Section 135.293 provides, in part, that a certificate holder may not use any person, nor may any person serve as a pilot, unless that pilot has passed a written or oral test on the listed subjects in this section as well as pass a competency flight check.

Therefore, a part 135 operator may only designate a pilot as SIC if that pilot is properly "qualified" in accordance with the regulations including sections 135.95 and 135.115 (he or she holds the appropriate certificate and ratings pursuant to section 135.245 and that pilot has received the initial and recurrent training and testing requirements in accordance with section 135.293).

In addition to being properly "qualified," a pilot may only manipulate the controls of an aircraft under section 135.115 if that individual is also "employed" by the part 135 operator. A pilot is considered to be "employed" by a certificate holder under part 135 if the pilot’s services are being "used" by the certificate holder. This is the dictionary definition of the word "employed"; there does not have to be a direct employer to employee compensatory relationship. While there does not have to be a direct employer to employee compensatory relationship, there does have to be an oversight relationship of the individual by the certificate holder for that individual to be considered properly "employed" (used) by the certificate holder.

As part of this oversight relationship, the part 135 operator is required, pursuant to 14 CFR part 135.63(a)(4), to keep certain records of each pilot the certificate holder uses in flight operations (e.g. the pilot’s full name, the pilot’s certificates and ratings, the pilot’s aeronautical experience, the pilot’s duties and assignments, the date and result of each initial and recurrent competency tests and proficiency and route checks, the pilot’s flight time,…). In addition, the part 135 operator is required under 14 CFR parts 135.251 and 135.255 to provide, directly or by contract, drug and alcohol testing for each individual it "uses" in safety-sensitive positions. Flight crewmember positions, of which pilots fall under, are considered to be safety-sensitive positions as defined under part 121, appendices I and J, (14 CFR part 121, appendices I and J), which require drug and alcohol testing.

In summary, based on your scenario, a pilot, wishing to advance his or her career, may pay a part 135 operator to fly in the right pilot seat during part 135 operations provided he or she is qualified, under part 135, for the operation for which the person is to be used. In addition, this pilot may manipulate the controls of the aircraft during part 135 operations provided he or she is employed by the certificate holder. This pilot may be designated as SIC even though the aircraft being flown does not require more than one pilot and the regulations under which the flight is being conducted do not require more than one pilot. Finally, this pilot may log PIC time for those portions of the flight when he or she is the sole manipulator of the controls of an aircraft for which the pilot is rated, but may not log any portion of the flight as SIC time.

We hope that this satisfactorily answers your questions. This opinion has been coordinated with Flight Standards.

Sincerely,

Donald P. Byrne
Assistant Chief Counsel
Regulations Division

 

[JungleJetFO]

You know why this is always an issue? No one understands it. It defies common sense. I have talked to the FSDO and get different answers. Federal examiners during check rides will readily accept whatever flight time you put in front of them and pilots take that as a voice of approval. How come they aren't the experts? Do they want your money so bad they sign you off and endorse an inaccurate logbook? And Part 135 companies know they can attract pilots to fly for them under the guise of getting SIC time even though it doesn't meet the requirements. I would bet thousands of pilots have falsified flight time and don't even know it. But as long as the FAA doesn't check it, you just go along your merry way. And then some poor bastard scrapes his Cessna into another plane and you flying career goes down the toilet since the FAA finally reviews your logbook.
Doesn't this all come down to the definition of aeronautical experience? Couldn't we all agree that sitting in the right seat of an airplane that is required for insurance reasons to have two pilots be considered aeronautical experience? Either the FAA needs to loosen up what is considered SIC or create another column for this type of flight time. It should be worth something, especially to aspiring airline pilots since this is exactly the type of experience that will make you a better airline pilot. All that mushy CRM stuff is developed when you fly as a multi-piloted crew. It doesn't have to be a heavy, passenger jet for you to develop those skills.

 

[A Squared]

You know why this is always an issue? No one understands it. It defies common sense.

No, many people understand this, and it does not defy common sense.

If a SIC is not required, you can't log SIC time. It's that simple and it makes perfect sense. There is a little tiny grey area regarding 135 pax operations under IFR with an autopilot. Other than that, it is crystal clear and is a very logical, common sense place to draw the log/no log line.

A great deal of the problem comes, not because it is difficult to understand the answer, (it's not) but because some want a different answer, so they try very hard to convince themselves that the plain, common sense, easy to understand answer really means something else.

I have talked to the FSDO and get different answers.

That's another part of the problem, officials who take it upon themselves to "interpret" the regulation to mean something different than what the words say. Be aware that "the FSDO" has no authority to interpretat the regulations and that an individual inspector's opinion has absolutely no legal standing.

And Part 135 companies know they can attract pilots to fly for them under the guise of getting SIC time even though it doesn't meet the requirements.

Yep, that's another part of the problem, unethical operators who perpetuate the myth because they can make money from it.

I would bet thousands of pilots have falsified flight time and don't even know it.

Yes, and that is unfortunate. The antidote is Know the rules yourself. Don't let someone else tell you that they mean somthing other than thier plain english meaning, especially if they are trying to sell you something.

Doesn't this all come down to the definition of aeronautical experience? Couldn't we all agree that sitting in the right seat of an airplane that is required for insurance reasons to have two pilots be considered aeronautical experience?

"aeronautical experience" comes in varying degrees: It goes all the way from commanding the space shuttle to sitting in 34b on a 737 or watching an airplane fly over your house. It's all "aeronautical experience" and you could claim that someting is learned in each case. On nice days, I've been known to go down to the local seaplane base and watch the floatplanes land, it's mostly just an excuse to sit around in the sun and relax, but I do carefully watch the various techniques, think about them and compare them to my own ...... so should I log this time? I'm learning something. Obviously, you have to draw the line *somewhere* ... So, the FAA has chosen to draw it at the "required pilot" point. You may not like that they've chosen this point, and you're certainly entitled to that opinion, but that doesn't mean that it isn't logical and easily understood.

 

[Erlanger]

Near the end of the counsels letter, it states:

"This pilot may be designated as SIC even though the aircraft being flown does not require more than one pilot and the regulations under which the flight is being conducted do not require more than one pilot."

 

[A Squared]

Near the end of the counsels letter, it states:

"This pilot may be designated as SIC even though the aircraft being flown does not require more than one pilot and the regulations under which the flight is being conducted do not require more than one pilot."

Yeah, you can be *designated* SIC, you can fly as SIC, but the interpretation repeats several times that you may not log the time as SIC.