Logging SIC time!!

[varicam]

I give up! You quote the very document that belies your interpretation and yet find that it says something it clearly doesn't. Take it to your lawyer and maybe he or she will explain it to you.

 

[dardar]

yeah, if it's in the ops specs. Airnet, for example, has a program where you can fly as an sic on a baron or something until you get your 1200 135mins. It used to address this issue somewhere on their website, but I can't find it now. Pretty much, I believe it used to be under the FAQs, Airnet brought this issue up with the FAA since so many applicants were asking about the legality, and the FAA said it was legit.

So no, you don't have to carry passengers and it doesn't have to be a two pilot airplane. It just depends on the ops specs.

 

[midlifeflyer]

I don't understand the argument. The FAA Legal Counsel have it A Squared have it exactly right and the opposing view, especially those citing pretend-SIC programs with imaginary FAA backing are living in a world where they try to bend fairly clear rules to fit what they want to do.

61.51(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.
==============================

What's so difficult about that? An OpSpec that says you "may" have an SIC an insurance company that insists of an SIC; a pilot who wants an SIC to help out - none of them make an SIC "required" by a regulation.

 

[CloudyIFR]

or the regulations under which the flight is being conducted.
==============================

if the A/P is inoperative and carrying passengers or for flight time over 8 hours.

Curtis

 

[transpac]

I don't understand the argument. The FAA Legal Counsel have it A Squared have it exactly right and the opposing view, especially those citing pretend-SIC programs with imaginary FAA backing are living in a world where they try to bend fairly clear rules to fit what they want to do.


What's so difficult about that? An OpSpec that says you "may" have an SIC an insurance company that insists of an SIC; a pilot who wants an SIC to help out - none of them make an SIC "required" by a regulation.

Well, as I understand the orginal question, it concerned "required" SICs, as defined in Part 135.101. The poster wanted to know if a SIC could be used in lieu of an autopilot. Since only IFR passenger carrying operations exercise autopilot authorizations, my assumption is that he wasn't referring to a "pretend" setup in a VFR or cargo scenario. The Chief Counsel has published an opinion to the effect that the presence of an autopilot authorization does not preclude an operator from assigning a qualified SIC to a flight and does not preclude such a SIC from logging the time. The answers and quotes from A Squared (and apparently you also) concern non-required SICs as defined by 135.101. The result of all this is confusion with each individual modifying the question to fit a pre-conceived answer.

BTW, could you post an excerpt from an Op spec that says you "may" have a SIC? I've never actually seen anything like that.

 

[CloudyIFR]

BTW, could you post an excerpt from an Op spec that says you "may" have a SIC? I've never actually seen anything like that.

You won't, because the Regs say an A/P in Lieu of an SIC. So it doesn't need to be in the Ops Specs.
The A/P can work all day long and still use an SIC legally and rightly so, assuming carrying passengers or flying over 8 hours to 10 hours in any operation.

Curtis

 

[transpac]

You won't, because the Regs say an A/P in Lieu of an SIC. So it doesn't need to be in the Ops Specs.
The A/P can work all day long and still use an SIC legally and rightly so, assuming carrying passengers or flying over 8 hours to 10 hours in any operation.

Curtis

No argument from me. The regs require a SIC but allow an autopilot in lieu of an SIC. And, like every other authorization granted by the FAA, an operator can either exercise it or can elect to comply with the underlying regulation. Hadn't thought of the over 8 hours scenario in a cargo operation, but that certainly fits the bill for requiring a SIC.

 

[A Squared]

I give up! You quote the very document that belies your interpretation and yet find that it says something it clearly doesn't. Take it to your lawyer and maybe he or she will explain it to you.

Well varicam, It is truly a mystery to me how you can read this passage from the legal interpretation: (which incidentally is precisely what I've been saying)

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.

And think that it actually means:

Therefore, a SIC is never "allowed", but is either required and can log time or is not required and cannot touch the controls nor log time.

is completely beyond me. The only obvious explanatins are extrordinarily poor eyesight, lack of literacy, or a delusional mental state.


Oh, by the way, where are the other 11 or more interpretations you claim exist?

 

[A Squared]

yeah, if it's in the ops specs. Airnet, for example, has a program where you can fly as an sic on a baron or something until you get your 1200 135mins. It used to address this issue somewhere on their website, but I can't find it now. Pretty much, I believe it used to be under the FAQs, Airnet brought this issue up with the FAA since so many applicants were asking about the legality, and the FAA said it was legit.

So no, you don't have to carry passengers and it doesn't have to be a two pilot airplane. It just depends on the ops specs.

No, not true at all. You are correct, Airnet *does* address this on thier website. They say that you are wrong. If you go this page on the airnet website: http://www.airnet.com/Careers/Flight_crew/flight_FAQ.htm you are referred to this website: http://www.airapps.com/articles/AirNetDec99/airnet.html#log which contains a letter from Airnet's Director of training, which says, in plain english, that unless you are engaging in an operation which requires an SIC (flight over 8 hours, pax under IFR, or t/o below 1800 RVR) the SIC is *not* required, and may *not* log SIC time.

So, yes, it addressed on Airnet's website; No, it *doesn't* say what you think it says.

 

[A Squared]

Well, as I understand the orginal question, it concerned "required" SICs, as defined in Part 135.101. The poster wanted to know if a SIC could be used in lieu of an autopilot. Since only IFR passenger carrying operations exercise autopilot authorizations, my assumption is that he wasn't referring to a "pretend" setup in a VFR or cargo scenario.

Well, that's the trouble, the original question was very vauge, and quite a few assumptions have been made here, including by you.

The actual question was:

Can you log SIC time flying for a 135 operator if the aircraft is flown single pilot when a SIC is not available? Example of aircraft could be a Caravan, BE99, or Metroliner ect...

And it says nothing about passenger operation, nor autopilots. As written the question could include pax or cargo operations with or without autopilots, under IFR or VFR.

The Chief Counsel has published an opinion to the effect that the presence of an autopilot authorization does not preclude an operator from assigning a qualified SIC to a flight and does not preclude such a SIC from logging the time.

Agree, in that specific situation. In a previous post I said that it was a grey area, in digging I found that, like you say, it is addressed in an interpretation, and the A/P in lieu of SIC does not preclude the SIC from logging time.....so not a grey are after all. Beyond that specific situation, the Chief COunsel is quite clear, "designating" an SIC when one is not otherwise required does not allow that SIC to log SIC time. That was my position from the begining. I may not have expressed that clearly.

The answers and quotes from A Squared (and apparently you also) concern non-required SICs as defined by 135.101. The result of all this is confusion with each individual modifying the question to fit a pre-conceived answer.

Not that it's terribly important, but the original question was *very* general, and my initial answer,

in order to log SIC, the SIC has to be required. allowed does not equal required.

was appropriately general. As far as I can see, you are the only one who has thought the question was specifically about 135 IFR pax operations with an autopilot. To clarify, when I said "allowed" I didn't mean that a specific allowance was made in the ops specs, rather that as long as an SIC is qualified, trained and checked in accordance with part 135, it's perfectly legal for him to be assigned as an SIC, therfore "allowed" in a more general sense, ie: not prohibited.

I don't think that really we disagree on much here, other than perhaps about the scope of the original question. :beer: