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Low Time FO's

Sniper@YourFeet

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A discussion has developed about this, so I'm hoping to get it fresh eyes:

In simple terms, can a regional FO without their ATP or a PIC type use their right seat time to meet the 250 hour PIC requirement of the ATP?

FAR 61.159 tells you what you need for an ATP. Among other things, you need "250 hours of flight time in an airplane as a pilot in command, or as second in command performing the duties of pilot in command while under the supervision of a pilot in command."

I've been told that FAR 61.55.b.2.ii will allow you to log SIC towards this 250 hour PIC requirement, b/c it says "Engine-out procedures and maneuvering with an engine out while executing the duties of pilot in command" is one of the requirements of a SIC annual check (a PT or PC).

The question is, just b/c a SIC does one maneuver in the sim (or airplane) during a PC "while executing the duties of PIC", does that mean that a SIC is always "performing the duties of PIC" whenever they are @ flying, just when they're the pilot flying, or never? Can a SIC with a FAA pilot's license limiting them to SIC privileges only in a plane log PIC in the plane?

Apparently, there is disagreement on the answers to these questions, since there are claims applicants using SIC @ their carrier to satisfy the 250 PIC requirement "has been shown to be current practice at most companies such as ASA, and Expressjet".

Can someone without a PIC type rating or an ATP log time that would satisfy the 250 hour PIC requirement of FAR 61.159 in an aircraft that requires a type rating and is being operated under FAR 121, which requires the PIC hold an ATP?

I would have put this in the FAR area, but it gets no viewing there.
 

OCP

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eh...
Simple terms yes... If you want the safest route than you put in your log book something along the lines as "name" was second in command performing the duties of pilot in command while under the supervision of a pilot in command.... and have the type rated PIC put his signature and type # in there as a sign off. (for the leg flown)
Do a search on the WWW as this has come up a bunch.
 

PA44Jockey

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Simple terms yes... If you want the safest route than you put in your log book something along the lines as "name" was second in command performing the duties of pilot in command while under the supervision of a pilot in command.... and have the type rated PIC put his signature and type # in there as a sign off. (for the leg flown)
Do a search on the WWW as this has come up a bunch.

I don't think I would go as far as getting the PIC's signature. You don't need his signature to log SIC and technically you wouldn't be logging SIC without a PIC present.
 

OCP

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eh...
I don't think I would go as far as getting the PIC's signature. You don't need his signature to log SIC and technically you wouldn't be logging SIC without a PIC present.

Nope you don't. But if you want to "quote" the rules than the no questions asked is having it signed off. Has this all been done 100s of time, yes. But that one time.. who knows
 

NoJoy

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Interesting question, but I would go with "no". PIC in a 121 operation is the one who signs for the release. Event the Captain applicant in the left seat getting IOE cannot log PIC time because the guy in the right seat is the PIC-they are the ones signing the release. I think it is pretty cut and dry.
 

CX880

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FAR 61.159 tells you what you need for an ATP. Among other things, you need "250 hours of flight time in an airplane as a pilot in command, or as second in command performing the duties of pilot in command while under the supervision of a pilot in command."

Well you answered your own question. That's what the FARs are there for. No need to make them even more complicated. I've flown with CAs that had 190 hours when they were hired as FOs.
 

Lynxman

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Kinda scary if you work for an airline and you don't even have 250 hours PIC. In fact I'm kinda bothered by that.
 

SEVEN

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Kinda scary if you work for an airline and you don't even have 250 hours PIC. In fact I'm kinda bothered by that.
Me too. But the "silver lining" is that after the Colgan crash, the days of hiring "unqualified" pilots for 121 ops is long gone. No more applicants getting hired with 188 total time, 14 hours multi, and a heart beat. Thank God that the changes are being made as we speak. The ONLY place for a pilot with 188 hours is flight instructing, banner towing, traffic watch, or gaining experience in the right seat of an aircraft that DOES NOT require 2 pilots. (except for insurance req.)
 

shamrock

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My upgrade partner did the FlightSafety fast track thingy and didn't have the stated PIC time for upgrade but his time spent at ASA in the right seat was used to satisfy the requirement. It only took an hour and 15 minutes at the beginning of the oral for the FAA inspector, check-airman, and him to figure it out.
 

Lynxman

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Me too. But the "silver lining" is that after the Colgan crash, the days of hiring "unqualified" pilots for 121 ops is long gone. No more applicants getting hired with 188 total time, 14 hours multi, and a heart beat. Thank God that the changes are being made as we speak. The ONLY place for a pilot with 188 hours is flight instructing, banner towing, traffic watch, or gaining experience in the right seat of an aircraft that DOES NOT require 2 pilots. (except for insurance req.)

I'm still low time myself but I at least have that much PIC maybe right around that much and I know for a fact I can't handle even being right seat in any jet.
 

Midnight Flyer

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I know I'm straying from the original question...but, has anyone noticed a huge increase in FAA activity within your airline's training dept, specifically in the sim?

I recently had my recurrent PC in the sim, and an FAA inspector sat in on 8 hours worth of sim. He was saying that as a result of the Colgan crash, the higher-ups are requiring them to observe 40% of the checkrides, and also sit in on some of the classroom recurrents. (This is at my specific company; I'm sure it varies from airline to airline).
 

GoingHot

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Kinda scary if you work for an airline and you don't even have 250 hours PIC. In fact I'm kinda bothered by that.

How is that even possible? I guess I wasn't paying attention to the low times they accepted during the airline hiring boom.
 

LazyLightnin'

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I know I'm straying from the original question...but, has anyone noticed a huge increase in FAA activity within your airline's training dept, specifically in the sim?

I recently had my recurrent PC in the sim, and an FAA inspector sat in on 8 hours worth of sim. He was saying that as a result of the Colgan crash, the higher-ups are requiring them to observe 40% of the checkrides, and also sit in on some of the classroom recurrents. (This is at my specific company; I'm sure it varies from airline to airline).

I love how the FAA lumps reputable regional training departments in with Colgan...
 

WMUSIGPI

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I know I'm straying from the original question...but, has anyone noticed a huge increase in FAA activity within your airline's training dept, specifically in the sim?

I recently had my recurrent PC in the sim, and an FAA inspector sat in on 8 hours worth of sim. He was saying that as a result of the Colgan crash, the higher-ups are requiring them to observe 40% of the checkrides, and also sit in on some of the classroom recurrents. (This is at my specific company; I'm sure it varies from airline to airline).

Yes, significantly more. And a new policy that reqires additional line checks if you are low time (based on months at the company and in each position as well)
 

Lynxman

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How is that even possible? I guess I wasn't paying attention to the low times they accepted during the airline hiring boom.

Some schools have contracts with airlines that allowed people with low times such as those to get hired. 141 schools do not need 250 hours TT for a commercial certificate.
 

avbug

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Where is the room for any sort of debate? The language of the regulation is clear, and this has been discussed here before.

A discussion has developed about this, so I'm hoping to get it fresh eyes:

In simple terms, can a regional FO without their ATP or a PIC type use their right seat time to meet the 250 hour PIC requirement of the ATP?
You're asking the wrong question. There is no PIC requirement. It's an either/or requirement, and one does not need 250 hours of PIC experience in airplanes...just 250 hours performing the duties of PIC. It's that simple. The regulation states as much in clear, concise, plain English. How can this be difficult to understand?

14 CFR 61.159(a)(4) states:

(4) 250 hours of flight time in an airplane as a pilot in command, or as second in command performing the duties of pilot in command while under the supervision of a pilot in command, or any combination thereof, which includes at least—
(i) 100 hours of cross-country flight time; and
(ii) 25 hours of night flight time.
This isn't a matter of requiring 250 hours of PIC time, but specifically requiring 250 hours of PIC or SIC time in airplanes. The salient point of this requirement is to have 250 hours of experience in the category of aircraft involved, namely, airplanes. It may be PIC or SIC, performing the duties of PIC. This time does not have to be pilot in command time, or logged as pilot in command time. One does not need to have "signed for the airplane" as this is meaningless and irrelevant in the face of the regulation.

The question is, just b/c a SIC does one maneuver in the sim (or airplane) during a PC "while executing the duties of PIC", does that mean that a SIC is always "performing the duties of PIC" whenever they are @ flying, just when they're the pilot flying, or never? Can a SIC with a FAA pilot's license limiting them to SIC privileges only in a plane log PIC in the plane?
You say "the question is," but none of the questions you then pose are the same as the question with which you start the thread. So let's work backward. First you're confusing issues of of logging flight time, with acting as PIC or SIC.

In order to log PIC, one must be qualified in the airplane, which includes category (airplane, for example), class (multi engine land), and type rating. If one only holds a SIC type, one cannot use it to log PIC time, as sole manipulator or any other way. One cannot be pilot in command, one cannot log pilot in command, one is not qualified to do either one. Therefore, the answer to your last question from the above paragraph is no...one may not hold a SIC-type only, and log PIC. Again, the regulation is very clear on the matter.

To move to your next question, which is three separate questions, one is performing the duties of PIC when they're flying the airplane and performing the duties of PIC. They need not be maneuvering the airplane on one engine during that time. The only requirement is that the time be PIC or SIC performing the duties of pilot in command under supervision. No specific reference is given to maneuvers that must be performed during this time, and indeed there is no requirement for specific maneuvers during this time. This includes engine-out maneuvering. Where do you think you find such a requirement?

I've been told that FAR 61.55.b.2.ii will allow you to log SIC towards this 250 hour PIC requirement, b/c it says "Engine-out procedures and maneuvering with an engine out while executing the duties of pilot in command" is one of the requirements of a SIC annual check (a PT or PC).
You've been told? Don't you read the regulation?

61.55 isn't about logging flight time. It's about acting as SIC, and establishes the requirements to do so. It is, therefore, irrelevant. 61.55 doesn't authorize you to log time, or establish any basis for meeting the requirement of 61.159. It's a separate regulation. If you intend to stand upon 61.55(b)(2)(ii) to establish "performing the duties of PIC," then do you intend to do 250 hours of engine failures? Of course not...which makes it a ridiculous association with 61.159.

61.51(f) governs the logging of SIC time, and is also very clear.

(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.
This regulation establishes the requirements and qualification for logging SIC time. It does not address the issue of performing the duties of PIC, nor are these germane to the issue of logging SIC.

So, to answer your question, "just b/c a SIC does one maneuver in the sim (or airplane) during a PC "while executing the duties of PIC", does that mean that a SIC is always "performing the duties of PIC" whenever they are @ flying, " the answer is no. The question is somewhat non-seqitor, and is somewhat like asking if because a boy was once sick, will he always cough? The proper response is "Huh? What are you talking about?"

What one did in the simulator is irrelevant. Either one is SIC qualified or one is not. This has no bearing on whether one spends the next 250 hours performing the duties of PIC, or not.

You may be confusing the separate and distinct concepts of logging flight time, acting as pilot in command, and performing the duties of pilot in command.

Acting as pilot in command is the legal act of taking upon one's self the full responsibility for the safe outcome of the flight It is taking upon one's self the final and ultimate authority with respect to the operation and successful conclusion of the flight.

Logging flight time is writing down a record of one's pilot time down on paper, or entering it in a database. Logging PIC time does not imply that one has acted as PIC. One may be other than the PIC, and still log the time as PIC, legally. One may be the acting PIC, yet not be entitled to log PIC, under certain circumstances. Logging flight time is not the same as acting as PIC; it's simply making a record, and is governed by different regulations than those governing serving as PIC. Logging PIC and acting as PIC are entirely different subjects.

Performing the duties of PIC is neither acting as PIC, nor logging PIC. Performing duties of is exactly as it sounds; it's the act of doing. It's doing what the PIC does, and does not imply, suggest, or touch on any requirement or possibility of acting as PIC.

A pilot in command may perform the duties of pilot in command, and log pilot in command.

A SIC may perform the duties of PIC, but may not log PIC (unless qualified), and is not the acting pilot in command.

This is the purpose of the regulation, and it's not the only place in the regulation where performing PIC duties under supervision is found.

The real mystery, then, is what could possibly be your confusion, or the source thereof?
 
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Skywest Pylot

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Me too. But the "silver lining" is that after the Colgan crash, the days of hiring "unqualified" pilots for 121 ops is long gone. No more applicants getting hired with 188 total time, 14 hours multi, and a heart beat. Thank God that the changes are being made as we speak. The ONLY place for a pilot with 188 hours is flight instructing, banner towing, traffic watch, or gaining experience in the right seat of an aircraft that DOES NOT require 2 pilots. (except for insurance req.)

Think again. Now ALPA is pushing MPL. Add that to an increase to 9hrs max daily flight time and a 13 hr duty day and we've got the recipe for another Colgan type crash.
 

Tarzan

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Think again. Now ALPA is pushing MPL. Add that to an increase to 9hrs max daily flight time and a 13 hr duty day and we've got the recipe for another Colgan type crash.

9 and 13 works for me. I am not after completely killing my QOL. I'd perfer scheduled to 12 and 14 for IROPS. As far as MPL goes, I don't like it. If it does pass, they had better up the requires for ATP for anyone qualified under to say 5000 hours or something ridiculous like that. Regardless, every captain will turn into a training pilot overnight. If they want to pay me for it, fine. But if not, I don't have the inclination to help out like that. Let these airlines twist in the wind and find ways to get pilots to come to work.

I can't believe ALPA is looking for ways to help with this. The airlines know they have screwed the pooch and they have depleted their pool of potential new hires. Let them raise wages to attract pilots again.
 

JustaNumber

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The real mystery, then, is what could possibly be your confusion, or the source thereof?

How about the fact that you had to take the equivalent of 3 pages (although you did an excellent job) to explain the somewhat muddy FARs? You must admit that the FARs seem to be written to try to confuse. What's the point of logging PIC when you aren't acting as PIC? What's the point of logging in your logbook that you performed the duties of PIC, but you didn't officially "log" PIC? And how do you keep it all straight when the examiner wants proof of the 250 hours performing PIC duties, the 8710 wants a total of "logged" PIC time, but your next interviewer wants a record of only acting PIC time? Makes you want to just go get another beer.
 
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