Low Time FO's

[OCP]

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

No you weren't.

 

[avbug]

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?

 

[Skywest Pylot]

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]

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]

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.

 

[avbug]

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?

No, I took the equivalent of part of one page...as there are multiple threads per page. The regulation is very, very clear on the subject.

The reason the explanation was extended did not have to do with an unclear regulation but the original poster who seems to be having some difficulty with the English language. Breaking plain English down to baby words takes up a little more space.

I was PM'd, and asked to comment on his thread, in part due to his comments here, and in part due to his comments elsewhere. I don't participate at the "elsewhere," so I was asked to comment here. In particular, my invitation noted that this poster tends to back up his statements with his own imagination ("someone told me") or what he guesses might be right, whereas I tend to back the conversation up with quotes, citations and facts. This also takes up space.

You must admit that the FARs seem to be written to try to confuse.

You really need not tell me what I must and must not do. The regulation is not at all written to confuse, and it's among the shortest and concise of any federal regulation (ever see the tax code?). The regulation is not a comic book. One needs to actually pay attention and read it, rather than guessing what is there.

What's the point of logging PIC when you aren't acting as PIC?

For one thing, they're entirely different subjects. For another, the regulation was made that way in favor of the pilot; it's a courtesy. The regulation recognizes that one has performed as a PIC and met the specific requirements of log that time, and that one is qualified in the airplane. Being the PIC is a legal responsibility; it's an office one briefly holds. Logging PIC is a record of experience pertaining to a specific set of criteria. You might as well ask what's the point of eating an orange when you can look at the color orange? The point is they sound the same when spoken...but are two entirely different things and shouldn't be confused. Most pilots do, because they're too lazy to read and understand the regulation.

This is a mystery. The pilot lives by his pilot certificate, is governed by and has privileges only according to the regulation which granted the certificate, and is under penalty of code and law to always adhere to those regulations on pain of losing his certificate...yet won't lift a finger to understand the regulation.

What's the point of logging in your logbook that you performed the duties of PIC, but you didn't officially "log" PIC?

What's the point of being hungry, but looking at the color orange? We're back to ignorance of the regulation again. The color and the fruit are not the same, any more than acting as PIC and logging PIC are not the same...in fact they're very different and distinct regulations, subjects, and concepts. That they sound the same should trip up a third grader...but shouldn't really present a problem to an adult capable of reading the English language.

Where does the regulation state that you must "log in your logbook that you performed the duties of PIC," or that "you didn't officially 'log' PIC?"

The regulation does not state this? Why invent what's not there?

You need not log PIC, period. You must perform the duties of PIC for a small part of the total 1,500 hours required for the ATP, in the category of aircraft (airplane, in this case). That's it. The FAA has graciously provided that one can get the ATP without ever having actually been the PIC...so long as one has demonstrated performance of those duties under supervision. The FAA is giving the pilot an "out," a chance. This is a favor to the pilot. They're giving you your chance to get your ATP..and you whine about documenting it? Truly unbelievable. Perhaps you'd prefer that the FAA come to your house, or your place of work, and log it for you? This is a typical attitude, of course...not willing or interested in lifting a finger to help one's self. Too hard?

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?

Firstof all, the 8710 doesn't "want" anything. Least of all PIC time. Do you not know how to fill one out? Do you not understand that if one is using simulator time, the form won't show 1500 hours, and that if one isn't using PIC time, one need not show PIC time? Have you not read the directions?

Do you not understand that the "examiner" doesn't "want" anything different...and is bound by the regulation, too?

What your interviewer wants is irrelevant in the face of the regulation. The regulation isn't written for your employer or your interviewer, but for you. What you really need to consider is how foolish you may appear showing up for an interview and not understanding the regulation.

I recently participated in a thread with a pilot who was logging only half of his SIC...because someone told him that's the way it is. His instructor, who also was ignorant of the regulation, told him this. Rather than actually crack a book or lift a finger to check, he miraculously went several thousand hours, and logged half of it? One cannot blame the regulation for ignorance thereof...it's simply a matter of pilots who are too lazy to actually read for themselves. As for what an employer wants to see...it's up to you to go get the experience.

Rest assured that if you meet the requirements for the ATP and obtain the ATP, the employer isn't going to tell you that you're not qualified to hold the ATP. If you're complaining about obtaining the ATP based on SIC experience rather than PIC experience (as the regulation allows), the only issue is in your mind.

With regulations such as 61.159, the FAA has handed the ATP applicant a gift on a platter...but only a pilot would whine and complain that even this is too hard. Too hard to do, too hard to log, too hard to understand. The FAA has bowed down to you, stated that you don't need the PIC time...you can do it with SIC, that's it...and even this is too much. I'm not sure if it's arrogance or sheer laziness that cops such an attitude, but it's prevalent in the business either way, and a sad comment on those who profess it.
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[V-1]

Good to see you post, avbug. Just a heads-up...attention spans have decreased significantly during your absence...but you're already noticing that.

 

[JustaNumber]

With regulations such as 61.159, the FAA has handed the ATP applicant a gift on a platter...but only a pilot would whine and complain that even this is too hard. Too hard to do, too hard to log, too hard to understand. The FAA has bowed down to you, stated that you don't need the PIC time...you can do it with SIC, that's it...and even this is too much. I'm not sure if it's arrogance or sheer laziness that cops such an attitude, but it's prevalent in the business either way, and a sad comment on those who profess it.

For someone who is able to read the FARs so precisely, you sure read a lot into my post that wasn't there. I believe it is arrogant of you to brand me as ignorant, whining, and lazy based on a few questions I posed about not agreeing with the point of what the FAA does. Believe me, I fully understand the distinctions the FARs make; I just don't agree with their lack of simplicity. That a previous posted stated that the FAA examiner and company instructor had to spend an hour and 15 minutes carefully parsing the wording of the FARs certainly adds to my point. Please be more circumspect about using your "sad comment" language; it's no way to win friends or influence people. Surely as a captain you understand the importance of good human relations?

 

[avbug]

Please be more circumspect about using your "sad comment" language; it's no way to win friends or influence people.

I have no desire, nor need to do so. You live your life; I can manage my own quite nicely, thank you.

 

[JustaNumber]

I have no desire, nor need to do so. You live your life; I can manage my own quite nicely, thank you.

You obviously have a desire to influence people's understanding, or else you wouldn't have spent as much time as you did with your explanations (unless you just like to see yourself type). You and I both have a need to influence people all the time as captains. I'm just suggesting you change your tone so we can have an intelligent discussion without all the name-calling. Life (and leadership) works much better that way.

 

[avbug]

I don't have a desire to influence anyone. I was asked to comment, and I did. I posted correct and accurate information, and whether anyone is influenced by it, I couldn't care less. The regulation remains the regulation, regardless of whom might think otherwise.

You have a ball influencing whomever you will, and change whatever tone you like. I have no need, or intention, of doing so.

Intelligent conversation? For those who find plain english regulation difficult to understand, I think any hope of intelligent conversation on the matter is long since lost. All that remains is baby talk in a largely wasted effort to explain.

 

[TMMT]

Avbug is kinda like that misunderstood uncle every family has, you know... the one that screams and yells at everyone for trotting across the lawn all year long then gives out bottles of Jack Daniels to everyone including the children for Christmas gifts.

 

[avbug]

This, from someone who calls himself/herself

TMMT
Town Drunk

No...the truth is that posters who make foolish comments such as "the regulation is hard to read" get upset when they're shown that it's their own laziness at fault, and not the regulation...which is written in plain English. Perhaps the FAA would be best publishing a cartoon version in order that some might not have to think too hard.

 

[TMMT]

Perhaps the FAA would be best publishing a cartoon version in order that some might not have to think too hard.

Coloring book might not be a bad idea... maybe connect the dots

 

[JustaNumber]

Intelligent conversation? For those who find plain english regulation difficult to understand, I think any hope of intelligent conversation on the matter is long since lost. All that remains is baby talk in a largely wasted effort to explain.

I bow down to your clearly superior intellect. I also cringe at your clearly inferior people skills. So you're a real smart jerk. What a way to make the world a better place! I think I'll color my coloring book with a smile, thank you.