Part 135 First Officer Intern Wanted

[time builder]

I'm not getting into what defends my company, nor will I, I'm not their spokesperson. I am defending what I've always been admonished to know, that is: how to justify a pilot logging time.

Have you had enough? As I said the other day, I'm just about done here, but you summoned me back, so here I am. We've given time building pilots plenty to think about, and again I think we're losing steam as far as the productivity of this discussion.

You insist I'm not listening, I am. I've also listened to the other side, theirs is more compelling to me. If you haven't caught my drift in this whole thread, I'm not a lawyer, I'm mostly passing on the other side's argument from the perspective of a pilot, and obviously defending my own intentions.

I have agreed with a lot of the things you've said, avbug, hopefully our next subject will be more pleasant. I'm gonna try to leave it at that.

 

[avbug]

I am defending what I've always been admonished to know, that is: how to justify a pilot logging time.

If that's the case, you're "defending" it incorrectly with misinformation, bad references, and a very poor understanding of the subject material. Thus far you've been 100% wrong.

Have you had enough? As I said the other day, I'm just about done here, but you summoned me back, so here I am.

Summoned you? I've repeatedly advised you to quit while you're ahead. This is the opposite of summoning you. It seems that you can't post at all, without being exactly 100% wrong. Every step of the way.

I had enough of you the first time you entered into the discussion to disclose your underhanded association.

You've been shown to be involved in not only a shady, but illegal operation, selling flight time for significant amounts of money. Enough in fact, that you've moved far beyond a misdemeanor to a felony. An attorney would tell you to shut up. You've been advised to shut up. You'd do well to shut up. Nobody has summoned you back. You've done that by yourself, and as you were advised very early on, you simply keep digging yourself deeper and deeper. While undoubtably your employer has no shame, your employer most certainly won't appreciate your leaving fingerprints and public statements where you ought not. One more time; you really need to shut up and slink away before you completely bury yourself, and your employer.

Do you understand this, yet? If not, keep yaking away. I'm more than happy to watch someone of your ilk sink right to the bottom, if that's what you really want. If you're you're that anxious to ram your head against the wall repeatedly, I'll even help you locate someone who has a reason to file...in the interest of cleaning up this industry one little pebble at a time.

...I'm mostly passing on the other side's argument from the perspective of a pilot,...

A classic example of one who doesn't, won't, or can't think for himself. I think we're done.

 

[brokeflyer]

so let's wait for the next episode of "who get's the last word?"

 

[Paradoxus]

I'm not getting into what defends my company, nor will I, I'm not their spokesperson. I am defending what I've always been admonished to know, that is: how to justify a pilot logging time.

Unbelievable. You are, in actuality, defending what has proven to be a wholly illicit justification for as much. The controlling regulations governing exactly this have been presented at length.

Have you had enough? As I said the other day, I'm just about done here, but you summoned me back, so here I am. We've given time building pilots plenty to think about, and again I think we're losing steam as far as the productivity of this discussion.

Had enough? Heh. This suggests to me you still consider this to be a debate, whereas I think it far more accurate to call it just what avbug did: a scathing, indicting exposure of fraud.

You insist I'm not listening, I am. I've also listened to the other side, theirs is more compelling to me. If you haven't caught my drift in this whole thread, I'm not a lawyer, I'm mostly passing on the other side's argument from the perspective of a pilot, and obviously defending my own intentions.

More compelling than a citation of easily-accessed evidence that demonstrates the contrary?

I have agreed with a lot of the things you've said, avbug, hopefully our next subject will be more pleasant. I'm gonna try to leave it at that.

Then why not admit your defeat? You cannot justify the veracity of such a "program" with respect to what is permitted in the regulations. Not only is the "service" your company provides unethical, it is totally fraudulent in its claims of what it can deliver.

I noticed that FR requires that clients of the program are required to have a CPL. Why? It seems like a superfluous stipulation given the hard facts surrounding the arrangement.

 

[WMUchickenhawk]

http://flightopenings.com/index.php...sting&layout=viewjob&vj=2&jobcat=58&jobid=230

It looks like they're hiring captains. I wonder if the company would accept the 300 hours SIC as counting towards the required 500 multi. Somehow I doubt it.

 

[livin'thesim]

Could anyone please cite the Operations Specifications page that would cover this issue?

In my career, which has been with maybe half a dozen 135 operators, the only page I recall that touches on this issue is A015, Autopilot in Lieu of Required Second in Command.

For passenger IFR, the requirements are structured that the SIC is always required unless the PIC demonstrates autopilot proficiency at checkride time. So, even if you have a King Air with an autopilot, the SIC is required unless this A015 is issued for that aircraft, and that PIC is trained and checked.

I only bring up this as a side issue to clarify what Ops Specs page is being referenced in this argument. Perhaps what a lot of people mean is that some companies place such an SIC requirement in the Company Operations Manual?

The company manual is a click further down the hierarchy than the operations specifications, in that in the event of a conflict, the ops specs is controlling.

I've gone round and round with lots of FAA inspectors about General Ops Manual as a legal document, and have received lots of different amswers. Several inspectors told me that if the Ops Manual requires pilots to wear neckties, then in the strictest sense, they could violate a pilot for flying without one (they wouldn't, they were just pointing out that they felt they could).

Other inspectors told me that in effect, they could not violate a pilot for GOM non-comliance unless an FAR had been violated. One example given was that suppose a company's manual prohibited night VFR flights. Since night VFR is legal, they said that they could not violate a pilot for acting against the manual. This interpretation, by the way, came from someone higher than the normal FSDO inspector level.

This means that these differing inspectors would have differing views on whether a statement in the Ops Manual requiring an SIC would have any effect of legally requiring one.


What I think is interesting is that when you spend a lot of time working with the FAA, you learn that the regs are not interpreted with the same black and white absolutism that we, as pilots (including me), would like to see.

We can read a reg and lawyer about it all day long, and we can feel that somehow we are able to see the 'truth' in the reg much better than others.

But without reading the original rulemaking document and/or seeing an interpretation from FAA legal (sometimes they do a sudden about-face as well), any attempt at regulatory absolutism may be pointless.

What really matters is what the FAA wants you to do and not do. This is learned through reading interps and enforcement actions.

The FAA is keenly aware that this type of logging is going on, and yet I have yet to hear of an instance where someone was violated for such logging. I would be interested to hear it ever happened. If it did, it would give tremendous weight to the opponents of this kind of logging.


That said, I am against pay for time programs.

 

[Secret Squirrel]

I think most of the posters on here are saying that this individual company may not be doing it on the up and up. They may not have the approved SIC training program and items in their ops specs to approve such a program.

 

[brokeflyer]

last time, the plane, operation and regulations DO NOT require a second in command.

UNLESS in section a of the ops specs the FAA requires the operator to have an SIC. And it ill say "operations require a second-in-command", in that case then the SIC can log time. That however is a whole other issue because then the captain would be taking his checkrides with an sic there. i.e. no single pilot.

I never said these jokers couldn't use SIC's, I said those SIC's couldnt not log the time because they aren't required crewmembers. And in this case, which we cant see their ops specs, the only way their statements of "logging sic time" on their web page is legal, is if the FAA requires them to have an sic per their ops specs. Because the plane(b99) and the operation (freight) dont require an sic.

so, to end this thread, this company charges a sic for flight time they can't log.

case closed.

 

[JAFI]

Since this is a "legal" discussion - If the aircraft or operation does not require an SIC then the person sitting in the other seat is legally a passenger not a required or any other flight crewmember. It does not matter if they are a pilot or not, there is no legal requirement for them to be there. They are not exercising the privileges of a pilot. The same reason a 135 VFR Day only Cessna 172 does not require a SIC. Any one sitting in the right seat is a passenger.

To my knowledge the current Automated OP Specs has no provision for a 135 Cargo operator to require a SIC in an aircraft that does not require an SIC. That is why I asked for a Op Specs reference. Since no one came up with one I would look at this as some one selling you a car and saying they will "mail" you the title. Keep both hands on your money.

 

[Secret Squirrel]

I think most companies are pretty touchy about employees spreading their proprietary information, such as FOM's and Ops Specs around on the internet. If you are the "civil service type" you claim to be you would probably have a better chance at looking into some of the companies that use these programs. How about confront the POI's or the local FSDO and ask them how they can allow such an illegal operation to continue. Up to and including carrying illegal passengers. They would probably like to know about it because these companies are being so hush hush about it, I mean they only advertise in every aviation magazine and on the internet. Go get em tiger.

 

[JAFI]

I cannot "confront" a POI or Office about anything; you need to go to a higher pay grade than me. (I have tried in the past, everyone I confronted got a promotion) That office, region or HQ can do that.

OP Specs are not private. There are Freedom of Information legal issues though. A written request to that office to obtain copies of documents (there is a copy fee involved).

A citizen can contact that Regional Office or HQ with their concern. A letter does leave a paper trail. Or call the national hot line phone number. This is tracked by HQ.

Senator Oberstar is a contact and he likes to hear about the FAA.

http://www.oberstar.house.gov/

D.C. Office
2365 Rayburn HOB
Washington, D.C. 20515
(202) 225-6211

I would be called a whistle blower and given a desk in a closet with a blinking light bulb with nothing to do untill I retire.

Can freight company carry (non-rev employee or non-employee) passengers? That could bear looking into.

There is no FAA requirement that companies be "Smart" or any way of measuring "Smart" that I know of.......

 

[brokeflyer]

the only thing you'll find in the ops specs, is a FAA requirement for an SIC. Which I'm 99% sure they wont have in there. The faa issues that little line when they have an operator they wish to have an SIC regardless of the plane or operation.

I friend of mine worked for a single-pilot operator who added a light twin. The faa REQUIRED them, per section A of their ops specs, to have an SIC in a c310. They were a new operator and this was a safety issue. Otherwise they wouldn't have an sic.

So your right, hold on to your money. You cant log the time in this plane. You will listed on the w&b as a cargo handler, not an sic. Good luck explaing that 500 hours of BE99 time. You're next employer will know what you're talking about more than you would.

good luck with that one.

 

[livin'thesim]

Again, any examples of the FAA stopping this anywhere, or violating a pilot for logging this type of time?

The FAA certainly knows that this happens.

 

[livin'thesim]

the only thing you'll find in the ops specs, is a FAA requirement for an SIC. Which I'm 99% sure they wont have in there. The faa issues that little line when they have an operator they wish to have an SIC regardless of the plane or operation.

What page would that be on?

I friend of mine worked for a single-pilot operator who added a light twin. The faa REQUIRED them, per section A of their ops specs, to have an SIC in a c310. They were a new operator and this was a safety issue. Otherwise they wouldn't have an sic.

A015 gives the authority to use an autopilot in lieu of SIC. Why would the FAA need to specify that an SIC is required? All they would need to do is not issue this authorization and the SIC would be required by default.

 

[brokeflyer]

Can freight company carry (non-rev employee or non-employee) passengers? That could bear looking into.

well normally yes, provided said passenger isn't being carried for compensation.

but this winner of the next safety award freight company is CHARGING for people to sit in the right seat and log illegal flight time. If they aint crewmembers, and they are paying an hourly rate, does that make it an instructional flight? Now they are giving flight instruction during a 135 leg. Is the PIC a check airman, that is the only way that would work. Is he a company designated instructor?

I could really rip that one apart.