PIC or SIC

[RJET]

I have a questions regarding logging PIC or SIC time in airplanes that are certified for single pilot operations such as a King Air.
However, the operator requires a SIC for safety purposes in a part 91 operation.

I looked it up in the FAR's, FAR 61.55 states that "no person may serve as SIC of an aircraft type certificated for more than one required pilot or in "operations" requiring a sic unless....:"
The King Air 90 do not require more than one pilot, however, what defines "operations" I called the local FSDO and I got two different answers. THe first said, that I could not log it as SIC, unless it was under Part 135 or Part 121. so in other words, I can log it as PIC anytime I was the sole manipulator of flight controls.
Another FSDO personel said, I could log it as PIC because the company had a designator PIC and I did not have the final authority.
Would like to hear others opinion in this matter.

Thanks

 

[501261]

Don’t go to the FSDO for answers, mostly they are just pilots who make the same mistakes that we all do. There are some legal opinions from the FAA lawyers on this subject that matter.

The lawyers say that under 91 you can almost never log SIC time in the King Air (the airplane is certified for 1 pilot, so it would be identical to logging SIC in a 172).

However, under 91 you can LOG (logging of flight time is different than actually being a PIC) all the flights that you are actually flying as PIC, thanks to 61.51e1i, as "sole manipulator."

Under 135 or 121 you can log SIC in a King Air because of 61. 55f1. If you are designated by a certificate holder as an SIC, you become a required crewmember. Be careful here, an insurance requirement or the PIC "taking you along" does not constitute being a required crewmember!

The only way to log PIC under 135, or 121 in if you are designated the PIC by the certificate holder.

 

[Timebuilder]

The OTHER thing to worry about...

Many operators do not look fondly on turbine PIC time logged under part 61. You wouldn't be the pilot who is ultimately responsible for the aircraft.

If you are on a career path, and I suspect you are, be mindful of this before walking into an interview ready to talk about XX hours of turbine PIC time. The FAR part 1 definition may be the only definition of PIC that the carrier will accept from their applicants.

SIC: I have lots of time in a Navajo where I was paid to add safety to the operation, but because the carrier had not designated me as a company SIC (that would have cost money, you see) the only time I could log at all was the part 61 dead legs. If the aircraft were a King Air, and I was flying dead legs and logging part 61 PIC as sole manipulator, I'd be careful to track that time separately from the turbine PIC that I would later log as an Far part 1 PIC. This way, I would not be giving the appearance of trying to inflate my numbers using a legal, yet not acceptable, total in the "turbine PIC" column on the time grid. I can easily break out the dead leg time for an interviewer.

>>The only way to log PIC under 135, or 121 in if you are designated the PIC by the certificate holder.

That's the PIC time they want when it comes to turbines.

Note: if you can sign out a King Air as a rental, you would likely meet most carriers's test for PIC turbine. In that case, you are responsible for the aircraft.

 

[Rick1128]

Rjet, opinions are like a$$holes, attorneys, especially FAA lawyers, have at least one if not more. On Part 91 flights where you are the manipulator of the controls, I can see no problems with you logging that time as PIC. If the comapny is hiring you as a SIC and you are getting paid for this, log it. You are then a professional pilot, being paid to perform that fuction. It then becomes very difficult for the FAA to argue against that position. If you are not getting paid, log it and have the PIC endorse the entry as a 'Safety Pilot". That time is logable as SIC.

As for Part 121, dispite some Captains' opinions, I don't know of any 121 operation that could be even considered single pilot. Mostly due to aircraft certification. Some of the smaller aircraft (Metro's, 1900 and 99's are single pilot certified).

Part 135. According to the legal opinions, I have read issued by FAA Legal, you can log PIC when you manipulate the flight controls. Some operators have a section in their Operations Manual that precludes that, however. On aircraft not requiring a type rating that would not be much of a problem. However, aircraft requiring a type rating, you will have difficulty explaining that during an interview.

And before the junior legal eagles jump on me, let me state this is based on opinions issued by FAA Legal, Washington. According to Legal, the pilot must be appropriately rated. However, Legal defines appropriately rated as having a form 8410-3 issued to the pilot in question. I don't make this up, I just read them.

Rjet, my best advise is do what you feel is right, but back it up with all the documentation you can. In other words, document, document, document. One piece of advise, whenever you talk with the Feds, get their full name and write a 'Memo for Record' during or right after the discussion. And keep it. They do the same thing.

 

[A Squared]

>>>>>If the comapny is hiring you as a SIC and you are getting paid for this, log it.

It depends on exactly what you mean by "log it". If you mean that he can log as PIC that time which he is sole manipulator of the controls, you are right. If you mean that he can log all the time he is in the airplane as SIC, then no, that is not correct. 61.51(f) covers logging of SIC time, and there is no provision for logging time when a SIC isn't required. In order to log the time, an SIC must be required, either by the type certificate of the airplane, or by the regulations under which the flight is conducted.
An SIC "required for saftey reasons" in a single pilot airplane by the operator, is not required by the regulations. The only time RJET can log is pic when he is the sole manipulator of the controls. There is some controversy regarding the value of time logged this way. Some airlines specifically exclude "sole manipulator PIC" from thier experience grids on their applications. make sure you know what the airline means when they ask for PIC time.


Regards

 

[Rick1128]

The real world

First of all, Rjet, you are only required to log the flight time necessary to show currency and for higher certificates and ratings. Next, FAA lawyers are like any other prosecuters, they will only take the cases they can win. So you logging flight time that does not quite meet the full definition of Part 61 to them is not important enough to try. As long as you do not failisfy your log book. In other words, you were in the seat and performing the functions of a SIC. FAA inspectors, especially GA inspectors are so overloaded right now, that this is below their radar. So as long as you don't use the copilot time for your next certificate, I wouldn't worry about it too much.

As for employment interviews, I have been on both sides of the table and have discussed this with other management pilots. We all agree on this. We really don't care if it really met Part 61 or not. If you were really doing the job, you got experience out of it. And that is the name of the game experience.

Now, to get the most of that experience, I suggest you do the following. First get a copy of the flight manual. If you can get a copy of the FlightSafety manual, even better. Study them. Really know the airplane. Don't be a sit on your hands co-pilot. Talk with the pilot and discuss your duties. Things like passenger loading and briefing. Baggage. Aircraft prep. Flight planning. Weather. Radio work. Navigation. CHECKLISTS. In short, as a co-pilot, you are part of a crew. BE A CREW.

A2, Like my old chief once said, 'Fine. That there was school, this here's the fleet'. The real world is that the FAA is not going to screw with a pilot who is making an honest effort to record his flight experience. As long as it is an honest record. It is too grey an area with too much tradition behind it. Besides the FAA is trying to push all turbine operators into 2 pilot operations and CRM and this would be a major hicupp in their plans.

Rjet, just a thought. If you really wanted to CYA, get a senior company official, like the presdient or Chairman to write you and the chief pilot a memo, requiring you to log your flight time for 'insurance' reasons. That will really muddy the waters.

 

[airludy]

I am in the same situation flying a king air 200. All the other copilots before me have moved on to great flying jobs...Airlines, good corporations...Trust me, its better experience than buzzing around VFR in a 152.

 

[A Squared]

Rick,

Your comments on this are based on "what's reasonable" or "what makes sense". I have no doubt that you're a reasonable, sensible guy. If you were reviewing my logbooks, either as an interviewer, or as an FAA inspector, I wouldn't sweat it a bit. I think you'd approach it with a reasonable, sensible attitude, rather than a nit-picky attitude. Whether it was a job interview, or an official review of my logs, I expect it would probably be a relaxed, friendly affair. The thing is, I can't be sure that I'm going to be dealing with guys like you in either setting.

The question is whether it's legal to log SIC time when an SIC isn't required, and the answer is no.

Your comments about whether the inspectors would pursue it are a little off the point. They answer the question. "will I get caught, and if I get caught, will I get violated?" Certainly points to consider, but that's definately not the same question as "is it legal"

>>>>The real world is that the FAA is not going to screw with a pilot who is making an honest effort to record his flight experience.

I'd like to believe in an FAA which thinks like this, unfortunately, like the tooth fairy, I don't think it exists. You may be right about the majority of FAA inspectors, they probably wouldn't be interested. But, you can bet your sweet bippy, there's some out there that would just love to violate you on this.

Yeah, the FAA isn't going to demand to see your logbook, just to check for this specifically, but they often do request to see your logbook when you've come to their attention for any reason. I know a number of pilots this has happened to. Once they're digging through your logs, anything in there is fair game. Despite what you say, it would be an easy bust. It would be easy to spot in your logbook, and it would be easy to prosecute and make it stick. In one hand, you have your log book with SIC time logged in a single pilot airplane, and in the other hand, you have 61.51(f) which clearly states that it's not legal. They don't need anything more than that. You refer repeatedly to "the real world", the thing is, we're not talking about the world outside the FAA. Once you're in an enforcement proceeding, the "real world" is the text of the regulations, not "what's reasonable".

>>>>>>If you really wanted to CYA, get a senior company official, like the presdient or Chairman to write you and the chief pilot a memo, requiring you to log your flight time for 'insurance' reasons. That will really muddy the waters.

Sorry, that's very bad advice. If you are unfortunate enough to be in the position of having the FAA deciding whether to violate you for this, that won't cover even a little corner of your a$$ or even make the waters a little cloudy. The guy that decides whether there's a violation is going to be looking at the regulation that says a SIC must be required by the type certificate or the regulations. Period. An internal company memo won't make the smallest bit of a differnce in his decision. The key to this situation is not to be in it. You avoid being in it by knowing what the regulations say and not putting things in your logbook against the regulations.

Regarding logbook reviews: I know that it is no longer the policy of the FAA to review the logbooks of ATP candidates, but I personally know one DPE who still does, even for commercial candidates. A few years ago, back when written tests were still written, I took a knowledge test from his wife, a designated test proctor, or whatever they call them. She went as far as to unscrew the barrel of my pen to check to see that I hadn't stashed some notes there. Now, these two people are designees, not FAA employees, but you will encounter this mindset within the FAA also.

>>>>>Besides the FAA is trying to push all turbine operators into 2 pilot operations and CRM and this would be a major hicupp in their plans.

This may be true, and it might be relevant if the FAA was a consistent organization, with everyone working toward the same end. The thing is they're not. There's a lot of different people, with a lot of different agendas, many of which are contradictory. There's a 135 operator in my area which operates the turbine navajo (PA-31T3) single pilot. They had a series of accidents, all pointing to pilot overload, including one which killed 5 people. The FAA required them to switch to 2 pilot crews ..all well and good. makes sense, and fits with what you said....but guess what? they're back operating single pilot again. This is a lot bigger hiccup in the 2 pilot turbine plans. If the FAA is going to re-authorize single pilot turbine ops for this operator despite the desire to have all turbine ops conducted with 2 pilots, than certainly something as simple as violating a pilot for logging illegal SIC time isn't going to faze them.


Interviews:

Again, your views reflect a reasonable, common sense approach to things. I would hope that any interview I get invited to would be conducted by pilots such as yourself. The thing is, not all interviews are like that. For some reason, many airline interviews are adversarial. United, particularly, has a reputation for this style of interview. I know folks who have been to United interviews, and that's what I hear from them.

So, you're sitting in one of these interviews, and one of the interviewers is flipping through your logbook. He stops and says, "I see you have SIC time logged in a King Air, can you tell me how you came to be logging SIC time in a single pilot airplane". You tell about the Part 91 operation and the good experience you gained from it, and what you learned about flying. The guy responds, that's nice, but under 61.51(f) it's not legal, now can you explain why you are logging illegal time? Suddenly, you have a feeling your interview isn't going so well. Harsh? yes, Unreasonable? perhaps, Can't happen? think again. An acquaintance of mine encountered precisely this sort of adversarial, in your face, "this is the law, and you violated the law", attitude in a United interview. It was regarding a single, minor traffic infraction, not a logging infraction, but guess what? He didn't get the job.

Your advice to get the most out of the experience, really learn the airplane, and be a functioning part of the crew is good advice.


BTW, where did you fly the DC-6?

Airludy,

I'm not suggesting that it's not good experience, certainly it can be if you make the most of it, but the question is, is it legal to log it as SIC, and the answer is no.

regards

 

[El Cid Av8or]

You can log SIC time in an aircraft that is certified for single pilot IFR under Part 135. The SIC is not required, but that does not mean that you can't have one. The SIC minimums for Part 135 are instrument and commercial ratings as well as a category (SEL or MEL, etc.) and type (B-200, etc.) rating if necessary. This is found under part 135.105. Also, any aircraft operating as Category II must have an SIC (Part 135.111).

Under Part 91.189.a.1 for Category II or III operations reads this:
"The flight crew of the aircraft consists of a pilot in command and a second in command who hold the appropriate authorizations and ratings prescribed in Sec. 61.3 of this chapter"

Then we see in Part 91.531 the following:
(a) Except as provided in paragraph (b) of this section, no person may operate the following airplanes without a pilot who is designated as second in command of that airplane:
(1) A large airplane, except that a person may operate an airplane certificated under SFAR 41 without a pilot who is designated as second in command if that airplane is certificated for operation with one pilot.
(2) A turbojet-powered multiengine airplane for which two pilots are required under the type certification requirements for that airplane.
(3) A commuter category airplane, except that a person may operate a commuter category airplane notwithstanding paragraph (a)(1) of this section, that has a passenger seating configuration, excluding pilot seats, of nine or less without a pilot who is designated as second in command if that airplane is type certificated for operations with one pilot.
(b) The Administrator may issue a letter of authorization for the operation of an airplane without compliance with the requirements of paragraph (a) of this section if that airplane is designed for and type certificated with only one pilot station. The authorization contains any conditions that the
Administrator finds necessary for safe operation.
(c) No person may designate a pilot to serve as second in command, nor may any pilot serve as second in command, of an airplane required under this section to have two pilots unless that pilot meets the qualifications for second in command prescribed in Sec. 61.55 of this chapter.

Which does NOT say that a person can't log SIC time. It just says that an SIC may not be needed if...

Then we look at Part 61.51.f and find out that we cannot log SIC time if the aircraft does not require it. Oh well.

Would the FAA kindly consolidate and SIMPLIFY the FARs, please

 

[slapstick]

If you don't plan on getting a ton of King Air hours in the right seat, and it's a 91 operation with a MEI captain, just log it dual received. Then they shouldn't be too leery of you if you don't know V speeds in an interview.

 

[Rick1128]

You really need to deal with the FAA on a regular basis. When they can't agree on what you can and can' t, why should we agree? In talking with an ex-FAA lawyer, who worked out of the Washington HQ, I was told that the FAA's lawyers spend a majority of their time writing what are called 'Letters of Intrepretation' In these letters they either define the regulation or the phrasology of the regulation. So you will find that the regulations are not as cut and dried as they first appeared.

As for an interview, NO ONE is going to ask what A2 said they will. I have been on interview boards. I have reviewed resumes and logbooks. If your resume said you were a KA90 co-pilot for XYZ Corporation and the company when called confirmed that fact. The only thing I am going to do, like almost all interviewers is to find out if you were a seat warmer or really did the job. In other words do you know the aircraft and the job. If so, no problem. If you're a seat warmer, your out of luck. And I have found seat warmers that had time in Lears, Metro's, etc, which require two pilots. Needless to say they didn't get the job.

The interview process is where they wed out those pilots who just showed up for work, talked on the radio and took care of the passengers. All they are is seat wamers.

Rjet, you're the one who has to live with your actions. With your talking with the FAA, you did what the lawyers call 'due diligence'. You were not sure, asked questions of the people who should know and went from there. I suggest you do what you are comfortable with.

On a professional note. I sugget that when ever to talk with the Feds, write what is called a "Memo for Record". Create a file and keep it. In it note the person's name, office, date, time, location and what was said. I also note my personal thoughts, observations and opinions. I also keep copies of every letter I write to the FAA and that I receive from them. I have written my personal memo, right in front of them. Be aware they do the same thing. Level the playing field a little.

As for the DC-6 question, YIP and MIA.

 

[A Squared]

Rick



>>>>I was told that the FAA's lawyers spend a majority of their time writing what are called 'Letters of Intrepretation'

Yes, I am aware of letters of interpretation, I've read more than a few. THey are very useful for clarifying unclear or ambiguous regulations. The thing is, 61.51(f) isn't unclear at all.It very clearly states that an SIC must be required by the aircraft's type certificate of by the regulations.

>>>>So you will find that the regulations are not as cut and dried as they first appeared.

I would be willing to wager that if you asked 100 FAA lawyers if "required by the regulations" means "required by company policy" or "required by my insurance policy", all 100 would respond with an emphatic "NO".

Your observations about due dilligence are alright, as far as that goes, but, If you will go back and read RJETs original post, you will see that he was told that he could not log SIC time in a single pilot airplane, just as I have been saying. Due dilligence isn't much of a defense if you have acted in direct contradiction of the information you were given.


>>>>>As for an interview, NO ONE is going to ask what A2 said they will.

Well, that's a pretty broad statement. I beleive that you are making the mistake of taking what *You* would or wouldn't do, and projecting it to the world in general. From the little I know of you, you're probably a pretty reasonable man. I wouldn't expect you to jerk someone around on this issue, but then, nor would I expect you to jerk someone around about a single minor traffic violation. The thing is, not all people are like you. For whatever reason, the guy I knew *DID* have some idiot at his United interview, very confrontationally demanding to know why he thought societies rules didn't apply to him, all over one minor traffic infraction. It's not a stretch at all to suggest that this same idiot would jack someone around over some SIC time that wasn't quite by the regulations. I don't know if this guy was just an A$$hole, or this is part of United's interview games, or what, but this type of behavior is real. I'm sure that you don't conduct interviews this way, but that doesn't mean that other companies don't.

Your advice about documenting conversations with memos is right on.

>>>>>As for the DC-6 question, YIP and MIA.


Zantop? Trans-Continental? Universal?

regards

 

[Timebuilder]

My information about part 1 PIC versus part 61 PIC comes from a captain who has regularly served on the hiring board for Continental. They believe that part 1 is a higher standard than the part 61 definition. He was very emphatic to me about the appropriatness of time logged. According to him, his comapny wants to see only proper, legally logged flight time for PIC and SIC. For example, he told me very specifically that in order to show him SIC time from a single pilot aircraft, he wanted to be certain that the ops specs showed that requirement for an SIC. A good example of this is the AirNet program.

If you stick with the regs a much as possible, you can rarely go astray. The ability to do something without gettin violated may speak volumes to an interviewer about your character. Some employers still care about that.