Quality time?

[hot section]

I am currently residing in FL but will be moving back to Madison, WI by the end of April. I have 625 TT, 162 Turbine (102 is PIC), 183 multi, and 54 actual instrument. I know that the regionals are looking for at least 1000 TT, some more than that. Should I bother sending in a resume to any companies or should I wait? Secondly, does anyone know of any good flight operations which are conducted near Madison, WI where I could work to build more time? The only place I know of that is close is Wisconsin Aviation in Madison and Watertown.

 

[bobbysamd]

Applying to Commuters

Your turbine time and actual v. total isn't bad. How much is PIC? Turbine PIC is key.

I see no harm in starting up the commuter resume spam if you find yourself able to continue building time. Don't get your hopes up too high, though. You'll still be fighting furloughed people and people with more time than you for the crumbs the commuters are throwing out. I'd send to 135 and freight if you feel so inclined.

Lots of luck with your job search.

 

[~~~^~~~]

I've got to know - who is insuring 500 hour pilots for PIC in turbines? If this came up on somebody I was interviewing, I'd be very curious...

As a pilot who occassionally helps other pilots find insurance, I'd like to know who has underwriting standards this flexible. So please tell.

 

[hot section]

PIC in Turbine

The PIC time came from flying the PC12. I was an intern for the state of WI aviation department and flew under their part 91 ops. I had a high altitude endorsement so it was legally logged.

 

[avbug]

THe high altitude endorsement makes no difference in the legality of logging PIC in an airplane. It makes a big difference in the legality of acting in as PIC, in an airplane requiring the endorsement.

To log time as PIC, you must be rated in the airplane. An endorsement is necessary to act as PIC (different from logging PIC); however, an endorsement is not a rating, and is not required to log pilot-in-command time.

Don't build time. Build experience. There is a big difference between logging time, and gaining experience.

 

[LR25]

Bragging rights!

If my dad was a 74 box hualer and he let me fly the thing, he would have had to lock me my room until he retired.

I must say thats cool as $hit.

LR25

 

[ksu_aviator]

Hotsection--

Send out the resumes but my guess is don't expect to get called in until you have 2000 hours or so. Reading the gouges on COMAIR, I only see that number and higher getting hired right now. That should come down as the airlines slowly begin to hire again, but right now its doubtful that you would be called.

The key is to send out resumes...they won't call you if you don't. You may not have a very good chance at getting an interview right now...but the more you send out resumes the better you look to that airline. I know American Airlines wants to know that you have sent out many resumes to many airlines. They only want serious airline pilots and they feel that serious airline pilots try to get hired by any major. The point is...send send send.

 

[727PAA]

PC 12

The Pilatus doesn't require a type...does it? With the high altitude endoresement you can go ahead and log that time (legally). Any time you are flying the airplane and you are rated in it(if required) part 91 then log it.

The Pilatus is a single pilot airplane so you cannot log any of the time that you were not manipulating the controls (part 91).

Send out the resumes, but, expect to answer questions about the airplane, such as, limitations, powerplant, etc.

 

[ksu_aviator]

Actually, you can log part 91 SIC time or 121 and 135 time for that matter in a single engine airplane. The reg on SIC time says something to the effect that you can log time as SIC if the aircraft is certified only for flight with two pilots or the company policies or insurance requires a second pilot.

Just to go a little further, you can't log IFR time unless you are actually manipulating the controls. You also don't have to be type rate, just current in category, class and type, and even that can be waved if you get the landings and ground school in the first 90 days.

I think that has to be one of the least rigid regs out there.

 

[bigD]

Hmmm....interesting. Do insurance companies tend to dictate minimum requirements for the guy flying SIC? It's amazing that hot section, with about the same amount of TT that I have now (at the time he started flying SIC in the PC12), was given the opportunity. I'm jealous, hot section!

I'm a programmer for a small company that flies the big boys around in Citations. Maybe I need to start talking to the pilots...

 

[727PAA]

SIC

SIC cannot be logged because a company requires it nor if insurance requires it.

Case in Point..the Pilatus. The Pilatus is a single pilot certified airplane.
Just because a company says you will have a second pilot in the airplane does not mean that the pilot (not flying) can log that time.

61.159 ATP requirements: a commercial pilot may credit the following second-in-command flight time or flight engineer time toward the 1,500 hr of total time

1. Second in command time provided it is acquired in an airplane-
(i) Required to have more than one pilot flight crewmember by the aiplanes flight manual, type certificate or the regulations under which the flight is being conducted.

This is what interviewers are looking for if you say you have SIC time in a turbine aircraft.

Also their are SIC requirements that must be met under FAR 61.55

Just something to look out for.

 

[A Squared]

I second what 727PAA says about logging SIC time. Ignore KSU_Aviator. Despite her "superior" KSU education, she's apparently failed to do the most basic of fact checking before posting; reading the printed regs. Take a look at the excerpt from the regs that 727PAA has graciously supplied. Notice that it only refers to requirements "........by the manual, the type certificate or regulations....." not ".....by the regulations, insurance requirements, company policy, or someone's grandmother"
61.51, which regulates the logging of all SIC time, not just that for an ATP, contains exactly the same language as 61.159

It doesn't matter a bit what the company or insurance policy wants, if a SIC not required by the regulations, you can't log it.

KSU's statement that you may not log Instrument time if you are not sole manipulator of the controls is somewhat questionable also. The regulation states that you can log if you are "operating" the airplane by reference to instruments. The issue hinges on what the definition of "operating" is. Certainly in other cases, the FAA has held that an SIC is operating the airplane, even if he isn't manipulating the controls. Additionally, when the FARs mean sole manipulator, they say "sole manipulator", giving further indication that "operating" does not mean "sole manipulator" For a more in depth discussion of this take a look at this link. http://www.propilot.com/doc/logging2.html#defin It is addressed down near the bottom of the page. In absence of an FAA legal counsel interpretation specifically addressing this, it is impossible to say for certain which is the correct interpretation. Personally, I log only that instrument time when I'm the PF. I'd rather fly like someone with twice my time than fly like someone with half my time, but that's just personal preference.

As far as KSU's statement about SIC qualifications, all I can say is ...... huuhhhhh?????? Let me get this straight, you're saying that you can just hop in any transport category aircraft and legaly serve as SIC, as long as you study the flight manual, systems, emergency procedures, performance specs, limitations and all that other stuff required by 61.55 sometime within the next 3 months?????????

really????? I didn't know that the FAA recognized retroactive flight training. Does this apply to other privileges as well? Can I act as PIC of a 747 as long as I get a type rating 90 days later?

Can you actually support this with some credible source, or are you making this up?

BTW it's "waived" not waved ..... I have to say, I'm getting less and less impressed with the quality of education avaiable at KSU



regards

 

[Colonel Cairo]

KSU,

So if you can't log IMC time unless you're handling the controls then that means as PNF you can't log night time either, right? Seems to me that they're both conditions of flight. Guess I better go back and delete all that IMC and night time I logged when I was an instructor. After all, I wasn't actually flying the plane.

Honestly, I really don't care how people log their IMC time, I just thought I'd open this can of worms again. It was either that or start another PFT thread and we all know how old that gets.

Cheers!

 

[Fr8Dog]

Hey Hot Section send me a private message I have some info on WisAv. I worked there as a line guy for 2 years and as a CFI for 6 months along with getting all my ratings there, not at MSN but at their Juneau FBO. I also know of a skydiving outfit near there that has 182's and if you want to build time fast you can log well over a 100hrs a month during the summer there. I may also have some other leads for flying jobs in the area.

 

[Bluto]

You can log instrument and night time as an SIC, regardless of whether you are the PF or PNF. Only the PF, however, can log instrument approches or landings towards currency, since part 61 requires that you be "sole manipulator" of the controls. Incidentally, as I understand it, you could log SIC under certain conditions in an aircraft certified for single-pilot operation, like the PC-12. As a safety pilot while the PF was under a view-limiting device, for example. I don't want to get into that debate, though.

 

[FlightTraker]

Hey hot section,
send me a PM if you want the skinny on the Appleton area. The outfit I used to instruct at has a rather large charter dept as well. I am also interested on any info you can give me about that PC-12 you were flying for the State.

FlightTraker

 

[avbug]

Bluto,

You are correct, sir!

A SIC may be required by the aircraft type certification, or the regulations under which the flight is conducted. Without reiterating what A Squared said (which was all quite correct), insurance or company requirements do not constitute the need for a SIC.

OpSpecs requiring a SIC do constitute the need for an SIC, for the purposes of logging the time. A single engine airplane operated under FAR 135 under IFR, for example, will need either an autopilot, or a SIC. In such a case, though the type certification allows single pilot operation, the OpSpecs will specify the need for a second pilot, when conducting flights under the operating certificate. In such a case, the SIC becomes a required crewmember. When the flight is operated under Part 91, the SIC is no longer required, and may not log the time.

 

[bobbysamd]

Instrument time

Bluto is indeed correct on logging instrument time. A CFI-I giving instrument instruction in actual instrument conditions (which is probably the only kind of instruction which can be given in actual instrument conditions ) can log as actual all time during which the flight is conducted in IMC. Of course, the CFI-I gets PIC and night, if applicable. In the meantime, contrary to at least one former FlightSafety Chief Pilot's belief, the CFI does NOT get the approaches that were executed, unless he/she was sole manipulator of the controls.

Ten years ago we had a Chief Pilot who was trying to sell us on the notion that instructors could count their students' approaches as their own for currency. I .... don't..... think.....so.

 

[ksu_aviator]

Ok, I was wrong about the 3 months...its 30 days.

To qualify as SIC you have to have the requirements met within the first 30 days if it is a 91 operation. Read 61.55 and you'll see that. Maybe some of you should try reading the whole thing instead of just the parts you want to read.

As far as the insurance company or operator requiring SIC's for single pilot aircraft, it is possible. If the insurance company is requiring the operator to use an SIC and the operator includes that requirement in its operating certification then by regulation, the SIC is required. Ops specs hold the same weight as a regulation, if you violate them you violate the FAR's. Even if its a part 91 operation.

Logging IMC as SIC and not actually flying the airplane isn't legal according to an inspector at the San Antonio FSDO. I forgot his name or I would post it so you could verify it. Try calling your local FSDO and asking...the FAA is here to help you.

By the way, CFI's aren't SIC so they really don't apply to this conversation do they?

By the way Squared....my dick is waaaayyyy longer then yours!


here is part of the regulation:

(b) Except as provided in paragraph (d) of this section, no person may serve as a second in command of an aircraft type certificated for more than one required pilot flight crewmember or in operations requiring a second in command unless that person has within the previous 12 calendar months:

(1) Become familiar with the following information for the specific type aircraft for which second-in-command privileges are requested --

(i) Operational procedures applicable to the powerplant, equipment, and systems.

(ii) Performance specifications and limitations.

(iii) Normal, abnormal, and emergency operating procedures.

(iv) Flight manual.

(v) Placards and markings.

(2) Except as provided in paragraph (e) of this section, performed and logged pilot time in the type of aircraft or in a flight simulator that represents the type of aircraft for which second-in-command privileges are requested, which includes --

(i) Three takeoffs and three landings to a full stop as the sole manipulator of the flight controls;

(ii) Engine-out procedures and maneuvering with an engine out while executing the duties of pilot in command; and

(iii) Crew resource management training.

(c) If a person complies with the requirements in paragraph (b) of this section in the calendar month before or the calendar month after the month in which compliance with this section is required, then that person is considered to have accomplished the training and practice in the month it is due.

 

[bobbysamd]

Instrument time

I just added my comment because a lot of questions come up on non-flying pilots, including CFIs and SICs, logging actual, night and approaches.

 

[Cornelius]

KSU_Aviator, last time I looked at 121 regs about 7 months, 121 OPERATIONS ARE PROHIBITED IN SINGLE-ENGINE AIRCRAFT. I can't remember which reg it is but I'm sure i'm right. That's why you'll never see a 121 operator flying SEL aircraft around.

121 ops are only in multi-engine aircraft.

 

[A Squared]

>>>>>"Ok, I was wrong about the 3 months...its 30 days."

No, You're still wrong, and I HAVE read the whole thing, apparently a little more carefully than you.

Paragraph b establishes a requirement for training, and this training is required annually.
Paragraph c merely says that the RECURRENT training can either happen in the month before it is due, the month it is due, or the month after it is due, without changing the next year's due month. ie, if you get your initial training in December, you can accomplish your RECURRENT training in November, December, or January, and it is considered to have happened in December. This makes it so there is no penalty for having done it a month early, and no advantage to doing it a month late. Part 121, 125, and 135 have identical provisions for recurrent training requirements. No where does it say that you can serve as a SIC without EVER having been trained. If you are unable to see that by reading the words try this:

Think about the absurdity of a regulation that allows you exercise certain priveliges now, and get the requred initial training later. The Regulations might as well say that someone can exercise the priveliges of a private pilot now, as long as they get a PPL within 6 months, or hey, go fly a twin today, as long as you get a Multiengine rating next month. Do you really believe that the FAA intends to allow you to serve as a reqired SIC of a transport category aircraft with no training at all (training to happen later)????? Sounds pretty silly, doesn't it?

Regarding the Ops Specs:

Operations Specifications are standard, numbered rules for operations. A specific company's operaing Manual includes a certain set of these standard specifications. The company must be approved for each specification included in their manual. The wording for each specification is the same for each operator who has that particular ops spec. The specific numbers, like RVR, may vary from operator to operator. Ops specs are not just dreamed up by the Dir. Ops. and the POI over a couple of beers to include insurance requirements. There has to be a real reason for requiring a SIC in a single pilot airplane.

An example of when a SIC is required by an Ops Spec. is Operations Specification A046, Single Engine IFR (SEIFR) Passenger carrying Operations Under CFR Part 135. This Ops Spec requires an SIC
if the plane doesn't have an operating Autopilot.

Operations Specifications C079, IFR Takeoff Minimums in Weather Below Category I- 14 CFR Part 135 Airplane Operations, includes a requirement for a SIC also, I believe. I don't have the text of this Ops Spec, so I can't confirm that. I do have a list of the existing Ops Specs, and there is no "Operations Specifications AXXX, SIC Required to Meet Insurance Requirements" THe bottom line is that the FAA is not in the insurance industry, and they will not, nor should they, write the regulations to accomodate the insurance companies.

>>>>Ops specs hold the same weight as a regulation.

Yes, this is true, as far as it goes, but be careful. A company's Op's Specs are published as a section in it's General Operating Manual. The GOM also lists non-regulatory company policy. People sometimes get the idea that EVERYTHING in the GOM has the full weight of the regulations. This is not true. For example, my GOM requires me to report for duty 1 hour before our scheduled departure time. I am not in danger of getting a violation from the FAA if I show up 5 minutes late, I am, however, subject to enforcement if I don't abide by the ops specs.

>>>>......Even if its a part 91 operation.

No, wrong again. If you're talking about a Part 91 operator having to follow ops specs, that's just stupid, Part 91 operators don't have ops specs. If you talking about a certificated carrier or operator (121 or 135) operating a specific flight under Part 91, you're still wrong. The requirement to abide by the Ops Specs, and the requirement to abide by Part 121 or 135 is specified in Part 119 When a carrier or operator coducts a non-revenue operation under Part 91, the operator is not required to abide by the requirements of Part 121 (or Part 135), or the ops specs. All carriers do this at some time or another, for various reasons: Positioning flights when Wx is below 121 minima (including those in the Ops Specs), positioning flights which would exceed the crew flight time limits, Mx ferry flights, Mx test flights, etc. These are all examples of Part 91 operations which may be conducted by a carrier or operator, and they are not subject to the Ops Specs. This is precisely WHY an operation is declared to be Part 91, to get relief from the more restrictive regulations. If not, there would never be any point in declaring an operation to be Part 91.


>>>Logging IMC as SIC and not actually flying the airplane isn't legal according to an inspector at the San Antonio FSDO.


Ummm, so what??? This just illustrates how little you know about the way things work. What some individual inspector says about how a regulation is interpreted has absolutely no official standing. Inspectors do NOT interpret regulations. Only the FAA's office of the Chief Counsel may issue legal interpretations. The reality is that often inspectors are poorly informed about how a regulation is interpreted. Unofficial interpretations may be completely opposite at adjacent FSDOs, or even according to individual inspectors within the same FSDO. For every inspector you can name that says you can't log IMC when not the PF, I can probably find the same number who say you can. So what? Their opinions have no official standing. It is worth noting however that an inspector's own interpretation, right or wrong, unofficial though it may be, may be what he bases starting an enforcement action against you. However, the opposite is NOT true, you CANNOT defend yourself againd an enforcement because an inspector told you something was legal, even if you have it in writing. The FAA attorney prosecuting your case will just tell you "D@mn, you were stupid for believing an inspector could issue a binding interpretation of the regulations"

Bottom line on this is that an inspector's word on how a reg is interpreted is worthless unless he has a statement from the Chief Counsel that backs it up.

>>>>By the way, CFI's aren't SIC so they really don't apply to this conversation do they?

I agree, I don't think I mentioned CFIs


>>>>>>........my dick is waaaayyyy longer then
yours!


EEEEWWWWWWW!!!!! she's a hermaphrodite. That's disgusting!!!!!

 

[Bluto]

First, let's try to keep it clean here. There is no reason for foul language on a board like this.
Secondly, I have seen a number of students get confused by reading certain parts of a regulation without carefully reading what precedes it. This led one student to take a friend along on a commercial "solo" cross-country. Granted, it was a stupid mistake, but this is what happens when you misread the regs.

 

[Saabslime]

Me thinks it's time for you to raise your little white flag KSU.

 

[bigD]

I was looking at Airnet's web site, and they say that there's no minimum time requirement for pilot applicants, and that if you don't meet the Part 135 minimums when hired, they'll put you in a "High Performance Twin" as SIC until you're qualified to be PIC. So this begs the question - how are they doing this? I can't imagine that an insurance company would require a copilot for a piston twin, and I'm gathering from everyone here that you can't really log the time as SIC based on a company requirement alone. What's the deal?

 

[Saabslime]

AirNet offers a paid time-building option to pilots who do not yet qualify to fly as pilot in command in Part 135 operations. Under this arrangement, time-builders go through the same initial training program, but fly in the right seat with a captain-qualified pilot on one of AirNet’s piston twin routes until they build enough total and PIC time to take over the left seat responsibilities. Washka says pilots applying to the second-in-command program need about 900 total hours to be competitive for hiring.
“That would be excellent, because then it would take about three months to build enough time to become an AirNet captain and we think that’s optimal,” he says.

Inevitably, when AirNet’s SIC program is discussed, some pilots become confused about how to log the time. Washka recognizes the issue and says AirNet received so many questions on the logging of flight time “that we actually went back and sat down with the FAA in Washington to get interpretations and make sure we’re doing everything right.

“In a nutshell, what they said was not only can pilots log time in the right seat of our aircraft, but they can log it as SIC time because we require an SIC to be there,” he explains. “It used to be that we had them logging only their PIC time and the other time was just added to total time. Well, the FAA came back and said, ‘Look, even though the aircraft does not require a second crew member; because of the rules you operate under and your operations specs, you can assign a pilot to a plane and they can log their time as SIC time.’

“When a time builder is on board, as long as he’s trained and checked in the plane, he can log the time he’s actually flying the plane as PIC. If he’s not flying the plane, but acting as a crew member, he can log it as SIC time,” Washka states. “It’s totally legal and it’s important to understand. There’s no gray area in the logging of flight time as far as AirNet and the FAA are concerned.”

Washka also emphasizes that when AirNet hires a low-time pilot, he or she is immediately added to the company’s full-time pilot seniority list upon successfully completing initial training.

“It used to be they had to build up enough time to become a captain before they moved up to the full-time seniority list, so this change is a great perq for a pilot,” he says. “Their seniority is only determined by the day they pass their initial checkride, so if they hustle and do a good job, it can really pay off later when they’re higher on the list.”

— Ian Tocher



...............This is from an article on their website

 

[bigD]

So is this specific to Part 135, or include 91 ops as well? For example, a friend flies a doctor around in a Seneca to build time. If the doctor were to suddenly say, "I'd like to have a copilot flying too." - I can go and log SIC as an acting crewmember even if I'm not flying the plane? Somehow I doubt it...

 

[ksu_aviator]

I'm sorry to have to tell you this squared but you are still wrong. I worked for a fractional that had ops specs. Many of them do. I also flew as SIC in a Citation 501. I was not required to complete training prior to flying because the PIC was single pilot rated. The reason the FAR's don't require me to be trained prior to my flight is very simple. The PIC was capable of flying the aircraft without me and therefore able to fly the airplane safely wheter or not I was there. However, our ops specs required me to be there and because I was a required crew member, I logged SIC time. I got met the requirements within 30 days. If you read the reg, it says nothing about recurrency, you just assumed that. It really doesn't matter how emphatically you state your point you are still wrong.

 

[Cornelius]

The thing with the SIC programs some of these 135 operators have, you want to make sure the program is approved by the FAA.


I got right seat lear time during test flights at an executive jet charter company, I hope its legal. I think for the mx tests you don't need to go through the training program. Anybody know?

 

[A Squared]

>>>>>>I also flew as SIC in a Citation 501.


Ahhhh, KSU, now I understand why you're proposing such absurd interpretations of the regulations. You've logged a bunch of Jet SIC time that you're not legally entitled to log, and you're desperately searching for some way to justify it to yourself, no matter how ridiculous.
This is called denial, and I'm here to help you work through your denial. (Denial is a bad thing, don'cha know?)


News Flash, KSU, if you were sitting in the right seat of a Citation in Part 91 operations, with a PIC with a single pilot type rating in the left seat, you weren't an SIC, you were a passenger.
A PIC with a single pilot type certificate can legally make Part 91 flights without your presence.
He may, at his discretion, allow a passenger to play with the radios, or even the flight controls, but that doesn't make the passenger a required SIC.

>>>>The PIC was capable of flying the aircraft without me and therefore able to fly the airplane safely wheter (sic) or not I was there.

Yes!!! That's my point exactly!!! you weren't a required SIC, you were a passenger sitting in the right seat.

>>>>However, our ops specs required me to be there

Ops specs for a Part 91 operation ?? really??? OK, show me the paragraph in Part 91 which requires,
or even recognizes Ops Specs for Part 91 operators. Part 119 establishes the requirement for operations specifications for Part 121, 125, and 135 certificate holders. The requirement for operations specifications for Part 129 carriers is established within Part 129. Nowhere in these parts or any other are Operations Specifications mentioned for Part 91 operations. If your company had something they called "Ops specs" they weren't ops specs at all, they were merely company policies with a misleading name. Company policies have no official bearing with the FAA.

Now, I understand that some fractionals have a Part 135 certificate, and occasionally conduct operations under Part 135. If this is case, the company would have genuine ops specs, and for Part 135 operations, the ops specs would have to be complied with. When operating under Part 91, however, the Part 135 ops specs are completely meaningless.
I assume that we are not discussing a fractional with a Part 135 certificate as you have made no mention of a Part 135 certificate. Besides, if you were serving as an SIC required under Part 135, without first accomplishing the required training, (training to be done next month)it would be a gross violation of Part 135 training requirements.

I'm astonished at the the convoluted logic you use. To wit: "I can log the time because I was a required crewmwmber, but I wasn't required to accomplish the required training because I wasn't a required crewmember."
Hmmm, interesting, are you perhaps schitzophrenic??????

Let me ask you a question. Do you think it is really wise to admit on an open forun that you worked for some shady operator who stuck you in the right seat of a jet with no training, and told you it was OK, because you'd get the training later? Does that seem professional to you? I'm sure there aren't any potential violations, because, as you've pointed out yourself, the pilot was legal to make the flights by himself, and you were just a passenger. Personally, though I wouldn't want to be associated with this kind of operation.


>>>>>>If you read the reg, it says nothing about recurrency, you just assumed that.

No, 61.55 (b) Specifies the training that is required to serve as a required SIC, and further specifies that it must have been done in the previous 12 months. That means that if you serve for more than a year, you must have recurrent training. The training is not a one time thing. It doesn't use the word "recurrent" but you can't possibly be in compliance with 61.55 (b) for more than 12 months (13 months, actually, with the provisions in 61.55(c)) without accomplishing the training again, so it's recurrent. Notice that 61.55(c) refers to the "month it is due". The due month is normally associated with recurrent training, not initial training. Initial training is "due" before you start flying.

Part 135 contains similar, almost identical language.

135.301(a) If a crewmember who is required to take a test or flight check completes the test or flight check in the calendar month before or after the calendar month in which it is required, that crewmember is considered to have completed the test or check in the month it is required.

So you gonna tell me that means it's legal for a 135 operator to start useing a pilot in 135 operations without any initial checkride, just as long as the pilot is given a checkride next month????

Part 121 has the same wording regarding proficiency checks. You think that means it's legal for an airline to start using an FO (or a captain for that matter) without an initial proficiency check, just so long as the PC is completed next month??

No, of course not. When the regulations are talking about "month before" and "month after" they are talking about recurrent training and checks, whether it's 135, 121, 125 or 61.55(c)

Of course, none of this probably penetrates your curtain of denial. I'll make one more appeal to your common sense, though it's probably a futile gesture. You're obviously so desperate to keep your jet passenger time in your logbook that any vestige of common sense is long gone.

OK, indulge me, take a moment to answer the following quiz, all answers are yes or no:


1) Would it make sense to allow a person without any pilot certificate or training to act as PIC of an airplane carrying passengers now, provided he acquired a Pilot's licence next month?

2) Would it make sense to allow a pilot without 3 takeoffs and landings in the last 90 days to act as PIC while carrying passengers now, as long as he perfomed the 3 takeoffs and landings next month?

3) Would it make sense to allow a person with only a single engine rating to act as PIC of a multi-engine plane carrying passengers now, as long as he got multi engine training and a rating next month?

4) Would it make sense to allow a person to act as PIC of a complex aircraft now, as long as he got the complex training and endorsement next month?

5) Would it make sense to allow a pilot to act as PIC of an MD-11 now, as long as he got a MD-11 type rating next month?

6) Would it make sense to allow a pilot to begin flying as a required Part 121 pilot now, as long as he accomplished his initial indoc, systems training, flight training, and initial proficiency check next month?

7) Would you allow your mailman to perform a vasectomy (or is it a hysterectomy?) on you with his pocketknife today, as long as he went to medical school next month?

8) Are you really stupid enough to answer Yes to questions 1-7?

OK, I'm gonna assume that your answers to 1-8 are "No" OK, put on your thinking cap, next question is a tough one, and it's for all the marbles:

9) Would it make sense to allow a pilot to serve as a required SIC now, with no training, as long as he got the training required by 61.55(b) next month?

Tell me this; how can you answer "no" to qestions 1-8, yet answer "yes" to question 9?

Is any of this getting through to you, or am I just wasting my time and Mark's bandwidth?

regards