Quality time?

[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

 

[avbug]

KSU,

A Squared in 100% correct. I was going to reply to your post, but he covered it as thoroughly as it could possibly be covered. Even fractional operators, when operating under Part 91, cannot require a SIC for the purposes of logging time. Only if the aircraft requires a SIC by the type certification, or the FAA requires a SIC (safety pilot time is legitimate SIC time for the purposes of logging, as is time spent as SIC when required by OpSpecs), can the time be legally logged.

The fractional operator may require a SIC, but this doesn't make you a required crewmember in a single pilot aircraft. It doesn't entitle you to log the time as pilot, period. If the Fractional operator holds a 135 certificate with Operations Specifications which requires a SIC, you may log the time as SIC when properly authorized, only on flights conducted under FAR 135. Any flights conducted under FAR 91 in this case, as SIC, may not be logged as SIC. In cases where you are acting as SIC under the certificate and OpSpecs, you may only do so if current, with a current FAA 8410-3, and all your other currency requirements are met applicable to your position in the aircraft.

 

[A Squared]

Avbug,

Thanks for the backup. The sad thing is, every one of us on this board could line up, one by one, and each explain to KSU that there is no such thing as "Part 91 Ops Specs" or "retroactive training", and that his/her rides in the Citation are not legally loggable, but it wouldn't make any difference. He/she is so attatched to that "jet time" that no rationalization is too absurd.

The only reason I've kept on with this is to show how ridiculous this is to anyone else who might have been tempted to believe KSU...that, and I'm avoiding caulking my shower enclosure.

Regards

 

[puddlejumper]

Litmus Test for the SIC logger

Let's just say that your regular part 91 single pilot authorized captain calls in sick. Another pilot, who is current in the C501 is assigned to cover a part 91 trip. Unlike your regular captain's certificate, this individual's states under the limitations: "Second in Command Required" Have you met all requirements of 61.55? Are you legal to be the required crewmember for this flight?

I flew for a year in a King Air 300 as co-pilot with a PIC with the SIC required limitation. I'm not sure of the legalities, but as soon as we completed the 61.55 training for me, without passengers, I started logging SIC. Mind you, this was in a single-pilot airplane but with a pilot type rating limited captain.

Another point is that a single pilot authorization in a jet or >12,500 pound aircraft is simply that. An authorization or waiver. One doesn't have to operate under the privileges of a waiver or allowed exception, it is a tool an operator can use if they want. Autopilot usage in lieu of SIC is another situation that comes to mind. But that is a 135 issue and wouldn't apply to private general aviation part 91 operators who don't use op specs.

As far as your GOM specifying conditions like opspecs for 91 operations, if the FAA POI had approved/signed off on it, then I would treat them as regulatory, but if it's just a GOM to impress the chairholders or insurers of a corporate airplane, they don't pass the test and aren't considered official.

-PJ

 

[Joe Jet Pilot]

To KSU

I would suggest that you drop the subject. A Squared has given you 100% on the money information. I would suggest that you also consider making your logbook legal.

To once again help you in understanding this I will try to explain it again:

If the aircraft type certificate, Ops. Specs, or required by FAA regulations require an SIC, then and only then are you allowed to log SIC time. Now in order to log SIC time you must within the preceeding 12 months complete the provisions of 61.55.

I would suspect that the aircraft type certificate for the 501 says something to the effect that only one pilot is required with a SP endorsement. So since this was your case flying with a single pilot rated in a single pilot airplane, you don't have Ops. Specs since it is part 91, and I assume that you are not doing training under the hood, then you were a passenger, not a required crewmember. Therefore, you can't log the time as SIC. It is that simple.

I fly for a fractional. We hold a 135 certificate, but operate under 91. The only time the Ops. Specs come into play is if we are doing a 135 trip.

In response to what an inspector at a FSDO told you, well when you get all grown up, and have some time under your belt, you will see that the FSDO guys and gals are not GOD!

 

[FLYnMONKEYS]

What really matters is this.......If you and your 600 hours and that turbine time get an interview be ready for some tech questions on this airplane that you "legally" logged time in. Be prepared to be questioned on things such as the starting sequence, turbine theory, and limitations. You wouldn't be the first person who sat in the right seat talking and squawking who logged the time as PIC. Most interviewers want to know if the experience in your log book is yours.

 

[A Squared]

PJ,

>>>>>I flew for a year in a King Air 300 as co-pilot with a PIC with the SIC required limitation. I'm not sure of the legalities, but as soon as we completed the 61.55 training for me, without passengers, I started logging SIC. Mind you, this was in a single-pilot airplane but with a pilot type rating limited captain.

Sounds completely legal to me. You were a required crewmember for the airplane and operation, and you had met the requirements of 61.55 (b).; not the case with our friend from the cornfields.


>>>>As far as your GOM specifying conditions like opspecs for 91 operations, if the FAA POI had approved/signed off on it, then I would treat them as regulatory.


Maybe I'm missing something here, Why would a Part 91 operator have a POI, or a GOM, unless they were conducting some operation which required a waiver of certain provisions of Part 91(banner tow, perhaps?, I'm guessing here) Remember, we're just discussing a part 91 private airplane, there's no operating certificate involved, as far as KSU has indicated.

Are there some instances where a POI would be assigned to a non-certificated, Part 91 operator? I flew for a Part 91 operator for several years and we had nothing of the sort.

Joe Jet Pilot,

Thanks for the backup too.

>>>I would suspect that the aircraft type certificate for the 501 says something to the effect that only one pilot is required.

Yes, the 501 Type certificate says:

"Minimum Crew For all flights: One pilot plus equipment specified in the Airplane Flight Manual, or two pilots"

I suppose KSU could take a hammer and break the whiskey compass and claim he/she was then required because not all the equipment was functioning.


regards

 

[Joe Jet Pilot]

To A Squared

A Squared,

You wrote: "Are there some instances where a POI would be assigned to a non-certificated, Part 91 operator? I flew for a Part 91 operator for several years and we had nothing of the sort. "

In a sense they do, at least at my FSDO. They do have a person assigned as a Part 91 POI. From what I can tell this person really does not do much unless guidence is sought from the 91 operator. I remember when trying to get an MEL approved for my former flight department, I was directed to the Part 91 POI. Fancy title, I suppose. Of course this person does not do the same job that a 135 POI would do. Like I said probably just the go to person for questions from the part 91 community.

You also wrote: "I suppose KSU could take a hammer and break the whiskey compass and claim he/she was then required because not all the equipment was functioning."

I wonder if at 1300 hours one would know what a "whiskey compass" even is. Since logging of flight time 101 is not a required subject at KSU, perhaps "fancy names for flight instruments" is a required subject. Who knows?

 

[Joe Jet Pilot]

For Cornelius

Did you meet the requirements of 61.55? If you read the reg you will notice that you may serve as an SIC if you hold a Comm. or ATP with catagory and class ratings and not have to meet all of the requirements of 61.55 for the purpose of an aircraft flight test. See below:

(e) The holder of a commercial or airline transport pilot certificate with the appropriate category and class rating is not required to meet the requirements of paragraph (b)(2) of this section, provided the pilot:

(1) Is conducting a ferry flight, aircraft flight test, or evaluation flight of an aircraft's equipment; and

(2) Is not carrying any person or property on board the aircraft, other than necessary for conduct of the flight.


Paragraph (b)(2) is the requirement for the 3 takeoffs and landings. You still are required to meet all of the other requirements. If this training is not documented, then hate to say it, but you were not legal. If you have it in your logbook, it will sure look funny having say 3 hours of Lear time as an SIC with no documentation of meeting the requirements of 61.55 or documented training from a FAR 142 school.

 

[cvsfly]

Everyone will be looking at a rude awakening when it comes to insurance requirements. Our insurance on our BE-B200 was renewed in FEB. I've been flying it 91 and 135 for 2.5 yrs now. We had a maximum liability policy and the premimum went up 105% due to 9/11. Only 3 ins. companies (according to our agent) are writing the $100,000,000 liability policies on GA right now. In addition to dropping the war risk ( immediate following 9/11) they are also requiring us to fly 2 pilots on all flights. It was our company policy to do so before and got some consideration and discounts for doing so. But now we have no choice, although we are actively negotiating the policy requirements.
Regardless of what our insurance co. or our company/owner want, we can't log SIC based on what they want. Under 91 we alternate legs PF= PIC and PNF = another passenger. I am a CFI, but I think it cheesy to try to gain instrument time based on that and I would really have to document any portion of that as training for the "student" pilot. I've always been dubious of the interpretation that the safety pilot can log SIC time. I think it it a stretch of 61.55. We do fly 135 with a trained, qualified and checkedout SIC. He is listed in our Ops. Specs. By the literal interpretation of 61.51 (f), he can not log SIC because so far our autopilot has worked and our Ops Specs. do not have any other provision for requiring an SIC (I don't know of any operation that would for our aircraft) I do "log" it because I/he meet all the other requirements of 61.55 and 135 for being qualified and listed as SIC. (150 hrs SIC in last 2.5 yrs, 1st year SIC only in 135 ops in a 350-375 hr/yr operation) Be aware that once 135 qualified PIC, you are not necessarily qualified SIC. Your training and checking must include SIC competancy to alternate. As a matter of the logging, I don't sweat it if someone down the line says it doesn't meet 61.51 requirements because it is a fraction of my total time of 4700 hrs +/1800 twin/800 turbine/, etc.
The point is, it is experience that counts, be prepared to answer the questions in interviews and insurance surveys on how and why you got SIC time. Also be prepared to get different answers from different FSDOs. You would think they would all be standardized in the info they give and the requirements that they require. Insurance requirements are goinig up. Cost is going up. Know your personal liability when you occupy a pilot seat and you hold a license. Be clear on your designations, duties, responsibilities and transfer of control when you are PIC or "SIC".

 

[cvsfly]

I've never heard of Ops. Specs. for PT 91 until the NPRM for 91 K which addresses the fractionals. It is my understanding that the fractionals that do have Ops. Specs. are the ones who have elected to get 135 certified to be operationally flexible and standardized. Is this correct?