Question about PIC time for 119.71

[Hotstarter]

I have spent the last 6 years flying a 747-400. Some of that time is logged from the left seat, as the Captain is asleep or otherwise away from the controls, and myself and a designated SIC are flying. I am now being considered for a FAR 135 job as D.O. I understand that I cannot count that PIC time as captain time, but could it be considered PIC time for purposes of fulfilling 119.71 to be considered as a D.O.? I have previous experience as a Chief Pilot under 135, but that was more than 6 years prior. For reference, 119.71 is copied below...

§ 119.71

Management personnel: Qualifications for operations conducted under part 135 of this chapter .

(a) To serve as Director of Operations under § 119.69(a) for a certificate holder conducting any operations for which the pilot in command is required to hold an airline transport pilot certificate a person must hold an airline transport pilot certificate and either:
(1) Have at least 3 years supervisory or managerial experience within the last 6 years in a position that exercised operational control over any operations conducted under part 121 or part 135 of this chapter ; or
(2) In the case of a person becoming Director of Operations—
(i) For the first time ever, have at least 3 years experience, within the past 6 years, as pilot in command of an aircraft operated under part 121 or part 135 of this chapter .
(ii) In the case of a person with previous experience as a Director of Operations, have at least 3 years experience, as pilot in command of an aircraft operated under part 121 or part 135 of this chapter .
(b) To serve as Director of Operations under § 119.69(a) for a certificate holder that only conducts operations for which the pilot in command is required to hold a commercial pilot certificate, a person must hold at least a commercial pilot certificate. If an instrument rating is required for any pilot in command for that certificate holder, the Director of Operations must also hold an instrument rating. In addition, the Director of Operations must either—
(1) Have at least 3 years supervisory or managerial experience within the last 6 years in a position that exercised operational control over any operations conducted under part 121 or part 135 of this chapter ; or
(2) In the case of a person becoming Director of Operations—
(i) For the first time ever, have at least 3 years experience, within the past 6 years, as pilot in command of an aircraft operated under part 121 or part 135 of this chapter .
(ii) In the case of a person with previous experience as a Director of Operations, have at least 3 years experience as pilot in command of an aircraft operated under part 121 or part 135 of this chapter .
(c) To serve as Chief Pilot under § 119.69(a) for a certificate holder conducting any operation for which the pilot in command is required to hold an airline transport pilot certificate a person must hold an airline transport pilot certificate with appropriate ratings and be qualified to serve as pilot in command in at least one aircraft used in the certificate holder's operation and:
(1) In the case of a person becoming a Chief Pilot for the first time ever, have at least 3 years experience, within the past 6 years, as pilot in command of an aircraft operated under part 121 or part 135 of this chapter .
(2) In the case of a person with previous experience as a Chief Pilot, have at least 3 years experience as pilot in command of an aircraft operated under part 121 or part 135 of this chapter .
(d) To serve as Chief Pilot under § 119.69(a) for a certificate holder that only conducts operations for which the pilot in command is required to hold a commercial pilot certificate, a person must hold at least a commercial pilot certificate. If an instrument rating is required for any pilot in command for that certificate holder, the Chief Pilot must also hold an instrument rating. The Chief Pilot must be qualified to serve as pilot in command in at least one aircraft used in the certificate holder's operation. In addition, the Chief Pilot must:
(1) In the case of a person becoming a Chief Pilot for the first time ever, have at least 3 years experience, within the past 6 years, as pilot in command of an aircraft operated under part 121 or part 135 of this chapter .
(2) In the case of a person with previous experience as a Chief Pilot, have at least 3 years experience as pilot in command of an aircraft operated under part 121 or part 135 of this chapter .
(e) To serve as Director of Maintenance under § 119.69(a) a person must hold a mechanic certificate with airframe and powerplant ratings and either:
(1) Have 3 years of experience within the past 6 years maintaining aircraft as a certificated mechanic, including, at the time of appointment as Director of Maintenance, experience in maintaining the same category and class of aircraft as the certificate holder uses; or
(2) Have 3 years of experience within the past 6 years repairing aircraft in a certificated airframe repair station, including 1 year in the capacity of approving aircraft for return to service.
(f) A certificate holder may request a deviation to employ a person who does not meet the appropriate airmen experience requirements, managerial experience requirements, or supervisory experience requirements of this section if the Manager of the Air Transportation Division, AFS-200, or the Manager of the Aircraft Maintenance Division, AFS-300, as appropriate, find that the person has comparable experience, and can effectively perform the functions associated with the position in accordance with the requirements of this chapter and the procedures outlined in the certificate holder's manual. The Administrator may, at any time, terminate any grant of deviation authority issued under this paragraph.

 

[pilotyip]

I think you pass the scratch and sniff test, you are typed in the airplane, you act a CA. It will depend upon the FAA who oversees the Certificate. We got a DO a while back with no civilian PIC time but he Fed's waived it and used his Military PIC time to meet the requirement. As a former mil pilot, I knew nothing of 121 or 135 when I got out, so this guy came in with almost no FAR knowledge.

 

[jafo20]

Agreed. You'll be okay.

 

[ksu_aviator]

Under 119.71, you would not qualify. However, waivers can be granted.

You can act as PIC, but if you don't have the designation of PIC on the flight, even if the captain leaves his station, you are not the PIC. But, the FAA will grant waivers. You'll just have to talk with the POI and see what he says.

PS - Check out 8900.1 VOLUME 3 GENERAL TECHNICAL ADMINISTRATION
CHAPTER 18 OPERATIONS SPECIFICATIONS Section 3...for a little more information.

 

[TXDA2000]

You can log PIC. Typed, sole manipulator, but you aren't "operationally responsible"

One of those gray area situations where two can log PIC, but you're never the captain till you sign.

Agree, depends on your FAA experience on that day.

 

[Starscream]

You can log PIC. Typed, sole manipulator, but you aren't "operationally responsible"

You know, it's funny, FAR 61 says a Private or Commercial (note -- Airline Transport Pilot omitted) may log PIC when sole manipulator yadayadayada.

If you're typed but also an ATP you can't log PIC unless you're the acting PIC. We all know hiring departs only recognize PIC time that is logged while serving as the FAR 1 definition of PIC (ultimately responsible/final authority) but that's a different matter.