Seat-dependent training/checking 135

[ClassG]

OK. I realize this will be required for a transport catagory aircraft, but who has experience with a small (Pilatus PC12) normal category, turbine-powered aircraft when utilizing a pilot crewmember as SIC?

The idea is to have both PIC/SIC (left/right seat) qualification as well as just SIC (right seat only) qualified crewmembers available for 135 flight. Who has been over this with the FAA? Will it require checking and testing both seats or not?

I'm guessing there must be a cargo operation or two out there using some SIC's in Caravans or something who can answer this question.

ClassG

 

[350DRIVER]

Who has been over this with the FAA? Will it require checking and testing both seats or not?

It would have to be written into the company's ops specs to require the sic to be onboard since the aircraft is type certificated for single pilot operations. Obviously, if the sic is required by the ops specs then he must go through a training course specified in the ops specs and a checkride. Speak to your POI, DO, and CP, they should be able to add and amend what is already in place. Many 135 departments use a gear slinger and radio player in the right seat in smaller aircraft. Some pax feel more "safe" or "reassured" with two warm bodies up front versus just one.

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[transpac]

It would have to be written into the company's ops specs to require the sic to be onboard since the aircraft is type certificated for single pilot operations. Obviously, if the sic is required by the ops specs then he must go through a training course specified in the ops specs and a checkride.

This is the reverse of the actual requirements: FAR 135.101 requires a SIC for passenger flights under IFR. The operator may or may not hold an Op Spec that permits an autopilot to be substituted for the SIC. The key word here is "permits". Nothing in a standard Op Spec requires an operator to use an autopilot in lieu of a SIC, and the operator can continue to comply with 135.101 by assigning a qualified SIC to a flight.

It's interesting that the title of 135.101 mentions IFR conditions but the text of the regulation merely mentions IFR.

 

[350DRIVER]

This is the reverse of the actual requirements: FAR 135.101 requires a SIC for passenger flights under IFR. The operator may or may not hold an Op Spec that permits an autopilot to be substituted for the SIC. The key word here is "permits". Nothing in a standard Op Spec requires an operator to use an autopilot in lieu of a SIC, and the operator can continue to comply with 135.101 by assigning a qualified SIC to a flight.

It's interesting that the title of 135.101 mentions IFR conditions but the text of the regulation merely mentions IFR.

That is understandable but I was under the impression that the company in question did hold the autopilot authorization which would allow the flight to be conducted under single pilot operations. I am pretty sure since the aircraft is type certificated for single pilot ops that a second in command would not be able to "legally" log the flight time unless they were a required crew member which would be dictated by the ops specs. The key word in your response was "qualified" SIC to a flight, meaning he/she would have to be trained and checked out as a company pilot. AirNet and others have this done in a way which it is written into the ops specs and the sic's are put through all required training resulting in a "qualified" sic that may be assigned to flights. A "qualified" pilot outside of the company who holds the appropriate and required certificates and ratings cannot just jump in the right seat and log and act as sic of a plane operating under part 135 where the pilot flying is qualified to conduct the flight single pilot.

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[transpac]

That is understandable but I was under the impression that the company in question did hold the autopilot authorization which would allow the flight to be conducted under single pilot operations.

If a SIC is assigned, it makes no difference whether or not the operator holds an autopilot authorization. It's much the same concept as holding a MEL but having no inoperative equipment during a particular flight. In other words, the authorization is permissive; it does not take anything away.

It's a given that the SIC must be trained and checked in accordance with the operator's SIC training program.

 

[cvsfly]

It would have to be written into the company's ops specs to require the sic to be onboard since the aircraft is type certificated for single pilot operations. Obviously, if the sic is required by the ops specs then he must go through a training course specified in the ops specs and a checkride. Speak to your POI, DO, and CP, they should be able to add and amend what is already in place. Many 135 departments use a gear slinger and radio player in the right seat in smaller aircraft. Some pax feel more "safe" or "reassured" with two warm bodies up front versus just one.

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I've seen the arguements before. Specifically which Ops Spec is this written into? Axxx ? Our company started from a single pilot-in-command with a BE200 with SICs. We had A015 (autopiliot-in-lieu of SIC) and our approved PIC and SIC were listed in A007 (I believe - don't have a copy of it now). Now we are a Basic operator utilizing both PIC and SIC positions, it is listed in our training program and our POI has checked us and given his blessing on our operation for many years now. Our Ops Spec have no reference to any PIC or SIC anymore (just the management positions). Are we missing something? Are we not asking the right questions of our POI. Our checks tend to be fairly relaxed nowadays and occasionally we do manaeuvers from both seat positions to satisfy the PIC/SIC roles (293(a)1 & 8, 299 and 6 mo. 297 done in the aircraft with our POI). Flight Safety (our annual 293(a) 2-7, 297 done in level D sim) is always a little vague on the subject.

 

[350DRIVER]

cvs,

It was written into ours as is with other 135 operators. . I think your POI would probably be able to answer these questions more accurately and be able to specifically state how it would be written. I tend to disagree with transpac, it is written somewhere and "qualified" would mean being "company trained" and a "company pilot" not just someone holding the required certificates and ratings. It would make very little if any sense to buy into the notion that if two pilots are required per the ops specs (both pic/sic) then the flight can still be flown single pilot in equipment that is type certificated for single pilot operations given that the pic is part 135 single pilot qualified, current, and meets applicable regulations. The ops specs allows the company the freedom to either use the sic or be able to do operations under single pilot. I may be mistaken but I thought the original question was with regards to getting a sic to be a required crew member for XYZ operation. Once again, you can't just throw someone in that right seat under 135 and call them "qualified" because you may like him or think he is cute unless he has met the part 135 applicable regulations and has attended and passed company specific training.

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[transpac]

Once again, you can't just throw someone in that right seat under 135 and call them "qualified" because you may like him or think he is cute unless he has met the part 135 applicable regulations and has attended and passed company specific training.

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Don't believe that anyone has stated or implied that "qualified" means anything other than trained and checked in accordance with the relevant operator's FAA approved training program. If I've left this unclear, my apologies.

Once again, it's not Op Specs that requires two pilots, it's FAR 135.101. I get the impression that some believe that holding an autopilot authorization takes away a company's ability to assign a SIC to a flight (and for the SIC to log the flight time). This is incorrect. A qualified SIC enhances safety in IFR operations far more than an autopilot and operators are encouraged to train, check, and use SICs whenever feasable. However, to require a SIC in an airplane with limited seating would greatly limit its economic viability. Hence, the compromise of permitting an autopilot in lieu of a SIC in small airplanes, at the option of the operator.

 

[350DRIVER]

Once again, it's not Op Specs that requires two pilots, it's FAR 135.101.

Correct, but the ops specs should also have documentation and sections in it regarding what the company can and cannot do.

A qualified SIC enhances safety in IFR operations far more than an autopilot and operators are encouraged to train, check, and use SICs whenever feasable.

This is not overly true in operations where the captain is qualified for single pilot part 135 operations. If anything I have seen guys in the right seat of a King Air and other airplanes that are type certificated for single pilot operations do more damage than anything else. You surely do not need a gear slinger in some types of equipment and it can throw the flows off of the guy in the left seat who was trained, tested, and is "qualified" to be flying the aircraft as single pilot, simple as that.

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[English]

This is not overly true in operations where the captain is qualified for single pilot part 135 operations. If anything I have seen guys in the right seat of a King Air and other airplanes that are type certificated for single pilot operations do more damage than anything else. You surely do not need a gear slinger in some types of equipment and it can throw the flows off of the guy in the left seat who was trained, tested, and is "qualified" to be flying the aircraft as single pilot, simple as that.

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For once I agree with 350.

When the tequila wears off, I'll probably disagree again.

 

[cvsfly]

It was written into ours as is with other 135 operators. ----- Again which Ops Spec? A007? Which one?. There is a format to the Ops Specs. Some allow some creative writing, some do not. And we are not talking about your GOM Chap A-S correct? ------I think your POI would probably be able to answer these questions more accurately and be able to specifically state how it would be written. ----- Problem is he is a little fuzzy on the subject as well. -----I tend to disagree with transpac, it is written somewhere and "qualified" would mean being "company trained" and a "company pilot" not just someone holding the required certificates and ratings. The ops specs allows the company the freedom to either use the sic or be able to do operations under single pilot. I may be mistaken but I thought the original question was with regards to getting a sic to be a required crew member for XYZ operation. Once again, you can't just throw someone in that right seat under 135 and call them "qualified" because you may like him or think he is cute unless he has met the part 135 applicable regulations and has attended and passed company specific training. ----- No question that any official crew member has to be trained and checked according to the Operator's approved Training Program PIC or SIC (except single PIC operator). I do not think this interpretation is true that since the aircraft doesn't require an SIC, the Operator can't choose to use qualified SICs whether or not they have Auto-pilot in-lieu of or not. Of course there are other scenarios where a SIC would be required as well. Does a Citation SIC do any more of a job than a trained and qualified SIC in a King Air? The real guidance here needs to be in the 8400 Inspectors Handbook, but I haven't found it yet.

 

[350DRIVER]

cvsfly,

If my memory serves me correct it was noted under the company Procedures and Policy section of the ops specs where it made mention to the SIC. It was also touched upon under the general section of the ops specs which I believe was A015. It was also specifically written that only a company qualified SIC, authorized representative of the Administration or NTSB, or a company check airman could occupy the right seat. I will make a call to the FAA and speak to one of the inspectors that I did a captain ride with a few years ago and he should be able to answer this.

Does a Citation SIC do any more of a job than a trained and qualified SIC in a King Air? The real guidance here needs to be in the 8400 Inspectors Handbook, but I haven't found it yet.

It would depend on which Citations you are talking about, the ones that do (by type certificate) require a SIC would be a more standardized due to the training and the set up. In reality it is a "two crew" environment. It is a little harder to get this when operating planes where the captain is trained and qualified for single pilot operations and throwing a SIC onboard. You can easily and safely fly the CJ1/2/3 single pilot where as trying to do that on the X may be a little more complicated.

avbug, where are you?

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[transpac]

I tend to disagree with transpac, it is written somewhere and "qualified" would mean being "company trained" and a "company pilot" not just someone holding the required certificates and ratings. The ops specs allows the company the freedom to either use the sic or be able to do operations under single pilot.

Perhaps you could point out the post wherein transpac posted the statement you disagree with.

 

[transpac]

Getting back to the seat dependent training question... If there are no significant differences in instrumentation and equipment between the respective seats, additional seat dependent training and checking should be minimal. On airplanes with equipment that is accessable to only one seat, such as a nose steering tiller or emergency gear extension mechanism, both pilots will probably have to demonstrate competence in operating the equipment from the appropriate seat. Non flying pilot duties usually can be demonstrated from either seat. In any event, the final say is up to the POI. If there are no equipment/instrumentation differences between the seats, many POI's will consider one approach and landing from each seat adequate to satisfy the seat dependent requirements.

 

[xdashdriver]

It would have to be written into the company's ops specs to require the sic to be onboard since the aircraft is type certificated for single pilot operations. Obviously, if the sic is required by the ops specs then he must go through a training course specified in the ops specs and a checkride. Speak to your POI, DO, and CP, they should be able to add and amend what is already in place. Many 135 departments use a gear slinger and radio player in the right seat in smaller aircraft. Some pax feel more "safe" or "reassured" with two warm bodies up front versus just one.

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Actually, the reverse is true. In order to carry passengers in IFR operations WITHOUT an SIC, then the autopilot authorization must be included in the OpSpecs. FAA Regional Counsel has interpreted (read it yesterday, don't have a link, sorry) that the autopilot is simply an authorization giving the company an option to use either the autopilot OR an SIC. They further interpret that should the company choose to use an SIC in lieu of the autopilot, that the SIC (who must be fully qualified as an SIC for that operator in that aircraft in order to act as such) may log the time. Additionally (still from the letter of interpretation), under 61.51, if the SIC is rated in the aircraft (i.e. in a Kingair, has a multi-engine rating) and it's "his" leg, he can log PIC as sole manipulator. The PIC also gets to log PIC in this case since he is the acting PIC and is the only qualified pilot to ACT as PIC on board the aircraft. I'll see if I can dig up the actual interpretation.

Ray

 

[xdashdriver]

Getting back to the seat dependent training question... If there are no significant differences in instrumentation and equipment between the respective seats, additional seat dependent training and checking should be minimal. On airplanes with equipment that is accessable to only one seat, such as a nose steering tiller or emergency gear extension mechanism, both pilots will probably have to demonstrate competence in operating the equipment from the appropriate seat. Non flying pilot duties usually can be demonstrated from either seat. In any event, the final say is up to the POI. If there are no equipment/instrumentation differences between the seats, many POI's will consider one approach and landing from each seat adequate to satisfy the seat dependent requirements.

I was qualified PIC/SIC on a Kingair B100. The seat dependent training consisted of the POI asking me "do you want SIC privileges too?" at the completion of my 135 PIC ride. He then checked the appropriate box on the form and I was qualified. There was no specific seat-dependent training tasks in our Training Program at all.

 

[cvsfly]

Perhaps you could point out the post wherein transpac posted the statement you disagree with.

I don't disagree. I did a poor job of quoting and pasting from 350DRIVER. I'm trying to figure out what specific "custom written" Ops Spec 350driver is referring to that authorizes his company to use SICs in single-pilot aircraft. I haven't seen anything that requires that language. Whether or not you have A015 authorization, I believe you can still use SICs in single-pilot aircraft as long as their training and checking is documented as any other crewmember. What happens when that auto-pilot becomes inop or you have lower than standard take-off minimums or want to be an "eligible operator" coming from 91K/135 rewrite? We don't use SICs "off the street". We have standard training together and we are CRM coordinated as any turbo-jet crew.

 

[transpac]

cvsfly:


Thanks!

Glad to know we're on the same page. I thought we were essentially saying the same thing. But, I'm aware that there's always room for improvement in my writing skills.

 

[350DRIVER]

Actually, the reverse is true. In order to carry passengers in IFR operations WITHOUT an SIC, then the autopilot authorization must be included in the OpSpecs. FAA Regional Counsel has interpreted (read it yesterday, don't have a link, sorry) that the autopilot is simply an authorization giving the company an option to use either the autopilot OR an SIC. They further interpret that should the company choose to use an SIC in lieu of the autopilot, that the SIC (who must be fully qualified as an SIC for that operator in that aircraft in order to act as such) may log the time. Additionally (still from the letter of interpretation), under 61.51, if the SIC is rated in the aircraft (i.e. in a Kingair, has a multi-engine rating) and it's "his" leg, he can log PIC as sole manipulator. The PIC also gets to log PIC in this case since he is the acting PIC and is the only qualified pilot to ACT as PIC on board the aircraft. I'll see if I can dig up the actual interpretation.

Ray

The autopilot authorization must also be included in the ops specs, that is correct. I have also read the letter of interpretation (if it is the same one) that you are referring to. You hit the nail on the head with regards to what a "qualified" SIC is. If they are "company qualified" then obviously some "approved" training course would have had to be completed Sat.

Getting back to the seat dependent training question... If there are no significant differences in instrumentation and equipment between the respective seats, additional seat dependent training and checking should be minimal. On airplanes with equipment that is accessable to only one seat, such as a nose steering tiller or emergency gear extension mechanism, both pilots will probably have to demonstrate competence in operating the equipment from the appropriate seat. Non flying pilot duties usually can be demonstrated from either seat. In any event, the final say is up to the POI. If there are no equipment/instrumentation differences between the seats, many POI's will consider one approach and landing from each seat adequate to satisfy the seat dependent requirements.

Seat dependent training and checking should be "minimal"?. One approach and one landing from each seat would be adequate to satisfy the seat dependent requirements?. I may be missing something here but neither would satisfy the applicable part 135 regulations to get one current as either the PIC or SIC. Can you specify where you are finding the information at?. A breif review of part 135 didn't bring any "answers" to this....

cvs,

For kicks, what was or is your company's BE200 SIC training that is required to get one "SIC qualified" on that equipment?.

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[Full of Foehn]

Legal link?

Actually, the reverse is true. In order to carry passengers in IFR operations WITHOUT an SIC, then the autopilot authorization must be included in the OpSpecs. FAA Regional Counsel has interpreted (read it yesterday, don't have a link, sorry)...I'll see if I can dig up the actual interpretation.

Here is a link to an FAA legal interpretation of this issue which supports raysalmon's information.