Quality time?

[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?