Sic Illegal

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350DRIVER

I wanted to get a few opinions regarding once again "SIC" time..
The 135 company I fly for requires "2" qualified 135 pilots on board meaning a PIC and SIC BUT our company ops specs DOES NOT REQUIRE a SIC on board- This is an "insurance" issue so all pilots who don't meet 135 PIC minimums are being given the required ground and flight training THEN a 135 SIC check ride (135.293) (FT106) which to me makes no sense since in my opinion you cannot legally log SIC time since there is no SIC required per our company ops specs and all King Airs are certified single pilot..... Fortunately I built up most all my flight time CFI ing and have only logged the part 91 legs as PIC time since I can "legally" do this in compliance with all the regs....

The question I have is not a matter of "how" to log SIC time since we are not allowed to log this but we have a few pilots who insist that having that "magic" FT106" SIC authorization allows them to do this in fact our senior pilots even say to log SIC time which I have no idea how they can come to this conclusion.?? The fact is that none of our airplanes are ever flown "single pilot" and they always have a part 135 qualified SIC on board even though the company ops specs does not require one so how is the best way that these pilots can log the flight time.?? Our chief pilot states that on the 135 legs since all the PIC's have their MEI and ATP that they endorse the SIC's logbook as dual given- I am not sure that this is correct but the insurance company allows this to count, and no where in the regs have anyone been able to shoot down this theory..- just curious if anyone has any opinions regarding this??

I have fought with our owner/chief pilot since for months he was upset at me for investing thousands of dollars in training me only to find out that I was not logging any SIC time at all and didn't understand this till I told him to contact the FSDO and what is even more bizzare is the explanation that the inspector gave hime saying that as long as he/she takes off and lands since he was "sole manipulator of the controls then he logs PIC time..- This made no sense to me since the people in the right seat are SIC qualified and NOT 135 PIC qualified so how could the inspector come up with this answer.??

I am getting ready to get my 350 type so it really doesn't effect me BUT it is a tad bothersome that the younger pilots are being given this info on how to log 135 time sitting in the right seat being 135 SIC qualified BUT the ops specs does not require that SIC to be there so how should they log that flight time?? Is it alright to log dual recieved as long as the PIC is an MEI/ATP??

any comments or opinions would be appreciated since everyone in our company has their own opinion and to me alot of those opinions are not correct BUT as most of the captains state how does the SIC build enough time to get the "magic" 1200 to upgrade to the left seat.??? I feel for some of these pilots since they are not CFI's and have no other way to build their flight time up BUT I think they may be making a mistake by logging time the way they do and was curious what you all thought since you have been in this business alot longer than I........


cheers and thanks for hopefully clearing this up....
 

328dude

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If it's not in the Ops Specs that your POI signs off on then that SIC letter dosen't mean squat. Insurance company's might require 2 people, fine put another guy in the other seat, but be carefull how you log it.

For your sake, I hope your not logging PIC in that BE-350 on the 91 legs. You can't legally... (no type rating)

In general, it has to be in your ops specs...
 

402driver

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SIC Time

If your Company's Operation Specifications have an approved SIC training program, and the pilot is qualified under 135.115 and 135.245, and is designated on the manifest as SIC, that person is a required crewmember and can log all time as SIC. Additionally, the SIC can log all time in which he/she is the sole manipulator of the controls as PIC under 61.51.(e)(1)(i).

Note that whenaever a carrier chooses to use a SIC, for whatever reason, including the request of a customer, and the SIC is qualified and current (these terms contemplate, among other things, the pilot's completion of the carrier's SIC training program), he/she is a required crewmember and may log the time accordingly.

So, the Operation Specifications are the determining factor on whether or not an SIC can log time on 135 flights. Of course, part 91 flights can be flown by the SIC and they can log it as PIC under 61.51.(e)(1)(i).

Aloha :cool:
 

328dude

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Good discription 402. I was to lazy to look it up. However, you can't log PIC in a airplane that requires a type rating if your not rated in it..

61.51 (E) Logging PIC Time
1. A Rec,Private, or Commercial pilot may log PIC time only for that flight time during which that person-
i.Is sole manipulator of the controls on an aircraft for which the pilot is RATED..
ii. Yada Yada Yada So on and so on.

Now, inless I'm reading this wrong, you can't log PIC in a aircraft that requires a type rating if you don't have the type.
Am I wrong on this?
 
3

350DRIVER

thx for your feedback- correct in the 300 and 350 it requires a type so only way they are having us log it is "dual received" since they are MEI's-don't think this is right though for some reason?

thx alot- lot of these guys are "old timers" and stuck in their ways even though its not right...
 

DoinTime

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Of course, part 91 flights can be flown by the SIC and they can log it as PIC under 61.51.(e)(1)(i).
61.51(e)(1)(i) states: is the sole maipulator of the controls of an aircraft for which the pilot is rated;

In this case the SIC is not rated in the equiptment because they have no type rateing. They can never log PIC.

Under 135 ops SIC time can only be logged under specific conditions if the ops specs only requires one pilot (i.e. flight in IMC, Cat II ops, aircraft requirements, ect...)

There has been some debate on how to log this time and the only thing reasonable is total time only. However, don't bring this total time with you to your United interview because they will show you the door if your single engine time plus your multi-engine time doesn't add up to your total time.
 

328dude

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If you do get a SIC checkride and get that yellow carbon copy of such a ride, keep it with you forever. Also get a copy of your Ops specs that states that the operation of your company and aircraft require two crewmembers. If you ever decide to go with a 121 operator, you will be asked about it. It makes it easier to explain to them. Better safe then sorry.

Also, had some guy interview the other day in which he had all this actual time flying in the right seat of a LearJet. I asked him at what point is he logging actual. He stated all the time he is under IFR. Not when he is the sole pilot at the controls, but all the time he is acting as SIC and not the one flying. Make sure those young guys aren't doing this.

The guy got sent home.
 

402driver

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More SIC stuff

61.51(e)(1)(i) states: is the sole maipulator of the controls of an aircraft for which the pilot is RATED; so if you are not rated, you can not log the time PIC.




Under 135 ops SIC time can only be logged under specific conditions if the ops specs only requires one pilot (i.e. flight in IMC, Cat II ops, aircraft requirements, ect...)
Key Word is Ops Specs. Again....If your Company's Operation Specifications have an approved SIC training program, and the pilot is qualified under 135.115 and 135.245, and is designated on the manifest as SIC, that person is a required crewmember and can log all time as SIC. Part 135.109 requires that both PIC and SIC be designated for each flight (note that it does not say designated for each phase of flight i.e. IFR conditions, CAT II ops, etc.) The flight manifest satisfies 135.109. Additionally, the Ops Specs for two pilot crew operation must always be adhered to while operating with a two-pilot crew (checklists, PF/PNF duties, etc.)

Maybe some companies have single pilot and two pilot crew procedures which are to be followed simultaneously, but I doubt the FAA would approve that sort of operation (can you imagine trying to shift from one pilot crew ops to two pilot crew ops every time you flew into a cloud?)

Our Company Ops Specs has a Deviation which specifically states that for all operations that require an SIC (including whenever the airline chooses to use a SIC, for whatever reason, including the request of a customer), the flight crewmember listed as SIC on the load manifest may log that time as SIC. This deviation was put in to validate all SIC time.

Aloha:cool:
 

avbug

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Everyone is getting warmer, but not quite there, yet.

The OpSpecs do not have to require a SIC. 14 CFR 135.101 requires a SIC for all operations carrying passengers under IFR, except for those operations which are granted specific authorization (via OpSpec A15) to use an autopilot in lieu of an SIC. Even in the presence of such an authorization, the operator may use the SIC in lieu of an autopilot.

The origional poster, 350 driver, states that he has been flightchecked for the position of SIC in the KingAir 350, and has been acting in that capacity under 135. This is legal, and appropriate, and he may log the time as SIC. He may do this without respect to manipulation of the controls.

He may log instrument time without respect to manipulation of the controls, or designation as first or second pilot (PIC vs. SIC).

He may not log PIC until type rated in the aircraft, or having been granted a Letter of Authorization in lieu of a type (but may act as PIC under certain specialized circumstances, without the type).

With respect to the question of receiving instruction from the PIC during the course of the flight; this is legal and acceptable, however, the PIC should ensure that instruction is indeed being provided. Simply being in posession of an instructor certificate (or ATP certificate in air transport service) does not automatically make one an authorized instructor for the flight, and does not mean instruction has been provided. That is to say, one may not simply indiscriminately endorse a logbook for instruction given, unless instruction has actualy been provided.

Endorsement by an instructor or ATP is not necessary in this case, as the origional poster is entitled to log the time without respect to the certification of the pilot in command. It must be logged as SIC, and sole manipulation time may not be logged as PIC in an aircraft requiring a type rating.

This subject aside, remember also that even in single pilot aircraft requiring a type rating, a PIC may be issued a type rating which requires a SIC. Thus, for that pilot to legally fly the aircraft type certificated for single pilot operations, the pilot may require a SIC, and the SIC becomes a required crew member even under Part 91. OpSpecs are not the only means of requiring a SIC.
 

stingray

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350driver anyway you can leagally log time do it, it may seem wierd, but screw it, multi time especially turbine time is to hard to come by.
 

ifly4food

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avbug said:
He may log instrument time without respect to manipulation of the controls, or designation as first or second pilot (PIC vs. SIC).
Avbug, can you discuss this in greater detail please? I have only been logging instrument time when in actual instrument conditions and sole manipulator of the controls for years. Have I been selling myself short?
Thanks.
 

414Flyer

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ifly4food said:


Avbug, can you discuss this in greater detail please? I have only been logging instrument time when in actual instrument conditions and sole manipulator of the controls for years. Have I been selling myself short?
Thanks.
Yes please do. I know on the ATP written, that was specifically addressed, and as an SIC, you could only long IFR time when acting as sole manipulator, not just when in FR
 

Bluto

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Avbug?

It is my understanding that you may log instrument time as an SIC while not acting as sole manipulator of the controls. It is simply a condition of flight, like logging night time. However, when logging approaches and landings you may only log them for recency requirements when acting as sole manipulator of the controls. You may log actual instrument time when in actual conditions whether you are the FP or NFP, as long as you are a required crewmember. At least this is my understanding.

Avbug? Some clarification please?
 

328dude

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A person may log instrument time only for that flight time when the person (not plural) operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.
 

avbug

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Instrument time is a condition of flight, as shown in 14 CFR 61.51(b)(3). Conditions of flight include day or night, actual instrument conditions, or simulated instrument conditions. If two crewmembers are required by the aircraft type certification to operate the aircraft (or the regulations under which the flight is conducted), it's rather difficult to have one crewmember flying in instrument conditions, and the other not, regardless of who is manipulating the controls.

61.51(g)(1) is the reference quoted by 328dude. An aircraft requiring more than one crewmember must be operated by both crewmembers. One is operating the aircraft as PIC, and the other as SIC.

The FAR makes no requirement to separate instrument time as SIC or as PIC, but many employers do. I've had to do this on application forms many times. In my own logbook, I differentiate between PIC-actual instrument and SIC-actual instrument, etc. In a total column, it's all instrument, but I make notations every few pages in the margin, or in a sticker, that show the breakdown.

This was discussed with some dissention on the FAR board for this site. I left a posting that shows John Lynch, AFS-640, disagrees with my position in his FAX site. He holds that only one person is operating the aircraft in an aircraft requiring more than one crewmember. This is not correct, and one will quickly learn that both pilots may be violated in enforcement proceedings, as both are considered to be operating the aircraft....usually too late.

Only one pilot may log an approach, and only one pilot may log a landing. However, instrument conditions apply to the conditions of flight, and except for simulated instrument flight, most certainly both pilots are in the same conditions of flight.

If the flight is conducted using an aircraft flight control system/autopilot, and no one touches the controls, who is logging the instrument time if no one is manipulating the controls? When FMS does the work, is only the FMS entitled to log the time? Of course not. Should only the legal PIC log the time, if it's the SIC/PF's leg? Of course not. Both pilots are in those conditions, and both pilots should log the time without respect to who is touching what.
 

stingray

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whoever is the one desinated as the flying pilot is the one that logs the instrument time. (pic, sic, autopilot doesn't matter.)
 

328dude

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Avbug: Great post but I have to disagree and agree with stingray on this.

If only one pilot is allowed to log the landing and approach, then how is both allowed to log actual? Regardless how many crew members the aircraft needs. I need to be in the plane in order for it to land (vague i know) then why can't I log the landing or the approach (I don't do it though) if I'm just running the gear handle?

If we are talking about phases of flight then is a approach a phase of the flight? If it is then is a actual instrument approach a phase or a condition? What I'm saying is that only one person can log the landing visual or actual. Fine I agree with that, but I can't log the approach in actual if I'm not flying.

Am I making sense or am I being stupid? Make the madness go away..................
 

avbug

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"Flying Pilot" isn't designated. The PIC and SIC are designated positions which are fixed under Parts 121 and 135, and flexible under 91. However, the pilot flying may be either pilot.

If you are suggesting that only the pilot manipulating the controls may log the time, this is not correct.

Only the pilot who performs a landing, or an approach, may log that landing or an approach. However, conditions of flight apply to the flight generally. If a PIC and SIC fly for one hour together in instrument conditions, the PIC may log one hour of instrument conditions, and log his flight time as pilot-in-command. The SIC may log one hour of instrument time (conditions of flight), and one hour of second-in-command.
 

328dude

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Then why cant you log a actual instrument approach if your the NFP? It's in actual conditions.... When do you stop logging actual and the condition switches over to an approach? This is getting alittle deep into the issue but I still don't agree.

I can't see how a pilot can log actual (regardless of their position in the aircraft) if they are not the flying pilot. Are you able to log it if your on VNAV/LNAV and in actual and it's not your leg?

Im getting a headache
 

gump88

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AvBug is incorrect!! Only the pilot manipulating the controls in IMC may log that time as actual instrument. Please be careful with this because you will be questioned in an interview, especially if your actual instrument time is unusually high in relation to the total time.

gump
 
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