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Old 07-05-2011, 05:29 AM
  #26  
Walkeraviator
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Joined APC: Feb 2008
Position: Airline Captain
Posts: 540
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Karch Letter from FAA Chief Counsel...

It was written to a guy in this very situation. He had a pay to play SIC program for his 135 cargo op. The letter plainly states that an SIC acting as an SIC on a plane not type-certificated for two pilots and not operating under regs that requires two pilots... CAN NOT LOG SIC TIME!

If, however, he meets the requirement of 135.245 and takes checkrides under 135.293, he may sit in the right seat , act as sole mainpulator of the controls, and log that time as PIC. However, legally, the man sitting the left seat and "acting as PIC" cannot "Log" PIC. They are two different things to the FAA. So if the guy in the left seat knows he cant log it if you are flying it from the right seat, whey would he ever let you have the controls?

With that said, they do have one passenger carrying aircraft out of Kansas City. Two pilots are then required under 135.101 and the SIC can log that time as SIC time.

I dont agree with pay-to-play programs, but if you feel you must do it, just dont pay for time that you can't log.
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