Originally Posted by
rickair7777
Oooh, that's a big change. Wonder how they're going to deal with all the folks who have ATP's based partly on 135 SIC?
It's not a big change. Part 135 requires a SIC for IFR operations. Operations Specifications may allow single pilot IFR, but the basic requirement is two pilots. See 14 CFR 135.101.
135.105 allows the use of an autopilot in lieu of a SIC, if operations specifications are issued to that certificate holder allowing such. Even where such opspecs exist, the operator may elect to use a SIC under an approved training program, in accordance with 135.101.
No change at all, and if SIC's under 135 have experience that they've used toward their ATP, it's no threat to them. SIC's have long been required under IFR under 135. It's not the opspec that requires the SIC. It's the SIC that may be used by the certificate holder to eliminate the SIC.
Originally Posted by
Starbucks
Respectfully disagree. If there is a company Ops spec requiring an SIC - Then you can log it.
It's a Part 91 operation. There are no operations specifications. Are you suggesting that the company can invent their own and apply them under the regulation?
Where do you find an allowance in 61.51 that enables one to log time based on what a private company invents? Where's the allowance for that?
If the company operates under Part 135 and actually has operations specifications issued, that's one thing...but there's no provision in Part 135 that sets the requirement for a SIC. That's found in 135.101.
The original poster isn't working for a 135 company. No opspecs.
A private company operating under Part 91 can make up their own policies; they can even call them "operations specifications," if they want. It doesn't make them an FAA approved document, and doesn't establish any allowance under the regulation pertinent to the logging of time. A private company may set their own requirement for a SIC; this does not entitle one to log SIC.
If you believe otherwise, show it in the regulation.
Originally Posted by
rickair7777
James for clarity...
You're saying a 135 trained SIC who is required to be on board by the company's OPSPEC is not able to log SIC? Ie he is just a passenger?
Or do those 135 OPSPECS always mirror something in the 135 regs, which do grant the legality to log?
The OpSpecs under 135 do NOT require a SIC. That requirement is found in 135.101.
The OpSpecs under 135 provide an allowance to not use a SIC, by using an autopilot in lieu of a SIC.
The allowance for the OpSpecs to do this is found in 135.105.
A SIC is required under 135. OpSpec authorization for single pilot with autopilot may be issued, but with a training program for SICs, the company may still use a SIC because it's a basic requirement under 135, Operations Specification not withstanding.
Originally Posted by
satpak77
If your internal company regs require an SIC, then I would log SIC, as you are Acting, and being paid, to be one. I would lose no sleep over this, as long as you could articulate it in the interview. Are you being paid to sit in the seat ? Does the company provide training or issue SOP's for your actions in that seat? Then I would log it accordingly. My two cents.
An employer expects that an applicant is intelligent and responsible enough to log time according to the regulation.
There is no allowance under the regulation that allows the logging of SIC based on an "internal company reg."
An applicant who shows up for an interview claiming time logged that isn't loggable shows ignorance of the regulation. When the applicant is found to be claiming time that he or she cannot claim, the applicant looks foolish. The applicant's overall time diminishes, as does his or her experience. Can he or she still meet the job minimums?
There is no provision in the regulation for logging time because one is "paid to be in the seat." If you know of such a regulation cite it.
There is no provision in the regulation for logging time simply because a company provides training, unless that training program is approved under Part 121 or 135. If you're aware of such a regulation, cite it.
There is no provision in the regulation for logging time simply because "company SOP's" dictate that a SIC be on board. If you're aware of such a regulation, cite it.