Originally Posted by
JohnBurke
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.
You're right. I have lived in the 91k and 135 world, so that's how I was thinking. 135 requires two pilots unless the Ops Spec allows otherwise. Not trying to state that a company requirement is an FAA allowance.
In this situation, I would agree that SIC time is unloggable unless the PIC has a crew stipulation attached to their licence.
This is why I've always kept two columns in the logbook. Basically "Logged PIC" (sole manipulator) and "Actual PIC" When asked what the total PIC time is - I respond with the "Actual PIC" numbers. When asked total time I respond with all flight time including the "Logged PIC".
If the original poster is technically not required in the plane - I would encourage them to be the pilot flying as much as possible, so they are legal to log the "Logged PIC" flight time.
Those are my thoughts.