Originally Posted by
piloto2
My opinion and interpretation of the regulations is not what matters. What does matter is the FAA legal division's interpretation. And they are crystal clear on the matter. If you aren't a required are member per the type certificate on the plane, you don't get to log the time. I don't know why that is so hard for you to understand.
As far as NetJets goes, they have an exception on their certificate. They are the ONLY 135 operator that does. It's not "my logic". The FAA has granted the exception. Because of that exception, their SICs get to log the time.
You're darned straight that I know the qualifications of the pilots I fly with. PIC is determined before the flight, every flight. If I am sitting right seat in a single pilot jet, and the other guy is the PIC, I don't log SIC time because it isn't legal (per the FAA).
I'm pretty sure none of this will change your mind. You've determined that you want to log the time and that's it. As I stated earlier, I am personally familiar with the details of the FAA Nichols letter as well as several of the individuals involved. The 135 certificate holder in that case was telling young, inexperienced pilots exactly what you want to believe. They did so because many of their customers wanted two pilots, even though only one was required by the FAA. And they hired these novices on with low pay, but with the promise of logging "jet time".
I have come across many of these erroneous logging entries while reviewing job applicants in both the 121 and 135 worlds. Only one applicant was able to satisfactorily explain the entries. A lot of operators won't care. Many will. And as stated by another here, if you find yourself in front of the FAA for an unrelated situation, they WILL care.
So why doesn't the FAA legal council yank all the low time guys and violate them? They obviously know about it right? Your logic is holier than thou and just because you have read a few LOI doesn't make you an expert in the matter. Why don't our pilots who are ALL single pilot typed in the EMB-500 get slapped? The OpsSpecs say we need it, it was blessed by the FAA. So until the FAA comes knocking on our doors, which they haven't in the company history, we continue to all log appropriately. Oh and our guys are leaving for places like Delta, United, Virgin, Southwest. Why haven't their hiring boards said anything about logging time in a single pilot airplane? Oh that's right because it's a crewed environment.
DH