"SIC" vs second pilot 135?
Some form or another of this comes up every few years, seems like.
Situation: Small 135 operator. Single pilot certified light twin jet. Single pilot qualified/typed/ PIC. Client requires 2 pilots. Can you pay Joe Pilot with a commercial multi-engine to sit in the right seat?
Argument For:
Joe SIC can be treated as a passenger since they are not technically required by the FAA as long as they don't touch the controls. (Lets assume that the particular operation doesn't include anything that is exempted single pilot. ie: low visibility T/O, Autopilot is working, etc...) I'm guessing if you wanted to go all-in on this argument that you would have to file FET/Segment fees for this "second pilot" as well...
Argument Against:
The fact that the client requires two pilots makes the second pilot a de-facto SIC that would require training per the 135 training manual, an SIC type rating and a .293. Also, if you were paying someone to sit in that seat, they would be using their commercial pilot privileges, and would require an appropriate type rating in the aircraft.
I've had different POI's agree with me from both points of view, and I can't find an appropriate legal interpretation. Anyone with any input? Am I missing something?
Obviously the equation changes somewhat if the client requires a particular 2-crew safety rating (Wyvern/Argus/etc...) instead of the more generic "2-pilot crew". Even if the bar to meet the SIC requirements for the safety rating is low, you are still making them an SIC on paper, which I would think would trigger the training requirements. Would just a SIC type rating suffice in this case?
I know there are plenty of 135 operators that operate on both sides of this one, and that our current POI has pretty much the only opinion that counts, but I wanted to have a clear picture when it comes to having to hire a third full-time pilot vs using an occasional contract guy.