Originally Posted by
dera
Exactly my point, it needs to be an OpSpec - not a "requirement" in GOM which most of these actually are.
What is the OpSpec number that would specify this? I've never seen an OpSpec requiring two pilots for single pilot plane, only GOM that specifies that. And GOM is not approved, it's accepted, and thus not strictly regulatory.
I think this is a grey area and neither the Nichols nor Tarsa letters sufficiently cover this scenario.
I know a Caravan "SIC" who got badly burnt by this (as in - logged up to 1500 hours, quit his job, went through 121 training and wasn't issued an ATP because 1000 hours of his time was 208 "SIC" time.)
I thought GOM was good enough, that's been the conventional wisdom for a long time. Not familiar enough with 135 OPSPEC to say where it be, if at all. But FAA legal can, and does, cast doubt on long-standing assumptions.