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Old 07-11-2018, 03:10 PM
  #24  
SunnyFL
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Joined APC: Sep 2017
Position: CFI, CFII, MEI
Posts: 132
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Originally Posted by MaxMar View Post
For context, an Op Spec is approval from the FAA to do something under 135 or 121. For example, even though under 135 there's no limitation on what types of approaches can be flown, without the specific, appropriate Op Spec for a given type (e.g. ILS, VOR with DME arc, VOR without DME arc, etc) then the operator is forbidden from performing it. Another way of thinking of it: under part 91, the rules are a list of things you can't do. Under part 135 or 121, the rules are a much shorter list of things that you can do.

Previously under Part 135, SICs could only log time under specific circumstances, either a. the flight was operated under IFR and the operator did not elect to use Op Spec A015 which allows them to use an autopilot in lieu of the required SIC (135.101 and 135.105), or b. the operator was required by law (Op Spec or GOM) to have an acting SIC on 135 flights, therefore making them required crew and opening up loggable time or c. the airplane required two pilots in the first place.

The new ruling formalizes part b into what they are calling a 'SIC Pilot Development Program', which will be allowed via, you guessed it, an Op Spec. Once an operator attains this Op Spec from the FAA, there is no longer a requirement for a 'minimum crew', the person sitting in the right seat is under no obligation to have a legally defensible 'required crewmember' designation, but as long as the rules as defined in the Op Spec are followed, that SIC time is perfectly legal. This extends, for the first time, to part 91 re-positioning legs which can happen frequently in the passenger 135 world. Since these flights are operated under 91, they need not follow the restrictions of 135 or other Op Specs, which means on single pilot airplanes an SIC will never be required. With this new ruling, SICs could log SIC time when conducting a 91 repo leg so long as the conditions in the PDP Op Spec are followed.

Example: A night freight operation that runs Caravans under 135 VFR and IFR can now hire pilots to fly and log time from the right seat to build time towards being a Captain there as well as towards ATP minimums, where previously these types of operations didn't do this because there's no incentive to; prior to this rule, an SIC wouldn't be required since there's no passengers and while a safety advantage may or may not be present, no one really cares about how many pilots are up front when the only thing in the back is boxes (in the 135 world).

This ruling also helps remove any doubt from Caravan and Pilatus 135 right seaters who typically have to sling gear without logging time on 91 legs, and some are suspect of any SIC time at all, even though there is a strong argument that it can be logged if the appropriate documents are accepted by the FAA.

Clear as mud, ya?

For your question about whether the flight time is legal for the regionals, simply ask during the interview or even before for the location, in writing, in their GOM or Op Spec where a SIC is required crew. If they can't provide that, or they give an answer like 'It's company policy / it's in the SOP / it's an insurance requirement' none of those answers will yield legal time. Only an Op Spec or GOM carry regulatory weight and thus you need to see it in writing in one of those documents.
Thank you very much for the break down and great explanation. That was very helpful and I feel like I understand it a lot more now!
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