Originally Posted by
MaxMar
But it is FAA accepted. The regs require compliance with a GOM as per 135.21, so if the GOM says an SIC is always required, no flights could depart without an SIC, making them required crew. Same goes for anything in a GOM, violating the GOM is violating 135.21.
Otherwise you’re right, if the GOM doesn’t explicitly state an SIC is to be designated then they’d need a 135.99 SIC PDP, or always fly IFR without A015 or PICs who complete a 135.297(g).
Yeah my point was more that there is no "Operations Specs" that require an SIC. The whole 135.99 SIC PDP, I think, shows that FAA understands that a lot of SIC programs weren't really useful and not loggable the way 61.51 means.
A Caravan SIC in VFR really is stretching the definition of a required crewmember in my opinion.