Originally Posted by JamesNoBrakes

This is again may be a good situation for someone to contact the POI of the certificate. The APD is probably managed by an APOI, but the POI is managing the POI. There have been some regional airlines recently not counting legitmate 135 SIC time, thinking that the only way is with a PDP program, when there are specific regulatory rules that require an SIC and allow the time to be logged, including IFR with passengers and 135.267(b)(2), or when the PIC's type rating says "SIC required", to name a few.

I see an interesting caveat in the regulations that I'm not sure has been addressed. According to 61.51, you have to be a civil pilot of some type to log time, as in commercial, private, student or ATP, etc. If one did not hold a civil pilot certificate when the time was logged, I'm not sure how those hours would be eligible for credit under the regulation. The FAA can do military-competency certification of military pilots up to commercial and flight instructor, where they don't have to meet any specific time requirements except the 10 hours of "pilot time", but for the ATP, to count PIC time, it would have to be logged under 61.51, no? If there was any further intent to the rule, it would be found in the NPRM/FR rulemaking information for 61.51 and without anything specific there, the rule would be taken at face value. In general, if this rule meant to include military time, it would say so.

Interested to see where this goes.