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satpak77
02-13-2013, 02:29 PM
I have a 1100 guy who is King Air copilot on our 350. Me, being an MEI, am actively training him and putting him on empty legs in the left seat.

we are getting some "push back" from Simuflite on whether he can be ATP'ed at the 1500 hour mark. I say I am endorsing his logbook when he is getting bonafide instruction and this should count. He is going to take his written soon, and holds 1st class Medical.

Any ideas how we can ATP-him ? Found simuflite's response weird, but I have been wrong before.

thanks


threeighteen
02-13-2013, 03:10 PM
How many hours of dual have you given him on the aircraft? Does he meet the 500 PIC XC requirement along with the other requirements.

KSCessnaDriver
02-13-2013, 03:54 PM
How many hours of dual have you given him on the aircraft? Does he meet the 500 PIC XC requirement along with the other requirements.

You mean the 500 hours of cross country, right? There is no 500 hour PIC cross country requirement.


satpak77
02-13-2013, 04:38 PM
well actually every flight we have some component of legit bonafide training, either seat. I am inclined to endorse all flights

fjetter
02-13-2013, 06:18 PM
Does it have to do with them PIC typing with relatively low-hours? Any chance they can ATP him with a PIC limitation (requiring 25 hrs with another rated PIC) before he can earn a full type?

satpak77
02-13-2013, 06:21 PM
Does it have to do with them PIC typing with relatively low-hours? Any chance they can ATP him with a PIC limitation (requiring 25 hrs with another rated PIC) before he can earn a full type?

I will check further. One of our admin ladies called and she may not have presented the correct picture. It sounds like they were not aware he is flying at all times with a MEI/CFII and thus potentially logging legal flight hours under the watch of the MEI. (I mean we are always learning while up front...)

Sounds like they were told "Pilot Jones has 1100 hours and is right seat on King Air, and when he reaches 1500 we want to ATP him"

so.....

GlobalEx
02-15-2013, 07:40 AM
I dont see why they should have an issue, as long as he meets all of the requirements for a type rating.

Is he possibly not of good moral character? :)

satpak77
02-15-2013, 08:13 AM
I dont see why they should have an issue, as long as he meets all of the requirements for a type rating.

Is he possibly not of good moral character? :)

yessssss he is good dude

Red Forman
02-15-2013, 10:55 AM
I have heard that sometimes Simuflite and Flight Safety don't like typing guys that are near the minimum qualifications. I think they view it as a liability problem. Even though it may be legal in the FAAs eyes, they don't want it coming back on them if he screws something up after he has gone through their training.

rickair7777
02-15-2013, 01:31 PM
well actually every flight we have some component of legit bonafide training, either seat. I am inclined to endorse all flights


Be very careful! You are on thin ice here (actually it's already cracked IMO).

The FAA only allows logging of dual when legit training is being conducted. This seems to include...

- Requirements for certs, ratings, endorsements
- Currency
- Club checkout, insurance checkout
- Area FAM
- Route FAM
- Environment FAM (ex. mountains)
- Aircraft FAM

You are doing aircraft FAM (route FAM might apply on the first round trip). The problem here is that it's customary and reasonable to spend 1-5 hours on ASEL, maybe 10 on AMEL and possibly as much as 40-50 on a turbine aircraft. There is no reasonable precedent to spend 400 hours doing aircraft FAM, therefore that time would not seem to qualify as legit dual.

I'm not surprised SF won't touch it...I wouldn't either frankly.

But that's just my read of the lay of the land...I don't know if the FAA has written policy on how much dual you can do.

galaxy flyer
02-15-2013, 05:13 PM
Why not just put him "in command" on legs he (she?) flies, assuming they have a CP AMEL and appropriate training? Or write a company flight manual specifying two pilots. But, logging 400 or 500 hours of dual given won't pass muster.

GF

KSCessnaDriver
02-15-2013, 05:55 PM
Be very careful! You are on thin ice here (actually it's already cracked IMO).

The FAA only allows logging of dual when legit training is being conducted. This seems to include...

- Requirements for certs, ratings, endorsements
- Currency
- Club checkout, insurance checkout
- Area FAM
- Route FAM
- Environment FAM (ex. mountains)
- Aircraft FAM

You are doing aircraft FAM (route FAM might apply on the first round trip). The problem here is that it's customary and reasonable to spend 1-5 hours on ASEL, maybe 10 on AMEL and possibly as much as 40-50 on a turbine aircraft. There is no reasonable precedent to spend 400 hours doing aircraft FAM, therefore that time would not seem to qualify as legit dual.

I'm not surprised SF won't touch it...I wouldn't either frankly.

But that's just my read of the lay of the land...I don't know if the FAA has written policy on how much dual you can do.

So basically, this post says, I make up my own rules as to what I think the FAA says? Correct, because there is zero regulatory backup on this one, no?

satpak77
02-15-2013, 07:01 PM
Be very careful! You are on thin ice here (actually it's already cracked IMO).

The FAA only allows logging of dual when legit training is being conducted. This seems to include...

- Requirements for certs, ratings, endorsements
- Currency
- Club checkout, insurance checkout
- Area FAM
- Route FAM
- Environment FAM (ex. mountains)
- Aircraft FAM

You are doing aircraft FAM (route FAM might apply on the first round trip). The problem here is that it's customary and reasonable to spend 1-5 hours on ASEL, maybe 10 on AMEL and possibly as much as 40-50 on a turbine aircraft. There is no reasonable precedent to spend 400 hours doing aircraft FAM, therefore that time would not seem to qualify as legit dual.

I'm not surprised SF won't touch it...I wouldn't either frankly.

But that's just my read of the lay of the land...I don't know if the FAA has written policy on how much dual you can do.

Rick, I follow alot of your posts and you have good material, but this isn't one of them. In good faith I sought out the advice of fellow colleagues and professionals, as a possible solution to this problem. Similar to the IRS, tax evasion is illegal, tax avoidance is not. Within the laws and policy as a framework, if I can endorse his logbook, I probably will. I have not seen in Part 1, the definition of "legit dual". I acknowledge that its on us (me) to communicate this to the FAA. Also, I am sorry that training at some places "stops" after 50 hours on turbine aircraft. I would hate to think that after 50 hours at Company XYZ (approximately two months if 25 a month), I can then go on to a 20 year career flying said aircraft and never receive training again.

Not at our place. At our place, we fuel it up and go out and do airwork and stalls and practice approaches every 90 days. We also do "training" with senior PIC's who enjoy giving training to newer guys while doing "standard" Point A to Point B flights that (due to my poor understanding of the aviation world) are now to be considered flight portions where training / instruction / learning is not possible. (I missed the FAA Chief Counsel memo on that one...)

Thanks for the others for the information provided.

USMCFLYR
02-15-2013, 07:09 PM
It might not be the FAA that this pilot ever has to worry about.
According to many posts on the forums, it is the airlines, or other employers, who don't subscribe to Sat's company training program that might find fault with a fairly new pilot with a serious amount of *training* time in the KA.

Remember - many of those previous posts draw some muddy lines of distinction between what is "legal" and what is "accepted".

Cruz5350
02-15-2013, 10:51 PM
Run him through an SIC program at one of the places or give him the SIC rating yourself and boom legal as can be. No where does it say you have to operate the plane single pilot if you have the endorsement. As for the 1500TT and type FSI is giving me the ATP and 350 type right at 1500TT so I don't see why it would be any different elsewhere.

Cruz5350
02-15-2013, 10:52 PM
It might not be the FAA that this pilot ever has to worry about.
According to many posts on the forums, it is the airlines, or other employers, who don't subscribe to Sat's company training program that might find fault with a fairly new pilot with a serious amount of *training* time in the KA.

Remember - many of those previous posts draw some muddy lines of distinction between what is "legal" and what is "accepted".

If a company doesn't want to recognize a legitimate SIC logging legal hours than forget em.

USMCFLYR
02-16-2013, 06:01 AM
If a company doesn't want to recognize a legitimate SIC logging legal hours than forget em.
Two things:

1) If talking about Sat's scenario - the pilot isn't acting / logging the time as a legit SIC. The pilot is basically acting as a student pilot.

2) If [forgetting them] is the route that you want to go......I agree.
If some particular type of flying is your goal and you are greatly reducing your chances then not such a grand stand to make.

dapper993
02-16-2013, 06:30 AM
Does it have to do with them PIC typing with relatively low-hours? Any chance they can ATP him with a PIC limitation (requiring 25 hrs with another rated PIC) before he can earn a full type?

They don't really have a choice. Assuming the whole check is conducted in the SIM:

It does not sound like he meets the experience requirements and his type will be issued with an SOE limitation for 25hrs per 61.64.

satpak77
02-16-2013, 07:01 AM
Without this turning into Court TV, I will move forward and figure this out amongst ourselves at our place and Simuflite.

Thanks

rickair7777
02-16-2013, 07:24 AM
Rick, I follow alot of your posts and you have good material, but this isn't one of them. In good faith I sought out the advice of fellow colleagues and professionals, as a possible solution to this problem. Similar to the IRS, tax evasion is illegal, tax avoidance is not. Within the laws and policy as a framework, if I can endorse his logbook, I probably will. I have not seen in Part 1, the definition of "legit dual". I acknowledge that its on us (me) to communicate this to the FAA. Also, I am sorry that training at some places "stops" after 50 hours on turbine aircraft. I would hate to think that after 50 hours at Company XYZ (approximately two months if 25 a month), I can then go on to a 20 year career flying said aircraft and never receive training again.

Not at our place. At our place, we fuel it up and go out and do airwork and stalls and practice approaches every 90 days. We also do "training" with senior PIC's who enjoy giving training to newer guys while doing "standard" Point A to Point B flights that (due to my poor understanding of the aviation world) are now to be considered flight portions where training / instruction / learning is not possible. (I missed the FAA Chief Counsel memo on that one...)

Thanks for the others for the information provided.

Like I said this is certainly not clearly defined but at some point it will raise eyebrows. What that point is I don't know...50? 100? 200? 500?

I guess it comes down to this...what is the purpose of the dual? Can you clearly articulate the specific training value? Or is the purpose simply to allow two guys to log time in a single-pilot airplane?

If somebody really needs several hundred hours of dual to learn a new airplane, does that raise questions about his commercial certificate? JFK Jr. had hundreds of hours dual and apparently he was never going to grasp instrument flying.

I know this issue has come up with at least two FSDOs, and they both didn't approve. Not that a FSDOs opinion is the gold-standard, but it's probably st least a bronze standard.

If somebody came to me to do a checkride with a lot of this kind of time logged I would have to consult with the FSDO before proceeding.

The FAA is not always strictly bound by literal interpretation of the regs...you might have to take it to the NTSB (and win).

Any of our resident lawyers recall any formal FAA opinions on this?

rickair7777
02-16-2013, 07:28 AM
It might not be the FAA that this pilot ever has to worry about.
According to many posts on the forums, it is the airlines, or other employers, who don't subscribe to Sat's company training program that might find fault with a fairly new pilot with a serious amount of *training* time in the KA.

Remember - many of those previous posts draw some muddy lines of distinction between what is "legal" and what is "accepted".

That too. You might find varied opinions in the corporate world, and you might luck out with a few scum-sucking regionals but I already know how most 121 operators would feel about this. They would be afraid to give you an ATP based on a lot of dual under those circumstances.

galaxy flyer
02-16-2013, 08:00 AM
Not at our place. At our place, we fuel it up and go out and do airwork and stalls and practice approaches every 90 days. We also do "training" with senior PIC's who enjoy giving training to newer guys while doing "standard" Point A to Point B flights that (due to my poor understanding of the aviation world) are now to be considered flight portions where training / instruction / learning is not possible. (I missed the FAA Chief Counsel memo on that one...)

BUT, IF your "newer" guys are CP AMEL Iinstrument rated, they are qualified to do all that flying as PIC, not as "dual received", so it's not "dual given".

GF

Cruz5350
02-16-2013, 08:39 AM
Seeing as how in the next 5 months I will be giving 350 training at FSI it wouldn't cause me any heartburn to have a student like this. Now if they just didn't have it going on at all then yes it would be a game changer.

Cruz5350
02-16-2013, 08:47 AM
Plus you have maybe what 5-8 regionals with about 3-4 people at each conducting interviews that would say his time is bogus? I'm sorry but I'm not going to let those people be aviations literal interpreters on how "it" should be done. No one can say its any different if they're doing practice stalls approaches in a King Air, Seminole, or 172. They're practicing and logging legal dual for some airline or FSDO to say otherwise is pretty ridiculous. What you do have is some lucky individuals to get this experience and some hard headed other individuals saying no no no that's not how it works.

GlobalEx
02-16-2013, 08:47 AM
That too. You might find varied opinions in the corporate world, and you might luck out with a few scum-sucking regionals but I already know how most 121 operators would feel about this. They would be afraid to give you an ATP based on a lot of dual under those circumstances.

What do you mean about the regionals? They are now typing and giving ATPs to everyone they hire, congress has required it beginning in August.

Cruz5350
02-16-2013, 08:49 AM
Exactly they're giving ATP's to people with zero 121 or turbine time.

GlobalEx
02-16-2013, 08:55 AM
Exactly they're giving ATP's to people with zero 121 or turbine time.
Yes, they dont have a choice.

satpak77
02-16-2013, 09:30 AM
just started to make some popcorn....will be ready in a minute

rickair7777
02-16-2013, 09:33 AM
What do you mean about the regionals? They are now typing and giving ATPs to everyone they hire, congress has required it beginning in August.


I mean their interviewers would be wary about hiring someone whose ATP aeronautical experience was based on a lot of dual-given under the circumstances being discussed in this thread. They would be concerned about FAA pushback on the person's eligibility for that ATP.

Airlines have always been leery of flight time logged when not a required crewmember. Obvioulsy dual is fine with the customary bounds or earning your ratings. But hundreds of hours of dual received in a single-pilot airplane AFTER your CPL? They will be cautious of that (I'm putting it delicately).

rickair7777
02-16-2013, 09:34 AM
Exactly they're giving ATP's to people with zero 121 or turbine time.


But those folks generally meet all the aeronautical experience requirements based on working as CFI's. 1000+ hours of dual-GIVEN is not controversial.

USMCFLYR
02-16-2013, 09:55 AM
Plus you have maybe what 5-8 regionals with about 3-4 people at each conducting interviews that would say his time is bogus? I'm sorry but I'm not going to let those people be aviations literal interpreters on how "it" should be done. No one can say its any different if they're doing practice stalls approaches in a King Air, Seminole, or 172. They're practicing and logging legal dual for some airline or FSDO to say otherwise is pretty ridiculous. What you do have is some lucky individuals to get this experience and some hard headed other individuals saying no no no that's not how it works.
You missed it again Cruz.
It is a business who is interviewing and hiring who can make these decisions on whether they accept or deny this time in someone's logbook. It is their ball and they get to make the rules. I'm sure you really put your foot down in that FSI interview about something you didn't agree with too right? ;)

Cruz5350
02-16-2013, 10:05 AM
You missed it again Cruz.
It is a business who is interviewing and hiring who can make these decisions on whether they accept or deny this time in someone's logbook. It is their ball and they get to make the rules. I'm sure you really put your foot down in that FSI interview about something you didn't agree with too right? ;)

Nothing to put my foot down about it was a pleasant experience.

GlobalEx
02-16-2013, 10:09 AM
I mean their interviewers would be wary about hiring someone whose ATP aeronautical experience was based on a lot of dual-given under the circumstances being discussed in this thread. They would be concerned about FAA pushback on the person's eligibility for that ATP.

Airlines have always been leery of flight time logged when not a required crewmember. Obvioulsy dual is fine with the customary bounds or earning your ratings. But hundreds of hours of dual received in a single-pilot airplane AFTER your CPL? They will be cautious of that (I'm putting it delicately).

Sorry, I misunderstood what you were saying, got it now.

USMCFLYR
02-16-2013, 11:23 AM
Nothing to put my foot down about it was a pleasant experience.
There will be.
I remember you saying that about Silver too! :)

rickair7777
02-16-2013, 02:31 PM
Plus you have maybe what 5-8 regionals with about 3-4 people at each conducting interviews that would say his time is bogus? I'm sorry but I'm not going to let those people be aviations literal interpreters on how "it" should be done. No one can say its any different if they're doing practice stalls approaches in a King Air, Seminole, or 172. They're practicing and logging legal dual for some airline or FSDO to say otherwise is pretty ridiculous. What you do have is some lucky individuals to get this experience and some hard headed other individuals saying no no no that's not how it works.


Well, yes that's how it it generally works in 121. You of course do not have to apply to any 121 operations, not do you have to tolerate their opinion at the interview...you're free to tell them where to shove their interpretation at that time. But you don't have to believe me either, ask the interviewer when you get there.

But yes, the way I described it is the way most if not all 121 operations will view it. They will be especially concerned if they are going to be granting your ATP based on that dual time. If you already have an ATP, maybe they won't care.

Once again, I fully agree that this is NOT clearly defined in the regs, but it is pretty clearly understand as general industry practice.

galaxy flyer
02-16-2013, 02:39 PM
Once more, if the pilot in question is qualified, FAA licensing, just have him log the PIC time. There is NOTHING in the regs preventing that.

GF

fjetter
02-16-2013, 03:28 PM
Once more, if the pilot in question is qualified, FAA licensing, just have him log the PIC time. There is NOTHING in the regs preventing that.

GF

One of the issues is that the pilot is not PIC qualified per FAA regs. The aircraft being discussed is the KA 350 which requires a type rating (I agree with you if it was a KA 200).

I agree with someone who said something earlier about talking to the local fsdo and having a SIC type issued. Then he can log all the time pf or pnf, if I read the thread right (aircraft operated under part 91). Just because the aircraft is certified single-pilot doesn't mean you have to operate it that way. If it's pt 135 we all know how that changes things.

Cruz5350
02-16-2013, 03:37 PM
Well, yes that's how it it generally works in 121. You of course do not have to apply to any 121 operations, not do you have to tolerate their opinion at the interview...you're free to tell them where to shove their interpretation at that time. But you don't have to believe me either, ask the interviewer when you get there.

But yes, the way I described it is the way most if not all 121 operations will view it. They will be especially concerned if they are going to be granting your ATP based on that dual time. If you already have an ATP, maybe they won't care.

Once again, I fully agree that this is NOT clearly defined in the regs, but it is pretty clearly understand as general industry practice.

No I hear ya I just think it's kind of ridiculous that it's slipped to this level.

Cruz5350
02-16-2013, 03:41 PM
One of the issues is that the pilot is not PIC qualified per FAA regs. The aircraft being discussed is the KA 350 which requires a type rating (I agree with you if it was a KA 200).

I agree with someone who said something earlier about talking to the local fsdo and having a SIC type issued. Then he can log all the time pf or pnf, if I read the thread right (aircraft operated under part 91). Just because the aircraft is certified single-pilot doesn't mean you have to operate it that way. If it's pt 135 we all know how that changes things.

That's what I was trying to say... you can get around this whole logging dual issue if you just get him the SIC type either through an FSI type of company or heck in house. It sounds like all the dual that's been provided would be plenty for the 61.55 endorsement. Reference this thread....

http://www.airlinepilotforums.com/aviation-law/67708-how-give-sic-type-pt-91-a.html

I'm not sure if you could back date it or not but you might be able to.

galaxy flyer
02-16-2013, 04:28 PM
Sorry, I just looked at the TCDS and saw single pilot; it doesn't mention the TR, but the TOGW should have clued me in. If it is cert'd as single pilot, not sure a SIC T/R would be available and not needed within the US. Maybe, give them PIC ratings on their CPL.

GF

Yabadaba
02-17-2013, 08:46 AM
Sorry if I skipped this part, but do you have a single pilot type? If not then the Copilot is a required crewmember. He then only requires a Multi-commercial and all time is logable as SIC.

mojo6911
02-20-2013, 06:00 PM
Don't see why you need a lot of dual. They should have told you exactly what the reason is they won't type him.