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Old 03-01-2021, 09:29 AM   #31  
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For the 100 hr consolidation after OE the FAA only allows seat time in a pilot position to be counted.
Iíve continued logging my time that way.
Total time = block time
SIC time = seat time

It doesnít say anywhere that your PIC + SIC needs to equal TT.
Thatís a bean counter thing.
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Old 03-01-2021, 09:55 AM   #32  
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Originally Posted by TiredSoul View Post
For the 100 hr consolidation after OE the FAA only allows seat time in a pilot position to be counted.
Iíve continued logging my time that way.
Total time = block time
SIC time = seat time
That seems fine, since it's easy to see on your application and logbook what your time in seat actually was.

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Originally Posted by TiredSoul View Post
It doesnít say anywhere that your PIC + SIC needs to equal TT.
Thatís a bean counter thing.
There's no regulatory definition of total time anyway. I don't think mine matches, pretty sure I had dual received as a student pilot where I logged TT but was not the PIC, and there's no SIC position in a 172.

AMEL+ASEL = TT is a more useful check for logbook errors, if you're a typical FW pilot.
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Old 03-02-2021, 02:01 AM   #33  
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How would you suggest logging SIC vs. IRO? I'm looking at it mainly to be easily defensible at a job interview, where the person reviewing the logbook may not be familiar with the regulatory ins and outs of augmented crew time. You need to be able to explain it succinctly without sounding like you're reaching, and worst case you need to be able to quote chapter and verse of the regs.

My premise here is that might be a big can of worms to bring to an interview, especially a SWA/ULCC interview where they just don't have SA on that sort of flying. Basically you're trying to use bunk time to compete with mil, regional, and corporate pilots who were in the seat the whole time... can you make the case that bunk time is equivalent and reg-kosher?

Obviously the PIC who signed for the plane can log it all I think that's well established and assumed.
It's not a big can of worms at all. How would I recommend differentiating between "SIC" and "IRO?" I wouldn't.

The IRO is a SIC. Log it as SIC. No explanation needed.

A typical augented crew on an ACMI flight may, for example, have three F/O's assigned as SIC on a long trip, and one captain. The captain is the PIC designated in the flight release, and remains so. The F/O may sit in the pilot seat, may run a plotting chart on an ocoeanic lega and make the HF calls, or do other duties, or may sit in either the right or left seats during the flight. Typically every F/O is qualified to be IRO, sitting in either right or left seats. He or she is an assigned member of the crew on the flight release, performing duty, restricted by the same flight and duty limitations, subject to the same legal enforcement as other members of the crew, must file the same ASAP report as the rest of the crew, and is an SIC for the purposes of the flight and the assignment of the flight by the 121 operator. How to describe one's experience for the duration of the flight? SIC.

If two or even three captains are assigned together to a flight, one is the designated PIC, listed as such on the flight release, and responsible for the safe outcome, and for signing for the flight. He or she is the PIC, and logs it as such. The other captains may log SIC. The fact that they're captains is irrelevant. They're not the pilot in command. Whether they are "Captains," "IRO's," or "First Officers," They're not the PIC on the release: they're a SIC. Log accordingly.

There's nothing to explain.
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Old 03-02-2021, 07:22 AM   #34  
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It's not a big can of worms at all. How would I recommend differentiating between "SIC" and "IRO?" I wouldn't.

The IRO is a SIC. Log it as SIC. No explanation needed.

A typical augented crew on an ACMI flight may, for example, have three F/O's assigned as SIC on a long trip, and one captain. The captain is the PIC designated in the flight release, and remains so. The F/O may sit in the pilot seat, may run a plotting chart on an ocoeanic lega and make the HF calls, or do other duties, or may sit in either the right or left seats during the flight. Typically every F/O is qualified to be IRO, sitting in either right or left seats. He or she is an assigned member of the crew on the flight release, performing duty, restricted by the same flight and duty limitations, subject to the same legal enforcement as other members of the crew, must file the same ASAP report as the rest of the crew, and is an SIC for the purposes of the flight and the assignment of the flight by the 121 operator. How to describe one's experience for the duration of the flight? SIC.

If two or even three captains are assigned together to a flight, one is the designated PIC, listed as such on the flight release, and responsible for the safe outcome, and for signing for the flight. He or she is the PIC, and logs it as such. The other captains may log SIC. The fact that they're captains is irrelevant. They're not the pilot in command. Whether they are "Captains," "IRO's," or "First Officers," They're not the PIC on the release: they're a SIC. Log accordingly.

There's nothing to explain.
Yeah that's what I've been saying, all the other guys who are not the PIC of record log SIC when doing crew duty, but the question was what about bunk time? My assertion was that the PIC can log all flight time because he's the PIC at all times, but if there are multiple SIC's should they log bunk time?

I bring this up because I've heard anecdotally that it's been a friction point with some hiring people, at two single-fleet LCCs that I know of.
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Old 03-02-2021, 08:19 AM   #35  
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Originally Posted by rickair7777 View Post
Yeah that's what I've been saying, all the other guys who are not the PIC of record log SIC when doing crew duty, but the question was what about bunk time? My assertion was that the PIC can log all flight time because he's the PIC at all times, but if there are multiple SIC's should they log bunk time?

I bring this up because I've heard anecdotally that it's been a friction point with some hiring people, at two single-fleet LCCs that I know of.
I think 61.51 (f) (2) is pretty clear in allowing all SICs to log the entire flight if their presence was required by the regulations under which the flight was conducted. The 3 items under 61.51 (f) are ďorĒ items, not ďandĒ items. So if an interviewer questioned me I would very tactfully point him/her to that reg, and if they still didnít like that, thereís really not much I can do.
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Old 03-02-2021, 05:53 PM   #36  
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Yeah that's what I've been saying, all the other guys who are not the PIC of record log SIC when doing crew duty, but the question was what about bunk time? My assertion was that the PIC can log all flight time because he's the PIC at all times, but if there are multiple SIC's should they log bunk time?

I bring this up because I've heard anecdotally that it's been a friction point with some hiring people, at two single-fleet LCCs that I know of.
There is no "other" category for the logging of flight time.

How could a "hiring person" possible know what portion of a flight, if any, one spent in a bunk? Are HR personnel asking this as a question? "Did you ever log time while sleeping in a bunk?"

I've flown a lot of long haul flying and have never slept in a bunk. I haven't always been in a pilot seat during that time, as there are flight deck duty limitations. Never the less, 100% of that time counts toward flight time limitations under Part 121. How is it that one's time, assigned on the flight release, counts against flight time limitations under 121 (or 135), and het is not loggable?

We know that there are circumstances in which one can be the pilot, or a required crew member, and yet not log the time. The classic example is the private pilot in a Cessna 172, who allows his non-pilot friend to manipulate the controls. Even though the private pilot IS the acting pilot in command, he can't log it, because he fits none of the definitions during that time frame, to log the time. He isn't sole manipulator, he isn't PIC of an aircraft requiring more than one crew member by type certification, and the rules under which he is operating don't require a second crew member. He can't log it as SIC. Neither pilot may log the time, and yet there is still a PIC. It's an oft-used example of the difference between the logging of pilot time, and acting as a pilot: two very different things.

There are FAA Chief Legal Counsel letters of interpretation which do state that time spent not in the pilot seat isn't loggable. Or is loggable under certain circumstances.

For example, in a June, 2013 memorandum from the Acting Assistant Chief Legal Counsel to the POI over UAL's certificate management, Mark Bury noted that specific to IOE and consolidation times under 14 CFR 121.434, only time spent in the pilot seat could be logged toward the requisite OE hours, or consolidation hours. That interpretation applies to logging for the purposes of meeting initial operating experience requirements as a new-hire, or the 100 hour consolidation of experience requirement, not to logging in general.

https://www.faa.gov/about/office_org...rpretation.pdf

The issue of how HR will view experience is not a legal issue. Logging of flight time is. For example, legally, and according to Chief Legal Counsel interpretation, a type rated SIC may log PIC as sole manipulator. There's no HR department in the business that will look at a SIC logging sole manipulator in a transport category airplane under Part 121, as legitimate. The universal response is "it doesn't pass the smell test," and "if he didn't sign for it, he wasn't the PIC." That's the industry response, but it's legally incorrect.

We know that one can log PIC, yet not be PIC. We know that one can be PIC, and yet not be legally able to log PIC. We know that one can fly a single pilot aircraft and be entitled to log PIC, and to log SIC, all depending on circumstance. So far as the logging of flight time, and how it relates to hiring departments and HR personnel, it's subjective, and can't be considered a legal issue; it's whatever the hiring personnel think is right. That falls back to opinion, conjecture, convention, and frequently, misunderstandings. It's more about the way the general opinion leans.

When a pilot shows up for a job, having flown at ACMI carrier XXX Cargo, and has been doing long haul, wide-body international flying, he's got two thousand hours as SIC. He hasn't created a column in his logbook called "time I spent in a bunk asleep with a mask over my face, but was logging SIC." Nobody does that, because it's pointless, and stupid. My first question would be how the personnel at the company where the SIC applies for his next job, know the SIC was in a bunk at all, or what portion of a flight he was in the bunk.

Certainly if the SIC at XXX Cargo was a typical "IRO" or "Relief Captain," or whatever the flavor of the day title is, he was still a second in command, and logged second in command, though he may have conducted most of each flight from the left seat. Or the right seat. Or maybe in the IRO seat...but as he hasn't logged it that way, but only as SIC, how and why might the prospective company to which he is applying know? How might they dispute that which is not in evidence, and how would they know where he was sitting or what he was doing when that time was logged?

A review of the pilot's 121 records will show that he flew as SIC during those periods. The 121 operator XXX Cargo, will have recorded SIC Extrordinaire Johnny Beegood as SIC, and they'll have used his block time as his flight time of record, because block time and flight time are the same under the interpretations of the regulation. Therefore, if XXX Cargo has record of Johnny Begood flying two thousand hours as SIC, XXX Cargo won't have it broken down into bunk time, seat time, pilot time, coffee time, lav time, or any other classification. Just two thousand hours of SIC experience with XXX Cargo.

Now, the prospective company to which Johnny Begood is applying, might ask "how much of this time did you really fly, and how much did you spend laying in a bunk looking at a centerfold duct taped to the underside of the bunk above?" Johnny Begood might be stupid enough to say "Well, that would be eight hundred ninety seven hours, sir, and in my defense, she was nice," but then Johnny would be an idiot.

Johnny was a legitimately assigned crew member, cited on the flight release under Part 121 as second in command, and all of his block hours (flight time) are cited as his cumulative 121 hours. All of those hours (flight time, time aloft, block hours) counted toward his flight time limitations under 121. It was considered commercial flying. He didn't stop being a crew member if he got up to go visit the lav, make some coffee, or sat down in another seat. If the flight violated an altitude, or went below minimums, or took off with open write-ups, Johnny is still on the hook legally as a crewmember during that time. If one crew member files as ASAP report to seek protection under the program, all crewmembers, including Johnny, must complete the report, else they aren't covered. Again, Johnny is still a crew member, and still a SIC. He may have been sitting in the right seat. Or the left seat. Or the IRO seat. Or just sitting on his thumbs. But he was still a SIC, and that's what he will log, as that's what he's entitled to log, and that's what he did for the flight. He was a SIC. There may be more than one SIC...many times a captain may fly with several SICs in some operations. He logs SIC.

What if Johnny was assigned IRO for a flight, but immediately after takeoff, the right seater got up and went in back, and Johnny spent four hours in the right seat, flying? Then the captain left, the other F/O came back, and Johnny moved to the left seat and occupied that for four hours. Is he unable to log time because he was assigned IRO duties? Of course not. He's still a SIC. If he gets out of that left seat and returns to his IRO desk for another four hours, is he unable to log those four hours? He's still a SIC assigned on the flight release on a 121 flight. His duty is still accruing as a bona fide crewmember on a 121 flight, and all of that time aloft/flight time counts as commercial flying for the purposes of 121. He will also log it as SIC.

What if Johnny is assigned as SIC, but sits in the right seat and does nothing? The captain was flying, but the IRO handled all the radio calls. Is Johnny unable to log that time? He was SIC, in a pilot seat, but did nothing. Does that make him ineligible? Of course not. He logs the time. Can the IRO log the time? Yes, he can. Will he? Almost certainly. Will the company show the duration of the flight as flight time as SIC, for both Johnny, and his IRO? Yes, of course. If sometime goes wrong, are they both on the hook as required crewmembers? Yes, they are.

I've yet to see anyone carefully divide up the time spent in left seat, then right seat, the lavatory, then checking cargo, then in a bunk, then in a courior seat, then at the IRO desk, then pacing back and forth, then checking the cooler and then warming dinner...to see just how much they could log. That time aloft as a required crew member is what they'll log, because that's exactly what they did; made a flight as a required crewmember, assigned by a 121 certificate holder.
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Old 03-03-2021, 06:39 AM   #37  
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One additional item. If Johnny is SIC and spends a couple of hours in the bunk, does he not get paid FO pay for all the hours? Or is he unpaid for the time in the bunk?

if he gets paid for being a FO during the entire flight, why not log all the hours. . .
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Old 03-03-2021, 06:51 AM   #38  
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One additional item. If Johnny is SIC and spends a couple of hours in the bunk, does he not get paid FO pay for all the hours? Or is he unpaid for the time in the bunk?

if he gets paid for being a FO during the entire flight, why not log all the hours. . .
Because the specifics of oneís contract has nothing to do with the FARs.
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Old 04-28-2021, 11:38 PM   #39  
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Hello all,

I'm currently a CPL holder operating as widebody cruise-relief co-pilot aka "Second Officer" for a foreign carrier, interested in obtaining an FAA ATP. I hold a "cruise relief type rating", which as far as I can see, the training syllabus is very similar to that of an FAA SIC type rating.

I don't seem to be able to find a clear answer as to how to log time as cruise relief (as per the FAA interpretations, with the intention of obtaining the minimums for an FAA ATP). The answers I've seen online so far, range from:

a) the entire block time as "SIC"
b) the time spent in seat as "SIC", but the entire block time as "total time"
c) only the time spent in seat as "SIC"
d) only the time spent in seat as "total time"
e) none of the time

Does anyone have experience in this regard as to what the FAA considers time that count towards the 1500 hour ATP minimum (or any other resources/contacts I could ask)? Thanks
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