Connect and get the inside scoop on Airline Companies

Welcome to Airline Pilot Forums - Connect and get the inside scoop on Airline Companies

If this is your first visit, be sure to check out the FAQ. Join our community today and start interacting with existing members. Registration is fast, simple and absolutely free.


User Tag List

Post Reply
 
Thread Tools Search this Thread
Old 10-10-2011, 02:34 PM   #1  
Line Holder
Thread Starter
 
jbt1407's Avatar
 
Joined APC: Jul 2011
Position: moving along
Posts: 52
Default Another logging SIC question

I have read almost all the threads related to logging SIC time, but I was still wondering if you could log SIC in this specific situation.

The Metro III is a single-pilot certified aircraft. However, in order to be flown that way the aircraft must have a functioning autopilot and the PIC must have a single-pilot type PIC rating. If the aircraft does not have an autopilot, nor does the PIC have a single-pilot rating in the aircraft, then could the co-pilot log SIC time in a part 135 operation because he is technically a required pilot?

Thanks
jbt1407 is offline  
Old 10-11-2011, 05:55 AM   #2  
Gets Weekends Off
 
Whale Driver's Avatar
 
Joined APC: Nov 2010
Posts: 544
Default

I think you answered your own question.

Yes.
Whale Driver is offline  
Old 10-11-2011, 06:04 AM   #3  
Gets Weekends Off
 
NoyGonnaDoIt's Avatar
 
Joined APC: Nov 2008
Posts: 826
Default

Quote:
Originally Posted by jbt1407 View Post
The Metro III is a single-pilot certified aircraft. However, in order to be flown that way the aircraft must have a functioning autopilot and the PIC must have a single-pilot type PIC rating.
Who says so?

That's not intended to be sarcastic. It's a real question, the which makes a difference in the answer.

Id is part of the type certificate? Does a reg say so (like it's' being used to transport passengers IFR and subject to FAR 135.101 and 105)? Does the company OpSpec mandate the use of an autopilot. Is it an insurance company that insists on it? Is it a marketing choice by the company to make potential customers feel better. ,O, is it just that does Uncle Joe thinks it's a good idea?

Without knowing the source of the requirement, it's hard to answer your question.
NoyGonnaDoIt is offline  
Old 10-11-2011, 02:56 PM   #4  
Line Holder
Thread Starter
 
jbt1407's Avatar
 
Joined APC: Jul 2011
Position: moving along
Posts: 52
Default

Quote:
Originally Posted by NoyGonnaDoIt View Post
Who says so?

Id is part of the type certificate? Does a reg say so (like it's' being used to transport passengers IFR and subject to FAR 135.101 and 105)? Does the company OpSpec mandate the use of an autopilot. Is it an insurance company that insists on it? Is it a marketing choice by the company to make potential customers feel better. ,O, is it just that does Uncle Joe thinks it's a good idea?

Without knowing the source of the requirement, it's hard to answer your question.
I am not 100% sure what reg this it is based off, but you bring up a good point and I guess it would just depend on the situation. What i do know is that the plane is used by a night cargo outfit.

In retrospect, I guess the question should be, "How would potential future employers look at the time?"

Thanks to both of y'all for your replies.
jbt1407 is offline  
Old 10-11-2011, 03:28 PM   #5  
Gets Weekends Off
 
Whale Driver's Avatar
 
Joined APC: Nov 2010
Posts: 544
Default

jbt,

if you, the commercial AMEL pilot in the right seat are required to be there, be it the regulations or method which it is operated under then you are the SIC and should log it as such.


*************************************

Below is a letter from the FAA in response to the subject matter of your question. (I have removed the name and date)


*************************************

Thank you for your letter of April -,-----, in which you ask questions about logging pilot in command (PIC) and second in command (SIC) time when operating under Part 135 of the Federal Aviation Regulations (FAR). We apologize that staff shortages, regulatory matters, and interpretation requests received prior to yours prevented us from answering your questions sooner.

Your letter presents the following scenario: a Part 135 certificate holder conducts operations in multiengine airplanes under instrument flight rules (IFR). The operator has approval to conduct operations without an SIC using an approved autopilot under the provisions of FAR 135.105. The operator has assigned a fully qualified pilot, who has had a Part 135 competency check, to act as SIC in an aircraft that does not require two pilots under its type certification. Although FAR 135.101 requires an SIC for Part 135 operations in IFR conditions, the autopilot approval is an exception to that requirement.

You correctly state that while the SIC is flying the airplane, he can log PIC time in accordance with FAR 61.51(c)(2)(i) because he is appropriately rated and current, and is the sole manipulator of the controls. Additionally, he has passed the competency checks required for Part 135 operations, at least as SIC.

You then ask two questions. The first asks whether the pilot designated as PIC by the employer, as required by FAR 135.109, can log PIC time while the SIC is actually flying the airplane. The answer is yes.

FAR 1.1 defines pilot in command:

(1) Pilot in command means the pilot responsible for the operation and safety of an aircraft during flight time.


FAR 91.3 describes the pilot in command:

(a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft.

There is a difference between serving as PIC and logging PIC time. Part 61 deals with logging flight time, and it is important to note that section 61.51, Pilot logbooks, only regulates the recording of:

(a) The aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of this part.

FAR 61.51(c) addresses logging of pilot time:

(2) Pilot in command flight time. (i) A recreational, private, or commercial pilot may log pilot in command time only that flight time during which that pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or when the pilot is the sole occupant of the aircraft, or, except for a recreational pilot, when acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

(ii) An airline transport pilot may log as pilot in command time all of the flight time during which he acts as pilot in command.

(iii) (omitted).

(3) Second in command flight time. A pilot may log as second in command time all flight time during which he acts as second in command of an aircraft on which more than one pilot is required under the type certification of the aircraft, or the regulations under which the flight is conducted.

As you can see, there are two ways to log pilot in command flight time that are pertinent to your question. The first is as the pilot responsible for the safety and operation of an aircraft during flight time. If a pilot is designated as PIC for a flight by the certificate holder, as required by FAR 135.109, that person is pilot in command for the entire flight, no matter who is actually manipulating the controls of the aircraft, because that pilot is responsible for the safety and operation of the aircraft.

The second way to log PIC flight time that is pertinent to your question is to be the sole manipulator of the controls of an aircraft for which the pilot is rated, as you mention in your letter. Thus, a multiengine airplane flown under Part 135 by two pilots can have both pilots logging time as pilot in command when the appropriately rated second in command is manipulating the controls.

We stress, however, that here we are discussing logging of flight time for purposes of FAR 61.51, where you are keeping a record to show recent flight experience or to show that you meet the requirements for a higher rating. Your question does not say if the second pilot in your example is fully qualified as a PIC, or only as an SIC. This is important, because even though an SIC can log PIC time, that pilot has not qualified to serve as a PIC under Part 135.

An example of this difference is FAR 135.225(d), which raises IFR landing minimums for pilots in command of turbine powered airplanes flown under Part 135 who have not served at least 100 hours as PIC in that type of airplane. Served and logged are not the same in this context, and no matter how the SIC logs his time, he has not served as a PIC until he has completed the training and check rides necessary for certification as a Part 135 PIC.

Approval for single pilot operations with use of an operative approved autopilot system under FAR 135.105 gives an operator an additional option in the conduct of operations. It does not mandate that all future flights be conducted in that manner. The operator can elect to fly trips with two pilots, as is otherwise required for flight in IFR conditions under FAR 135.101, using the second in command instead of the autopilot.

Your second question asks if, under the circumstances given above, the SIC can log time as SIC when the designated pilot in command is flying the aircraft. The answer is yes, as long as the certificate holder is using the SIC as a crewmember instead of exercising the autopilot authorization. In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option, but rather conducts an IFR flight using two qualified pilots. The two pilots are then "required by the regulations under which the flight is conducted", FAR 61.51(c)(3), and the assumption is that the second pilot (SIC) will function as a required crewmember, and SIC time may validly be logged. However, if for some reason another qualified pilot "rides along" and does not function as a crewmember, then second in command time may not be validly logged.

This interpretation has been prepared by Arthur E. Jacobson, Staff Attorney, Operations Law Branch, Regulations and Enforcement Division; Richard C. Beitel, Manager. It has been coordinated with the Manager, Air Transportation Division, and the Manager, General Aviation and Commercial Division, Flight Standards Service.

We hope this satisfactorily answers your questions.

Sincerely,


Donald P. Byrne
Assistant Chief Counsel
Regulations and Enforcement Division
Whale Driver is offline  
Old 10-11-2011, 09:10 PM   #6  
Line Holder
Thread Starter
 
jbt1407's Avatar
 
Joined APC: Jul 2011
Position: moving along
Posts: 52
Default

Whale Driver,

Thank you for taking time to post this letter. Not only does it answer my question, but it solves many others that were still unclear to me.
jbt1407 is offline  
Old 10-12-2011, 04:45 AM   #7  
Gets Weekends Off
 
NoyGonnaDoIt's Avatar
 
Joined APC: Nov 2008
Posts: 826
Default

Quote:
Originally Posted by jbt1407 View Post
Whale Driver,

Thank you for taking time to post this letter. Not only does it answer my question, but it solves many others that were still unclear to me.
That opinion letter is extremely helpful, but understand it's limitations.
Quote:
Your letter presents the following scenario: a Part 135 certificate holder conducts operations in multiengine airplanes under instrument flight rules (IFR). The operator has approval to conduct operations without an SIC using an approved autopilot under the provisions of FAR 135.105. The operator has assigned a fully qualified pilot, who has had a Part 135 competency check, to act as SIC in an aircraft that does not require two pilots under its type certification. Although FAR 135.101 requires an SIC for Part 135 operations in IFR conditions, the autopilot approval is an exception to that requirement.
Go back to the question I asked about the source of the requirement for more than one pilot. In the case of this letter, it's 135.101
==============================
135.101 Second in command required under IFR.
Except as provided in 135.105, no person may operate an aircraft carrying passengers under IFR unless there is a second in command in the aircraft.
==============================

In other words, the scenario starts with an operation that requires an SIC and then points out that there is an exception that allows 1 pilot operation with an autopilot.

Hence my question to you: You mentioned that it was a cargo flight, so 135.101 doesn't apply. What is the source of a SIC requirement in your scenario?

Here's the rule on logging SIC:

==============================
61.51(f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:

(1) Is qualified in accordance with the second-in-command requirements of 61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or

(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft orthe regulations under which the flight is being conducted.
==============================

Since it's a single-pilot aircraft, 61.51(f)(1) doesn't apply. 61.51(f)(2) may if (using your scenario as an example), the type certification requires 2-pilot operations but only one with an autopilot. Similarly, an OpSpec might require two pilots if no autopilot.

The question remains the same; what's the 2-pilot requirement and what is it based on?
NoyGonnaDoIt is offline  
Old 10-12-2011, 08:46 AM   #8  
Line Holder
 
mwf008's Avatar
 
Joined APC: Feb 2009
Posts: 29
Default

The original post is incorrect. A Metro can be flown 135 single pilot without an autopilot.
mwf008 is offline  
Old 10-12-2011, 12:03 PM   #9  
Gets Weekends Off
 
Fly Boy Knight's Avatar
 
Joined APC: Oct 2009
Position: PT Inbound
Posts: 218
Default

Quote:
Originally Posted by mwf008 View Post
The original post is incorrect. A Metro can be flown 135 single pilot without an autopilot.
Passengers require an SIC or an AP in lieu of an SIC. No passengers (ie: cargo) then no SIC or AP is required.

Either way, PIC still needs a PIC Type Rating (No "SIC Required" limitation) to fly the plane 91, 121, 135, whatever

135.101 Second in command required under IFR.

Except as provided in 135.105, no person may operate an aircraft carrying passengers under IFR unless there is a second in command in the aircraft.
Fly Boy Knight is offline  
Old 10-13-2011, 03:25 AM   #10  
Gets Weekends Off
 
NoyGonnaDoIt's Avatar
 
Joined APC: Nov 2008
Posts: 826
Default

Quote:
Originally Posted by Fly Boy Knight View Post
Passengers require an SIC or an AP in lieu of an SIC. No passengers (ie: cargo) then no SIC or AP is required.
I think he was referring to what the type requires, not what the operation requires.

I had the same question myself. I know that Metros are (or at least have been) flown single pilot without an autopilot in cargo ops. That was part of the reason for the questions I asked about the source of the requirement.
NoyGonnaDoIt is offline  
 
 
 

 
Post Reply
 



Thread Tools Search this Thread
Search this Thread:

Advanced Search


Related Topics
Thread Thread Starter Forum Replies Last Post
Logging Actual dashtrash300 Aviation Law 2 09-21-2011 04:43 AM
New Private - question on logging PIC Agentessa Flight Schools and Training 18 11-20-2009 01:43 PM
Question for CRJ drivers on logging flight time Florida Flyer Regional 7 01-28-2008 04:19 PM
VLJ SIC question Sperl0863 Regional 20 12-27-2007 08:45 AM
Question about Logging PIC Turbinebound Regional 14 07-17-2006 11:36 AM


All times are GMT -8. The time now is 06:31 PM.