dera

And no autopilot use? And you fly passengers? Then you should be good to go If it's cargo, or you use autopilot, it's worth doing your due diligence on the regs - GOM is accepted, not approved. GOM requiring 2 pilots does not necessarily mean SIC is a required crewmember per 61.51(f)(2), because there is no regulation requiring it.

rickair7777

Actually, SIC is legit if your OPSPEC (which is approved by the FAA) requires an SIC for the operation in question. This applies even if the regulation or type cert does not require an SIC.

But an OPSPEC requirement is the ONLY legal way to log SIC in a single-pilot plane.

These do NOT allow legal logging of SIC or any flight time in a single pilot plane...
- Company Policy
- Rich guy boss asks for a second pilot
- Insurance Requirements
- Unreasonable flight training (ie you can reasonably do a couple fam flights as dual, but you cannot log 800 hours dual received to get around the lack of requirement for an SIC).


Also important to note that while it's very common to do repo legs under 91, an SIC required by the 135 OPSPEC cannot log SIC on 91 legs. Either the leg is flown 135 (often a rest/duty problem), or the SIC must serve as PIC for that leg. The later only works if the actual PIC doesn't care about accumulating PIC, and the insurance company is OK with it. Don't log PIC if someone else is designated PIC for the insurance company.

86BravoPapa

At what age is 'young guy' not applicable anymore in aviation?

rickair7777

Rough estimate, age when hired by major vs. MONTHLY value of one month at career end (today's dollars)...

20's: $40K
30's: $29K
40's: $29K
50's: $25K
Late 50's: $16K

Obviously lots of variables, assumes non-aggressive bidding, ie not chasing every dollar.

86BravoPapa

Thanks, I haven't seen a breakdown like that before. Oh how I wish I could've started training at 21 vs. 31.

dera

Exactly my point, it needs to be an OpSpec - not a "requirement" in GOM which most of these actually are.

What is the OpSpec number that would specify this? I've never seen an OpSpec requiring two pilots for single pilot plane, only GOM that specifies that. And GOM is not approved, it's accepted, and thus not strictly regulatory.

I think this is a grey area and neither the Nichols nor Tarsa letters sufficiently cover this scenario.

I know a Caravan "SIC" who got badly burnt by this (as in - logged up to 1500 hours, quit his job, went through 121 training and wasn't issued an ATP because 1000 hours of his time was 208 "SIC" time.)

rickair7777

I thought GOM was good enough, that's been the conventional wisdom for a long time. Not familiar enough with 135 OPSPEC to say where it be, if at all. But FAA legal can, and does, cast doubt on long-standing assumptions.

rickair7777

Now with that being said, that's hypothetical money, assumes you get a major job, don't medical out, die, or get fired. And the industry survives in something similar to it's current form.

Depending on your finances, $2k might be more important to you today than $40k will be in 30 years.

But the general principle is don't delay grabbing a seniority number when things are moving fast (they are).

dera

OpSpecs are "cookie cutter" numbered letters that approve the certificate holder to conduct certain operations. For example, to conduct IFR with autopilot in lieu of SIC, you need an OpSpec for it (A015 in this case). A015 allows you to operate this way, but does not mandate every flight will be conducted this way (this is in the Tarsa interpretation). So - SIC is "required" when _carrying passengers_ under Part 135 IFR. Cargo, SIC is not required for that.

GOM is accepted, not approved. You can require a crew of 2 in a 172 in your GOM, but it definitely does not make the SIC a required crewmember "by regulation or aircraft type certificate".

In my opinion, this would need an opinion from FAA legal - if correctly worded, it might even come back with a favorable opinion. Current interpretations aren't clear on this.

Most two pilot single pilot plane (Caravan, PC12) 135 operations log SIC time "illegally", relying only on the long-standing assumption but with no support from FAA legal interpretations or the FARs.
I know someone who destroyed two years of his career by this. He was not a happy camper.
This mainly affects 135 cargo (135 cargo IFR does not require SIC by regs), and 135 passenger VFR ops (135 passenger carrying IFR requires SIC or Autopilot, unclear if you can operate with autopilot and SIC).

As a 135 SIC, you can legally log PIC time for the legs you are pilot flying, but the pilot monitoring "SIC" legs, better know exactly what the regs say and know to defend your logbook if someone starts asking uncomfortable questions.

dera

Other side of the argument would be, that 135.21(b) says about the GOM that "This manual must be used by the certificate holder's flight, ground, and maintenance personnel in conducting its operations.", so indirectly GOM might be seen as regulatory requirement.

All in all, I'm just trying to say the "common assumption" is not necessarily correct in this case. Don't go to your ATP ride saying "oh it's in GOM so it's valid", you might be burnt.

This can get pretty complicated, here's my situation as a PC12 SIC;

All of our flying is international, and ICAO Annex 9 requires a crew of "no fewer than" number of crew required in the OM of the certificate holder, and since international ops fall partly under ICAO rules (and the countries AIM GEN1.7 has no exceptions from these where we operate), (this is why single pilot waivers aren't valid outside the US for example), I consider all of my time loggable because an SIC is required by the rules under which we operate internationally.