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DiveAndDrive 12-28-2017 11:17 AM

1000 hours TPIC vs Regional
 
Hello everyone! I'm posting this in the Major forum, because I am wondering what option would be my best bet to get to a major.

I'm currently under a contract flying Cessna Caravans on part 135 essential air service routes. My contract ends late summer/early fall 2018. I should be upgrading to captain in February or March. By the time my contract expires, I should be having about 4-600 hours TPIC. I know it's single engine turbo prop time, on an aircraft that is essentially a large 182. But it is still TPIC nonetheless.

My question to y'all, is should I stay at the 135 operation for probably 6 months or so after my contract expires to get that 1000 hours TPIC, or should I go to a regional ASAP? I'm really torn on it, as are most of my coworkers. About half says go to the regional asap, upgrade in 18-24 months, and start building 121 ME Turbojet TPIC. The other half says that an additional 6 months isn't that big of a deal to get 1000 hours TPIC, just to be able to "check that box". Some of my coworkers are even inclined to say that you can go right seat from a regional to right seat at a major if you get the 1000 hours TPIC time at my current company. I think that might be a little far fetched, but I really don't know. That's why I'm asking for everyone's opinions, please and thank y'all. I hope everyone had a Merry Christmas, and a happy new year!!

Otterbox 12-28-2017 11:33 AM


Originally Posted by DiveAndDrive (Post 2490805)
Hello everyone! I'm posting this in the Major forum, because I am wondering what option would be my best bet to get to a major.

I'm currently under a contract flying Cessna Caravans on part 135 essential air service routes. My contract ends late summer/early fall 2018. I should be upgrading to captain in February or March. By the time my contract expires, I should be having about 4-600 hours TPIC. I know it's single engine turbo prop time, on an aircraft that is essentially a large 182. But it is still TPIC nonetheless.

My question to y'all, is should I stay at the 135 operation for probably 6 months or so after my contract expires to get that 1000 hours TPIC, or should I go to a regional ASAP? I'm really torn on it, as are most of my coworkers. About half says go to the regional asap, upgrade in 18-24 months, and start building 121 ME Turbojet TPIC. The other half says that an additional 6 months isn't that big of a deal to get 1000 hours TPIC, just to be able to "check that box". Some of my coworkers are even inclined to say that you can go right seat from a regional to right seat at a major if you get the 1000 hours TPIC time at my current company. I think that might be a little far fetched, but I really don't know. That's why I'm asking for everyone's opinions, please and thank y'all. I hope everyone had a Merry Christmas, and a happy new year!!

I know several FOs who’ve gotten calls from legacies and LCCs without having 1000TPIC... they had no TPIC that I’m aware of. They had between 2 and 5 years on property as an FO and played the game hard to get the opportunities they were presented with though. YMMV.

It seems that the rules of thumb as to what majors are looking for change ever 12 months, or when someone new takes over hiring for a company....

You can skin the cat a couple ways. You should be able to upgrade to CA at any of the AA Wholly Owned regionals within 12-18 months on property. There’s enough attrition coming from the top at them to keep upgrade times low for the foreseeable future. I don’t think sticking it out at your current job for an extra 6 months will hurt you, but I wouldn’t want to get stuck with an additional 12 month training contract for recurrent etc.

Do what you want but don’t stay much longer than it takes to get your 1000hrs TPIC if that’s what you want to do. I don’t think 1000 SE TPIC time will be valued nearly as much as part 121 ME TPIC time though.

Sliceback 12-28-2017 03:50 PM

Leave.

The FO’s getting hired at majors aren’t getting hired because they have X hrs of Caravan PIC.

PilotJ3 12-28-2017 05:08 PM

GO to the RJs...

I was hired at Dal after 6 years with my regional without TPIC. I have a friend got hired with only 4 years in the RJs.

Just remember, start doing networking and going to job fairs once you feel competitive. Getting hired at the majors/legacies is a job on top of your regular job.

cynicalaviator 12-28-2017 05:25 PM

I was in the same position you were and I decided to stay to get 1000 TPIC. Times were different but since you are already logging TPIC I would still stay until you get 1000. I understand the value of seniority but 6 months is not such a long time. It's true that a legacy could hire you without 1000 TPIC. They've also hired without a 4 year degree. But the odds will be against you.
I would get 1000 TPIC and then become an RJ FO. That way, you can start applying as soon as you get 1000 TPIC and keep updating your app as you fly right seat RJ. The chance that you will get a call is slim but at least you will officially meet their minimums (Though I imagine they don't all require TPIC. You'd have to check what the current competitive requirements are.)
If you don't and go straight to RJ FO, you will be able to apply but without 1000 TPIC, your chances of getting called will be slim. (if current competitive requirements require TPIC). Without the TPIC, you will be just like the other thousands of RJ FO's.

CaptSwift 12-28-2017 08:26 PM

I’ve seen the term “crew environment” TPIC for getting hired at a couple of the majors..

I was in the same boat and moved on. Glad I did not stay as clearly a 135 Caravan driver is not as valuable as 121 experience.

Rama 12-28-2017 10:34 PM

Go to a 121 carrier. Upgrade times are pretty short.

Sliceback 12-29-2017 05:33 AM

If you’re a young guy, and will end up in the top 1000 at a major, a six month delay will cost you $200-250K.

Single pilot, small SEL, TPIC, non 121, isn’t a big plus for an applicant applying to a major airline.

dera 12-29-2017 06:03 AM


Originally Posted by Sliceback (Post 2491208)
If you’re a young guy, and will end up in the top 1000 at a major, a six month delay will cost you $200-250K.

Single pilot, small SEL, TPIC, non 121, isn’t a big plus for an applicant applying to a major airline.

This *2. When they SAY TPIC, what they mean, is turbojet crew environment TPIC.
Caravan time isn't what they are looking for there.

DiveAndDrive 12-30-2017 06:51 AM

I'm 23 with no college degree, if that helps at all. Yes. I will get my degree. I know that's a must. I am currently looking at/researching a few online universities. My plan is to get the degree online while I fly, whether that's at my current airline or a regional.

And I understand what everyone is saying about a 121 crew environment. I'm not trying to make excuses, but we do operate our Caravans with two pilots. Yes, I know it's single pilot certified, but it is in our OpSpecs for two pilots.

Let me ask this. Maybe as a "compromise" of sorts, do you think I should get 500 PIC at my current operator? I should have about 5-6 months on my contract after I upgrade, so worst case scenario, it would only take an additional month after my contract to get 500 PIC.

rickair7777 12-30-2017 07:09 AM

ASEL TPIC will not get you hired at a major.

But once you get some 121 jet time, that TPIC might push you over the top. I have seen RJ FOs with prop TPIC get called.

I'd probably take the quickest path that will get you to 4k TT and 1000 TPIC .

155mm 12-30-2017 07:19 AM


Originally Posted by DiveAndDrive (Post 2491889)

Let me ask this. Maybe as a "compromise" of sorts, do you think I should get 500 PIC at my current operator? I should have about 5-6 months on my contract after I upgrade, so worst case scenario, it would only take an additional month after my contract to get 500 PIC.

How much does a Captain make versus a 121 RJ FO? Understandable that finances have a lot to do with it! Some Regionals are offering recruitment bonuses for current 135 Captains as well. Other than that, unless your PIC turbine is in a single engine fighter ie: F-16, probably not much advantage to get on with a major. However, I have seen Caravan Feeder guys leave to the non-scheds flying international heavies but perhaps those days are gone as well. Most certainly work on your college degree!

Hacker15e 12-30-2017 07:45 AM

Remember, what the majors have been looking for is multi turbine PIC.

There are a few exceptions to this (ergo, military single-engine fighters), but Caravan time doesn't fit the bill.

Get to the regionals ASAP -- that's going to be your fastest path to the majors. The 121 time/experience is going to be far more valuable than the 135 ASEL time.

DiveAndDrive 12-30-2017 07:52 AM

Hey Howitzer, I'll be making 43/hr as a captain at my outfit.

DiveAndDrive 12-30-2017 07:52 AM

Also, I appreciate everyone's input. It sounds like the regional is the best choice. Thank you all for your input!

Sliceback 12-30-2017 10:58 AM

Free $.02 - you’re gaining experience at your current job. It’s bumping your TT. It will do little for your resume at a major. The learning curve has flattened out. Move on. The regional FO time will have more value. The sooner you get regional FO the sooner you upgrade. That has the most value. And if you go to a regional with a guaranteed flow the sooner you’d flow.

Short answer? Leave ASAP (1430-1500 hrs TT)

Guys getting hired avg 5000-7500 TT and 3000-4000 PIC. Put your foot on the gas and keep it floored. Take new opportunities, new type ratings, upgrade, CKA, flight department or union work. NONE of that is happening sooner or faster by continuing in a non 121 job, especially a Caravan, after you can move on (1500 hrs).

Sliceback 12-30-2017 11:01 AM

AA regionals with guaranteed flow don’t require a degree.
That said, you’d be silly to not get a degree. It provides opportunities at other airlines outside of the AA flow and is the foundation of a backup plan, or the path to a masters, if you lose your medical.

El Pilot 12-30-2017 07:38 PM

In my opinion the Caravan is a good way to build turbine PIC time if you are within 1000-1500 hour range. Once you get 1500, you should apply to regionals if 121 major's are your goal.

dera 12-31-2017 12:54 PM


Originally Posted by DiveAndDrive (Post 2491889)
And I understand what everyone is saying about a 121 crew environment. I'm not trying to make excuses, but we do operate our Caravans with two pilots. Yes, I know it's single pilot certified, but it is in our OpSpecs for two pilots.

What's the OpSpec for two pilots in a caravan? You mean your GOM?

Are you logging your VFR SIC Caravan time (I assume some of your flying is VFR?) It's not loggable even if your GOM makes you a "required crewmember", SIC time is only loggable if you are required by a regulation or aircraft type certificate, neither is true for VFR Caravan flying.
I know someone who got badly burned by this.

DiveAndDrive 12-31-2017 04:58 PM

It's zero VFR flying. Obviously if weather is permitting, we fly VMC. But all of our flights are IFR take off to touchdown. In fact, we're not even allowed to cancel IFR in the air. So if you're ever flying into a uncontrolled airport in the Midwest and have to hold because of us, sorry. :p

dera 12-31-2017 07:25 PM


Originally Posted by DiveAndDrive (Post 2492857)
It's zero VFR flying. Obviously if weather is permitting, we fly VMC. But all of our flights are IFR take off to touchdown. In fact, we're not even allowed to cancel IFR in the air. So if you're ever flying into a uncontrolled airport in the Midwest and have to hold because of us, sorry. :p

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 01-01-2018 07:44 AM


Originally Posted by dera (Post 2492718)
What's the OpSpec for two pilots in a caravan? You mean your GOM?

Are you logging your VFR SIC Caravan time (I assume some of your flying is VFR?) It's not loggable even if your GOM makes you a "required crewmember", SIC time is only loggable if you are required by a regulation or aircraft type certificate, neither is true for VFR Caravan flying.
I know someone who got badly burned by this.

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 01-01-2018 08:15 AM


Originally Posted by Sliceback (Post 2491208)
If you’re a young guy, and will end up in the top 1000 at a major, a six month delay will cost you $200-250K.

Single pilot, small SEL, TPIC, non 121, isn’t a big plus for an applicant applying to a major airline.

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

rickair7777 01-01-2018 08:51 AM


Originally Posted by 86BravoPapa (Post 2493132)
At what age is 'young guy' not applicable anymore in aviation?

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 01-01-2018 08:56 AM


Originally Posted by rickair7777 (Post 2493154)
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.

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

dera 01-01-2018 10:15 AM


Originally Posted by rickair7777 (Post 2493106)
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.

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 01-01-2018 02:14 PM


Originally Posted by dera (Post 2493208)
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.)

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 01-01-2018 02:16 PM


Originally Posted by 86BravoPapa (Post 2493157)
Thanks, I haven't seen a breakdown like that before. Oh how I wish I could've started training at 21 vs. 31.

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 01-01-2018 02:41 PM


Originally Posted by rickair7777 (Post 2493361)
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.

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 01-01-2018 03:13 PM

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.

Frankie Avalon 01-01-2018 03:20 PM

Best explanation I've ever heard:

If the FO called out sick an hour before departure, could the flight still depart as planned with just the PIC and be legal under that part? If yes, the FO isn't a required crewmember in the eyes of the FAA. If not, they are.

Insurance requirements, owner requirements, company procedures, et al, are irrelevant here. For logging time, the FAA only cares whether you're a legally required crew member under the FAR Part which the flight is operating.

Having the correct Op spec helps here because a Part 135 Ops Manual is FAA approved and considered regulatory. You could log legal SIC time in the right seat of a 172 with the proper 135 Op spec, but not in the right seat of some Citation's without it. Seems silly, but them's the breaks.

dera 01-01-2018 03:26 PM


Originally Posted by Frankie Avalon (Post 2493408)
Best explanation I've ever heard:

If the FO called out sick an hour before departure, could the flight still depart as planned with just the PIC and be legal under that part? If yes, the FO isn't a legally required crewmember. If no, they are.

Insurance requirements, owner requirements, company procedures are irrelevant to this. For logging time, the FAA only cares whether you're a legally required crew member under the FAR Part which the flight is operating.

Having the correct Opspec helps here because a Part 135 Ops Manual is FAA approved and considered regulatory.

GOM is ACCEPTED, not APPROVED. Huge difference.

I don't know of an OpSpec that defines that SIC is required, because it is required by the regulation under certain conditions. Circumventing this requirement is what OpSpecs are issued for.

In 99% of cases, even if GOM says two pilots required, the flight could LEGALLY depart with just one pilot, but it is COMPANY POLICY to cancel the flight.

Frankie Avalon 01-01-2018 03:39 PM


Originally Posted by dera (Post 2493414)
GOM is ACCEPTED, not APPROVED. Huge difference.

The FAA considers the language regulatory. It's not a huge difference.


Originally Posted by dera (Post 2493414)
I don't know of an OpSpec that defines that SIC is required, because it is required by the regulation under certain conditions. Circumventing this requirement is what OpSpecs are issued for.

In a lot of cases, yeah. But there exist OpSpecs that require an SIC for 135 ops.


Originally Posted by dera (Post 2493414)
In 99% of cases, even if GOM says two pilots required, the flight could LEGALLY depart with just one pilot, but it is COMPANY POLICY to cancel the flight.

Nosireebob. If a 135 GOM requires an SIC, with no provisions for single pilot 135, the flight cannot legally depart 135 without one. Doing so would constitute a violation, as the GOM is FAA blessed and considered regulatory.

dera 01-01-2018 03:42 PM


Originally Posted by Frankie Avalon (Post 2493424)
The FAA considers the language regulatory. It's not a huge difference.



In a lot of cases, yeah. But there exist OpSpecs that require an SIC for 135 ops.



Nosireebob. If a 135 GOM requires an SIC, with no provisions for single pilot 135, the flight cannot legally depart 135 without one. Doing so would constitute a violation, as the GOM is FAA blessed and considered regulatory.

State your source please. I haven't found a regulation or legal interpretation that says so, but it does not mean there is no such letter. You clearly know of one.

Also, what nr is that OpSpec that requires an SIC for 135?

GOM specifically is NOT regulatory, every GOM preface I've read says this:

"The procedures and policies contained herein supplement the regulations and are considered
essential to good operational practices and safety. If a question of applicability arises, the FARs shall
prevail."

Frankie Avalon 01-01-2018 04:02 PM


Originally Posted by dera (Post 2493425)
State your source please. I haven't found a regulation or legal interpretation that says so, but it does not mean there is no such letter. You clearly know of one.

Also, what nr is that OpSpec that requires an SIC for 135?

GOM specifically is NOT regulatory, every GOM preface I've read says this:

"The procedures and policies contained herein supplement the regulations and are considered
essential to good operational practices and safety. If a question of applicability arises, the FARs shall
prevail."

It's more about choosing to omit 135.105 from the Opspecs. Which admittedly, most operators don't because it grants them flexibility. It would be uncommon. But that further highlights my original point about logging legal SIC time.

As far as a GOM being regulatory or not, I don't have a specific source other than what's burned into my brain from years of 135 and common sense. Why would the FAA go to the trouble of "accepting" a 135 GOM if the operator could simply disregard anything they chose for the sake of convenience? A 135 GOM is like an addendum to the FAR's for the company it's issued to. You can't operate 135 legally without complying with it. That's like the whole reason there is a Part 135. The certificates are issued case-by-case, and subject to compliance with the GOM and the Opspecs contained therein. Of course you aren't going to supersede the FAR's with it. There's a hierarchy of applicability, and FAR's are always on the top. But an FAA accepted GOM for a 135 Op regulates that operation in addition to the ordinary FAR's.

dera 01-01-2018 04:12 PM


Originally Posted by Frankie Avalon (Post 2493433)
It's more about choosing to omit 135.105 from the Opspecs. Which admittedly, most operators don't because it grants them flexibility. It would be uncommon. But that further highlights my original point about logging legal SIC time.

As far as a GOM being regulatory or not, I don't have a specific source other than what's burned into my brain from years of 135 and common sense. Why would the FAA go to the trouble of "accepting" a 135 GOM if the operator could simply disregard anything they chose for the sake of convenience? A 135 GOM is like an addendum to the FAR's for the company it's issued to. You can't operate 135 legally without complying with it. That's like the whole reason there is a Part 135. The certificates are issued case-by-case, and subject to compliance with the GOM and the Opspecs contained therein.

OpSpecs are cookie cutter documents, every OpSpec has a number and they are standardized across the board. They are not custom written to an operator.

You do not "omit 135.105 from the OpSpecs", you have A015 OpSpec that you use with 135.105 to allow passenger carrying IFR without an SIC.

The problem is, you are stating the "commonly believed" way of thought, but it is not supported by any legal interpretations or regulations. It has some merit, but it is not 100% clear how it is interpreted. The problem is the wording in 61.51(f)(2), it only allows for "or the regulations under which the flight is being conducted." - There is no REGULATION under Part 135 that makes SIC a required crewmember apart from 135.101 (and CatII operations etc but they are beyond the scope here). 135.105 with A015 allows but does not mandate operating without SIC (as Tarsa letter clearly says), but this is all for passenger operations. For cargo, SIC is never required by regulations.

Again - you have an opinion, a common one, but it is not an FAA opinion, it is an interpretation on what GOM and regulations are TRYING to say, and that is not a solid foundation when dealing with the FAA.

I think someone should ask for an interpretation of this, because reading the regs to the letter, SIC time is not loggable per 61.51(f) most of the time.

rickair7777 01-01-2018 06:53 PM

You guys can settle this definitively... write a letter to FAA legal.

But the answer might make you some enemies...

dera 01-01-2018 07:07 PM


Originally Posted by rickair7777 (Post 2493544)
You guys can settle this definitively... write a letter to FAA legal.

But the answer might make you some enemies...

I've thought about it but I agree, you might become the most hated man in 135 world, when everyone refers to your surname as the reason they can't log SIC...

If the letter is worded correctly, it might yield a favorable response. But I don't think I'll risk it.
"Don't ask questions you might not like the answer for".

But I think discussion about this is useful, folks often go with the "common opinion" without understanding the regs (or lack of them) behind those opinions.

At least that way they can be better prepared if someone questions the hours they have logged.


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