When to log SIC (King Air)
#11
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Joined APC: Mar 2008
Posts: 152
TCDS A24CE specifies an optional 10 or more Part 135 seating configuration for the B200 so i guess that is more a combination of regulation and aircraft configuration. Also, FF serial numbers of the 300 require two pilots.
#12
As an aisde to that - it is actually changing where the FF serial numbered aircraft, IF HAVING THE PL21 STC, will revert back to single pilot capability at least in the eyes of the FSB; but our OPSECS will still require two pilots.
Appreciate the insight uboat.
#13
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Joined APC: Jan 2013
Position: Pitot heat, what's to eat?
Posts: 392
rickair7777 pretty much nailed it, I was doing 91 stuff and didn't know anything about 135 work until I had flown 85 hours at which time I stopped logging the time I flew with them. Ops Specs don't require a 2nd pilot unless the autopilot is broken, and not 135 check was given. I don't even want to log 91 legs as PIC because I was just there swinging the gear and radios/flying occasionally so don't know the systems that well. I think my best option is making one logbook entry and taking out all that time. Luckily no ATP ride was taken so I can get 25 hours instructing fairly quickly and have ATP mins. Ill probably rewrite my logbook because I don't think I can stand a messy logbook forever.
There is more to be said on this issue (much more) but in the end the fact is you don't want to be arguing legal nuance in an interview or in front of an FAA inspector. I have personally witnessed applicants rejected outright for having just a few hours of logged King Air time when they were not qualified.
I will say a few words about the nuance... the 135 autopilot exemption *allows* the operator to operate without an SIC but does not require them to. The SIC can still be considered "required" if they simply elect not to utilize the exemption for that flight. IF you had been trained and taken an SIC checkride *then* you could have logged it. Without the checkride, you were a passenger on the 135 legs. And logging the 91 legs CAN be legal but it's a minefield as has been previously discussed... you shouldn't both log PIC, and nobody can log SIC. You might log dual received if the PIC was a CFI and signed your logbook for dual given. But airlines generally want PIC time to mean that you were qualified and in command, so best to not try to find the loopholes.
#14
Gets Weekends Off
Joined APC: Mar 2008
Posts: 152
I don't know what the TCDS A24CE is but thanks for the information about all the FF serial numbers requiring two pilots. I had to research that but now I know a little bit more
As an aisde to that - it is actually changing where the FF serial numbered aircraft, IF HAVING THE PL21 STC, will revert back to single pilot capability at least in the eyes of the FSB; but our OPSECS will still require two pilots.
Appreciate the insight uboat.
As an aisde to that - it is actually changing where the FF serial numbered aircraft, IF HAVING THE PL21 STC, will revert back to single pilot capability at least in the eyes of the FSB; but our OPSECS will still require two pilots.
Appreciate the insight uboat.
#15
If you have a restriction for SIC required.
When I was at Flight Safety for Initial 350 type there were several people who were getting a type rating where a second in command was required and flew as a crew. My type was single pilot Part 91 and I was in the Sim alone, both training and check ride. I did have a 25 hour OE requirement per regs and 100 hours of type rated safety pilot per insurance though. If an SIC is not required legally it can't be logged as such but is still experience that no one can take away from you.
When I was at Flight Safety for Initial 350 type there were several people who were getting a type rating where a second in command was required and flew as a crew. My type was single pilot Part 91 and I was in the Sim alone, both training and check ride. I did have a 25 hour OE requirement per regs and 100 hours of type rated safety pilot per insurance though. If an SIC is not required legally it can't be logged as such but is still experience that no one can take away from you.
#16
New Hire
Joined APC: Aug 2016
Posts: 6
Logging SIC in the B-350
Hello,
Long time listener, first time caller looking for some clarification on logging flight time in the B-350. Former military pilot, ATP, and recently earned my B-300 rating with single piloted qualification. New to Part 91 flying, the King Air, and the rules governing flying with more than one pilot in the cockpit. Posting this request for info because there seems to be a lot of opinion about logging SIC time in the B-300 series aircraft even though it's classified by the FAA as a single piloted aircraft. I am a contract pilot for a Part 91 company that flies mostly international sorties for them. Company policy requires pilots to have a single pilot qualification on their rating and mandates 2 pilots in the aircraft during all operational flights. PIC and SIC responsibilities are designated for each flight on the daily flight schedule. To my knowledge, this 2 pilot requirement is company policy and does not exist as an OPSPEC//MSPEC with the FAA. PICs are usually swapped every other flight to spread the love. The way I read the regs, company mandate alone doesn't validate logging SIC in a single piloted aircraft, especially with 2 single pilot qualified, rated, and current pilots at the controls. ... But many of my co-workers whose opinions I respect and admire have differing opinions and log SIC time in the B-350 - citing company policy as justification.
Was looking for:
1) empirical data (source document references) to validate or refute their assumptions.
2) if unable to legitimately log SIC, guidance on logging flight time, night time, instrument time, and approaches when manipulating the controls as a co-pilot/SIC for currency.
3) if logging SIC is determined to be legit in the B-350 based on the company operating manual, am I required to have a "SIC type rating" under ICAO rules when acting as SIC in international airspace (not required in the US) ... Or does my single pilot qualification on my B-300 type rating infer a SIC rating as well.
Again thanks for reading and any help you could provide would be appreciated.
V/r,
AvgJoe
Long time listener, first time caller looking for some clarification on logging flight time in the B-350. Former military pilot, ATP, and recently earned my B-300 rating with single piloted qualification. New to Part 91 flying, the King Air, and the rules governing flying with more than one pilot in the cockpit. Posting this request for info because there seems to be a lot of opinion about logging SIC time in the B-300 series aircraft even though it's classified by the FAA as a single piloted aircraft. I am a contract pilot for a Part 91 company that flies mostly international sorties for them. Company policy requires pilots to have a single pilot qualification on their rating and mandates 2 pilots in the aircraft during all operational flights. PIC and SIC responsibilities are designated for each flight on the daily flight schedule. To my knowledge, this 2 pilot requirement is company policy and does not exist as an OPSPEC//MSPEC with the FAA. PICs are usually swapped every other flight to spread the love. The way I read the regs, company mandate alone doesn't validate logging SIC in a single piloted aircraft, especially with 2 single pilot qualified, rated, and current pilots at the controls. ... But many of my co-workers whose opinions I respect and admire have differing opinions and log SIC time in the B-350 - citing company policy as justification.
Was looking for:
1) empirical data (source document references) to validate or refute their assumptions.
2) if unable to legitimately log SIC, guidance on logging flight time, night time, instrument time, and approaches when manipulating the controls as a co-pilot/SIC for currency.
3) if logging SIC is determined to be legit in the B-350 based on the company operating manual, am I required to have a "SIC type rating" under ICAO rules when acting as SIC in international airspace (not required in the US) ... Or does my single pilot qualification on my B-300 type rating infer a SIC rating as well.
Again thanks for reading and any help you could provide would be appreciated.
V/r,
AvgJoe
Last edited by AvgJoe; 08-31-2016 at 06:05 AM. Reason: Spelling
#17
1) The source document is FAR 61.51(f), which is pretty crystal-clear. If you peruse FAA legal interpretations, I suspect they have provided some additional clarity on this at some point.
2) The FAA actually does not define "Total Time", so legally you can log anything you want in that column, including time flying RC airplanes or sleeping in first-class on your way to europe for vacation. But potential employers will generally not appreciate creative interpretations in your logbook.
Logging currency and conditions of flight gets tricky in this case, I think I know the answer but don't have time to look up right now so maybe I'll update this later.
3) I believe that a PIC type is good to act as SIC in all cases. 135/121 typically provide seat-specific training but I don't think FAA type ratings are seat-specific at all. Airlines frequently use relief pilots, all of whom have PIC types, who rotate among seats on international flights. You cannot hold both an FAA SIC and PIC type to my knowledge.
The underlying issue here is that the employer has not provided a clear and legal path to log your flight time. If you're doing the job just to make money, that's OK. If you're doing the job to build flight time then there are two problems...
- The employee needs to understand and comply with FAA time logging rules, primarily because that is the standard potential employers expect. Technically you can log anything you like, as long as you use only FAA-legal flight time for currency and 8710's. But good luck explaining that at an airline interview.
- Employers should be up-front about time logging legalities in their type of operation. Too often they gloss over these issues, and the pilot (especially ex-mil) only finds out when he gets called on it at an airline interview. Trust me, ALL of these 135 employers know the rules cold...what you have to ask yourself is why are they not honest about it with you?
2) The FAA actually does not define "Total Time", so legally you can log anything you want in that column, including time flying RC airplanes or sleeping in first-class on your way to europe for vacation. But potential employers will generally not appreciate creative interpretations in your logbook.
Logging currency and conditions of flight gets tricky in this case, I think I know the answer but don't have time to look up right now so maybe I'll update this later.
3) I believe that a PIC type is good to act as SIC in all cases. 135/121 typically provide seat-specific training but I don't think FAA type ratings are seat-specific at all. Airlines frequently use relief pilots, all of whom have PIC types, who rotate among seats on international flights. You cannot hold both an FAA SIC and PIC type to my knowledge.
The underlying issue here is that the employer has not provided a clear and legal path to log your flight time. If you're doing the job just to make money, that's OK. If you're doing the job to build flight time then there are two problems...
- The employee needs to understand and comply with FAA time logging rules, primarily because that is the standard potential employers expect. Technically you can log anything you like, as long as you use only FAA-legal flight time for currency and 8710's. But good luck explaining that at an airline interview.
- Employers should be up-front about time logging legalities in their type of operation. Too often they gloss over these issues, and the pilot (especially ex-mil) only finds out when he gets called on it at an airline interview. Trust me, ALL of these 135 employers know the rules cold...what you have to ask yourself is why are they not honest about it with you?
Last edited by rickair7777; 08-31-2016 at 08:01 AM.
#18
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Joined APC: Apr 2007
Posts: 867
#19
New Hire
Joined APC: Aug 2016
Posts: 6
Rickair7777,
Thanks for the response and reference. With regard to logging SIC time, I think that the end of FAR 61.51 paragraph (f)(2) is vague and open to interpretation when a company's operating manual requires two pilots in a single piloted aircraft to execute their operations. The exact verbiage of that passage is "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 OR THE REGULATIONS UNDER WHICH THE FLIGHT IS BEING CONDUCTED." FAR 61.55 para (a) regarding SIC qualifications isn't much clearer in my opinion, stating "a) A person may serve as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember oOR IN OPERATIONS REQUIRING A SECOND-IN-COMMAND PILOT FLIGHT CREWMEMBER...." If I knew the intent of the regulation I think it would be easier to interpret as intended. Any insights?
Regarding logging SIC flight time, THINK
I'll stick with the same way I did it in the military - logging first pilot time whenever I am the sole manipulator of the controls, whether designated PIC or not. Realize that's not an official FAA term. I'll use this time for flight, instrument, night, approach and landing currency and count toward total turboprop time (essentially 'PIC logged'). Designated PIC time will go into my logbook as Aircraft Commander time (i.e. PIC Actual) to align with my military flight time entries and airline application expectations. Got the ATP and hours for the airlines, so I will log the right seat non-flying time in my logbook as Pilot Monitoring time as a record of B-300 experience but not include in any airline apps or total flight time. That keeps me away from the SIC ambiguity issue, documents my experience, but only credits stick time as a rated pilot in the aircraft.
Thanks again for the help,
AvgJoe
Thanks for the response and reference. With regard to logging SIC time, I think that the end of FAR 61.51 paragraph (f)(2) is vague and open to interpretation when a company's operating manual requires two pilots in a single piloted aircraft to execute their operations. The exact verbiage of that passage is "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 OR THE REGULATIONS UNDER WHICH THE FLIGHT IS BEING CONDUCTED." FAR 61.55 para (a) regarding SIC qualifications isn't much clearer in my opinion, stating "a) A person may serve as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember oOR IN OPERATIONS REQUIRING A SECOND-IN-COMMAND PILOT FLIGHT CREWMEMBER...." If I knew the intent of the regulation I think it would be easier to interpret as intended. Any insights?
Regarding logging SIC flight time, THINK
I'll stick with the same way I did it in the military - logging first pilot time whenever I am the sole manipulator of the controls, whether designated PIC or not. Realize that's not an official FAA term. I'll use this time for flight, instrument, night, approach and landing currency and count toward total turboprop time (essentially 'PIC logged'). Designated PIC time will go into my logbook as Aircraft Commander time (i.e. PIC Actual) to align with my military flight time entries and airline application expectations. Got the ATP and hours for the airlines, so I will log the right seat non-flying time in my logbook as Pilot Monitoring time as a record of B-300 experience but not include in any airline apps or total flight time. That keeps me away from the SIC ambiguity issue, documents my experience, but only credits stick time as a rated pilot in the aircraft.
Thanks again for the help,
AvgJoe
#20
New Hire
Joined APC: Aug 2016
Posts: 6
Deadstick35,
Extremely helpful post. Only unanswered question for me now is what 'regulation' the lawyer is referring in the passage "the regulations under which the flight is being conducted." Does that refer to the company's internal operating regulations (where my company mandates two pilots in a single piloted aircraft during most operations) or OPSPEC agreements with the FAA.
Thanks for posting,
AvgJoe
Extremely helpful post. Only unanswered question for me now is what 'regulation' the lawyer is referring in the passage "the regulations under which the flight is being conducted." Does that refer to the company's internal operating regulations (where my company mandates two pilots in a single piloted aircraft during most operations) or OPSPEC agreements with the FAA.
Thanks for posting,
AvgJoe
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