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ATP/250PIC Part121

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Old 12-02-2014, 12:56 PM
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Default ATP/250PIC Part121

Can "supervised sic" part 121 time be used towards the 250 pic requirement? So far Ive called the faa and local fsdo and they couldnt tell me! I have done some research and it looks like it might??? I have about 1500 hours sic in a crj from 6 years ago. Been out if 121 since then but considering coming back. Problem is that I really only have 180 PIC. ATP written was done this past July. Thank You!
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Old 12-02-2014, 03:01 PM
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I know that 61.159(a)(5) has been used by at least one regional (prior to the 1500 hour rule) to get FO's who were hired with low time up to ATP mins. That was done in coordination with the CMO, authorized and documented by the airline.

If you're going to employ this rarely-used rule...

Discuss it with the relevant FSDO.

Don't try to "retroactively" claim that you were "SIC performing the duties of PIC" during your previous 121 gig. You weren't, and you can't prove that you were.

Get the PIC to agree in advance, log it as such, and get his signature...or whatever documentation the FSDO wants.

Don't try to do this without the owner/operator's permission. I know a 121 CA who got fired because he was letting FO's do this and signing their books without company authorization. The issue was that he wasn't a check airman.

I don't recall hearing of this rule being applied outside 121, but there's nothing that says you couldn't do it while flying 91 so if you can get a 91 SIC job you could probably knock it out that way. Or just go CFI or traffic watch for a couple months.

Again don't try to do this retroactively...unless maybe you're REALLY good buds with a CA you flew with back then and can get him to sign your book. But the FAA would consider that fraud I'm sure, and your buddy would be on the hook too.
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Old 12-02-2014, 04:43 PM
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Thanks Rick. I was just searching some more, and I see that some don't even mention the 250 PIC as a requirement, some say "supervised SIC", and some say 250 PIC is required. This is probably why the FAA and FSDO sounded so confused when I spoke to them. Just to clarify: In order to get hired by a regional (part 121), as an FO, I would have to have the 250 PIC...Does that sound correct?
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Old 12-02-2014, 04:44 PM
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...Just to clarify as I re-read my post: When I say "some", I am referring to articles that I googled, not airlines.
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Old 12-02-2014, 05:53 PM
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The FARs still allow supervised PIC to count towards the PIC required for an ATP. It looks black and whote to me.

Technically, Feds and DPEs should be onboard with the concept but it's so rare I wouldn't bet on it...or show up for a checkride expecting them to just "be good with it".

For either a 91 checkride, or an airline checkride, let them know well in advance that you plan to count this kind of time, and let them know how it's documented. That will give them the time to get educated and get back to you if they have any concerns...sort it all out before the checkride (91) or starting class (121).
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Old 12-02-2014, 06:21 PM
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My company asked no questions about the counting SIC time as the required PIC time. Although, they had to do over 1000 people's ATPs in 6 months so they were used to it. Couldn't tell you how many needed it, but likely in the dozens. Didn't ask for PIC signatures or approval. They just assumed at least half of the SIC was your leg.
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Old 12-03-2014, 05:11 AM
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So, I guess the question would be: Would any potential part 121 regional be willing to blindly accept my previous sic time as "supervised", since it all occured prior to the new ATP rules and I have no sign-off's saying such. Hmmm...???
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Old 12-03-2014, 07:49 AM
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Originally Posted by Zookie View Post
So, I guess the question would be: Would any potential part 121 regional be willing to blindly accept my previous sic time as "supervised", since it all occured prior to the new ATP rules and I have no sign-off's saying such. Hmmm...???
You'll have to ask each airline, but I'd also have a personal conversation with the CMO...if everybody's good with it then go for it. I would say start with the CMO...that way you can tell the airline that you already got CMO approval, and tell them who gave it.

I have a suspicion that the intent of that rule is NOT to let every FO count half of their SIC towards the ATP. At the one airline where I saw this happening the company gave specific authorization on a case-by-case basis and logbooks were signed. So they did not consider SIC time to be automatically eligible...it had to be "premeditated". The FO's actually acted like the CA, and the CA only intervened if necessary.

But if some legit powers-that-be are going to interpret it that way, then you may as well take advantage of it before they change their minds...I think if the CMO approves it, then I doubt it could come back and haunt you.

If you really want to be anal, write the FAA and ask for an interpretation...but you may not like the answer you get.
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Old 12-03-2014, 10:32 AM
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Thanks again Rick for your knowledge and insight. Guess ill see how it plays out!
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