FAA not accepting SIC time towards ATP min.
01-28-2012, 09:15 AM
#31
Gets Weekends Off
Joined APC: Jun 2010
Posts: 442
Originally Posted by N42ER
I'm not saying I disagree that SIC time should count towards your ATP. I believe it should count, but not for this reason that you have a "type rating"...I just think that thousands of hours of SIC time should count for at least something.
I'm think you're confusing an "SIC type rating" with a real type rating- it's just not. Actually, anyone can jump in the right seat and fly as an SIC, without the "SIC type rating", you do not need this like you would a real type rating.
This formality was recently added within the past several years by the FAA for ICAO compliance for international travel, that's all, its just a paperwork technicality. So if you're not flying internationally (or have the potential to land at an airport in another country, like overflying Canada or something) you actually are fine to have a Commercial ticket with no "SIC type rating" (because it's not a true type rating).
I know that every FO out there has this "SIC type rating" but the truth is, you do not need any type rating to just sit right seat and fly as an SIC domestically in the US. The only reason they're issued is because of ICAO- you ONLY need it if you potentially will be going outside the US because ICAO requires it...and it's so easy to put on a certificate (since it's just paperwork, not a true rating) that most places just throw it on there.
If an airline application asks you to list the number of type rating you hold, are you really going to list that you hold "3 type ratings" just because you were an FO at a few regionals or something? A provision like the ICAO "SIC type rating" which has no real bearing in the US, has no practice test, and no written test associated with it, is just a formality for international regulatory compliance and is not something you can claim as qualifying you as "rated" on a plane requiring a type.
But hey, I could be wrong. Look into it, maybe I'm way off...but to me an "SIC type" means nothing, it's just your typical Commercial ticket with an ICAO stamp on it, for all intents and purposes- no real change in privileges from your commercial.
I'm think you're confusing an "SIC type rating" with a real type rating- it's just not. Actually, anyone can jump in the right seat and fly as an SIC, without the "SIC type rating", you do not need this like you would a real type rating.
This formality was recently added within the past several years by the FAA for ICAO compliance for international travel, that's all, its just a paperwork technicality. So if you're not flying internationally (or have the potential to land at an airport in another country, like overflying Canada or something) you actually are fine to have a Commercial ticket with no "SIC type rating" (because it's not a true type rating).
I know that every FO out there has this "SIC type rating" but the truth is, you do not need any type rating to just sit right seat and fly as an SIC domestically in the US. The only reason they're issued is because of ICAO- you ONLY need it if you potentially will be going outside the US because ICAO requires it...and it's so easy to put on a certificate (since it's just paperwork, not a true rating) that most places just throw it on there.
If an airline application asks you to list the number of type rating you hold, are you really going to list that you hold "3 type ratings" just because you were an FO at a few regionals or something? A provision like the ICAO "SIC type rating" which has no real bearing in the US, has no practice test, and no written test associated with it, is just a formality for international regulatory compliance and is not something you can claim as qualifying you as "rated" on a plane requiring a type.
But hey, I could be wrong. Look into it, maybe I'm way off...but to me an "SIC type" means nothing, it's just your typical Commercial ticket with an ICAO stamp on it, for all intents and purposes- no real change in privileges from your commercial.
01-28-2012, 10:17 AM
#32
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Joined APC: Apr 2007
Position: Captain
Posts: 90
Originally Posted by CrakPipeOvrheat
What was that last thing you said after "SIC type...."? Was it "rating"? Get my point. I found a whole CFR about "sic type rating". It is actually called that you don't have to put quotes around it like it doesn't exist. Look it up it refers to ICAO and the changes the FAA made in order to be consistent with ICAO.
I think that SIC time should somehow be weighed into the ATP requirements, but not by wholly agreeing that SIC time is akin to PIC since now they both have a rating. You simply cannot log PIC without a PIC type rating (aircraft not requiring a type rating excluded, of course). I don't think it's the case that an SIC, as you say, "...is allowed to log PIC when he is the sole manipulator of the controls for an aircraft he is rated in". The question boils down to whether you are really rated or not, as SIC only.
The original reg you quoted mentioned a provision for pilots operating aircraft, "...for which the pilot is rated...", but how can you cite this as justification when the SIC rating's uses are clearly and specifically restricted to SIC privileges only? I would argue that you are not rated (to log PIC) in kind of the same way that you are not rated to fly left seat in a 747, even with a PIC type for a CRJ. The restrictions are key. Kind of like with the 747 type, your priviges are essentaiily restricted to the 747...yes a CRJ requires "a type rating", and as a 747 type holder you meet that criteria since do have "a type rating", but that doesn't mean you qualify. You need to include all of the details outlined on the type rating, such as specific aircraft, or PIC vs SIC. I would say that for any purpose, other than specifically operating as SIC, you are not rated for an aircraft with just an SIC type.
You also said that, "No one can just jump in the right seat of a CRJ without a rating". Is this true? I was under the impression that someone could theoretically go start an airline flying CRJs tomorrow and fly strictly within the lower 48 of the US and have their FO's simply have their Commercial MEL; can they not? This would be legal- the CRJ does not require both pilots to be type rated in the aircraft, only that the PIC hold a type rating, as far as I can tell. I've definitely been wrong before, so please correct me if I am wrong here.
So if these things were what you were basing your argument on, then I'm not sure if it still holds up. I'm not trying to be a jerk about it, I'm just throwing it out there for the sake of argument that even though you make some good points, I just don't think your interpretation is correct on this particular issue.
Please don't take this the wrong way. I may be totally wrong, and maybe your FSDO is wrong too. I'm just making some counter points for discussion's sake because it's probably a good discussion to have.
Last edited by N42ER; 01-28-2012 at 11:36 AM.
01-28-2012, 12:35 PM
#33
Gets Weekends Off
Joined APC: Jun 2010
Posts: 442
Originally Posted by N42ER
I'm confused. Are you saying that since it's technically a "rating" (the quotes here are a purposeful denotation of a categorical difference between the rating to which I'm referring in this statement (the recently invented SIC-restricted type rating) and the other traditional ratings; the ones where you take a check ride, etc.) then an SIC can log PIC with it somehow?
I think that SIC time should somehow be weighed into the ATP requirements, but not by wholly agreeing that SIC time is akin to PIC since now they both have a rating. You simply cannot log PIC without a PIC type rating (aircraft not requiring a type rating excluded, of course). I don't think it's the case that an SIC, as you say, "...is allowed to log PIC when he is the sole manipulator of the controls for an aircraft he is rated in". The question boils down to whether you are really rated or not, as SIC only.
The original reg you quoted mentioned a provision for pilots operating aircraft, "...for which the pilot is rated...", but how can you cite this as justification when the SIC rating's uses are clearly and specifically restricted to SIC privileges only? I would argue that you are not rated (to log PIC) in kind of the same way that you are not rated to fly left seat in a 747, even with a PIC type for a CRJ. The restrictions are key. Kind of like with the 747 type, your priviges are essentaiily restricted to the 747...yes a CRJ requires "a type rating", and as a 747 type holder you meet that criteria since do have "a type rating", but that doesn't mean you qualify. You need to include all of the details outlined on the type rating, such as specific aircraft, or PIC vs SIC. I would say that for any purpose, other than specifically operating as SIC, you are not rated for an aircraft with just an SIC type.
You also said that, "No one can just jump in the right seat of a CRJ without a rating". Is this true? I was under the impression that someone could theoretically go start an airline flying CRJs tomorrow and fly strictly within the lower 48 of the US and have their FO's simply have their Commercial MEL; can they not? This would be legal- the CRJ does not require both pilots to be type rated in the aircraft, only that the PIC hold a type rating, as far as I can tell. I've definitely been wrong before, so please correct me if I am wrong here.
So if these things were what you were basing your argument on, then I'm not sure if it still holds up. I'm not trying to be a jerk about it, I'm just throwing it out there for the sake of argument that even though you make some good points, I just don't think your interpretation is correct on this particular issue.
Please don't take this the wrong way. I may be totally wrong, and maybe your FSDO is wrong too. I'm just making some counter points for discussion's sake because it's probably a good discussion to have.
I think that SIC time should somehow be weighed into the ATP requirements, but not by wholly agreeing that SIC time is akin to PIC since now they both have a rating. You simply cannot log PIC without a PIC type rating (aircraft not requiring a type rating excluded, of course). I don't think it's the case that an SIC, as you say, "...is allowed to log PIC when he is the sole manipulator of the controls for an aircraft he is rated in". The question boils down to whether you are really rated or not, as SIC only.
The original reg you quoted mentioned a provision for pilots operating aircraft, "...for which the pilot is rated...", but how can you cite this as justification when the SIC rating's uses are clearly and specifically restricted to SIC privileges only? I would argue that you are not rated (to log PIC) in kind of the same way that you are not rated to fly left seat in a 747, even with a PIC type for a CRJ. The restrictions are key. Kind of like with the 747 type, your priviges are essentaiily restricted to the 747...yes a CRJ requires "a type rating", and as a 747 type holder you meet that criteria since do have "a type rating", but that doesn't mean you qualify. You need to include all of the details outlined on the type rating, such as specific aircraft, or PIC vs SIC. I would say that for any purpose, other than specifically operating as SIC, you are not rated for an aircraft with just an SIC type.
You also said that, "No one can just jump in the right seat of a CRJ without a rating". Is this true? I was under the impression that someone could theoretically go start an airline flying CRJs tomorrow and fly strictly within the lower 48 of the US and have their FO's simply have their Commercial MEL; can they not? This would be legal- the CRJ does not require both pilots to be type rated in the aircraft, only that the PIC hold a type rating, as far as I can tell. I've definitely been wrong before, so please correct me if I am wrong here.
So if these things were what you were basing your argument on, then I'm not sure if it still holds up. I'm not trying to be a jerk about it, I'm just throwing it out there for the sake of argument that even though you make some good points, I just don't think your interpretation is correct on this particular issue.
Please don't take this the wrong way. I may be totally wrong, and maybe your FSDO is wrong too. I'm just making some counter points for discussion's sake because it's probably a good discussion to have.
Last edited by CrakPipeOvrheat; 01-28-2012 at 12:48 PM.
01-28-2012, 03:56 PM
#34
Gets Weekends Off
Joined APC: Jun 2010
Posts: 442
Originally Posted by CrakPipeOvrheat
I get what your saying and I see where you are coming from but for me my interpretation and the interpretation of the DPE doing my checkride is all that matters. Fact is, people can, and do earn ATP certificates using the SIC sole manipulator towards the PIC requirement. I'm not 100% sure about jumping into the right seat of a CRJ without a rating. You say you cannot log PIC without a PIC type rating. I can show you where it says I can log the PIC. Can you show me where it says I can't? In your first paragraph you imply that an SIC rating doesn't require a checkride. Where do you get that from? You say it is not a traditional rating. What is the definition of a "traditional rating"? It is in printed clear as day in my mind. It says if you are the sole manipulator of the controls and you are rated in that aircraft you can log PIC. You can argue that I don't have a PIC type rating. I am not acting as PIC on a CRJ with an SIC type rating. You must be thinking of the part of the regs that talks about what is required to act as PIC and not the section I'm referring to which is about logging PIC. Acting as PIC as apposed to Logging PIC. Two different things. Logging of PIC is to comply with requirements for certificates. Acting as PIC is the pilot ultimately responsible for the flight and has the final say. I'm not going to take this PIC time to an airline interview and present it as PIC turbine time. I will present it as SIC turbine. I am just using it to get my ATP.
1.1 General Definitions
Rating means a statement that, as a part of a certificate, sets forth special conditions, privileges, or limitations.
I believe and some DPE's believe you are. Others don't. The idea that you are not rated in the aircraft just because you are restricted to SIC privileges only is bologna. It is true you not allowed to be the PIC on a CRJ flight but it does not restrict you from logging PIC in accordance with 61.51.
Last edited by CrakPipeOvrheat; 01-28-2012 at 04:11 PM.
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