FAA not accepting SIC time towards ATP min.
 

Recently we've been hearing a lot about the FAA not crediting an F/O's SIC time with their airline toward the 100 PIC Cross Country requirement for the ATP/upgrade. Has anyone encountered this personally yet?

If so, has your company told you you're on your own to get the PIC XC (i.e. rent a 172 on your days off)? Has anyone's company given them any word about it at all?

I hear that has been corrected very recently. Sic time will now be counted towards ATP. I believe there's another thread you can read into here.

I heard rumors about this years ago, but like most rumors never knew anyone personally it happened to.

you get credit for the total NOT PIC. ATP PIC is just that. better rent that cessna,

I know it's currently happening at PDT and I believe PSA might be having an issue with it too.

Good thing I was furloughed for three years and had to flight instruct I guess eh?

Heh. Heh.

You can get your ATP, you just have the ICAO restriction on it. Meaning you can't fly to Canada/Mexico/Internationally until you meet the ATP requirements. Once you meet the requirements you can have the restriction removed.

"(d) An applicant is issued an airline transport pilot certificate with the limitation, "Holder does not meet the pilot in command aeronautical experience requirements of ICAO," as prescribed under Article 39 of the Convention on International Civil Aviation, if the applicant does not meet the ICAO requirements contained in Annex 1 "Personnel Licensing" to the Convention on International Civil Aviation, but otherwise meets the aeronautical experience requirements of this section."

55. FLIGHT EXPERIENCE REQUIREMENTS FOR THE AIRPLANE CATEGORY. Each applicant for an ATP certificate in an airplane category rating must meet each of the following seven experience requirements.

A. Total Pilot Flight Hours. A minimum of 1,500 total pilot flight hours must have been accumulated by the applicant. The following types of flight experience may be credited toward the total pilot flight hour requirement:

All pilot-in-command (PIC) hours

All dual instruction received by the applicant

All flight time acquired as a second-in-command (SIC) in aircraft requiring at least two pilots by the approved airplane flight manual (AFM), airworthiness certificate, or in FAR Part 121 or 135 operations

For commercial pilots, up to 500 hours of flight engineer (FE) time acquired in FAR Part 121 operations (The FE time must have been acquired in an airplane requiring an FE. While acquiring these hours, the applicant must have held a commercial pilot certificate and been participating as a pilot or FE in a FAR Part 121 approved pilot training program. FE time may be credited at a rate of 1 hour of pilot time for each 3 hours of FE time. For example, if the applicant has accumulated 300 hours of FE time, 100 hours may be credited toward the 1,500 total pilot hour requirement.)

B. Hours as PIC. The applicant must have accumulated at least 250 hours an PIC. SIC hours acquired while performing the duties of PIC under the supervision of a qualified PIC may be credited toward this requirement.

C. Hours of Cross-Country. At least 500 flight hours must have been accumulated as a pilot in cross-country flight. Cross-country time is that time acquired during flight from a departure point to a destination point that is not the same as the departure point. It is also time acquired in a flight that is cross-country in nature even though the departure and destination points are the same (such as forestry patrol).

D. Hours of PIC Cross-Country. At least 100 flight hours must have been accumulated as PIC while conducting cross-country flight. SIC hours while performing the duties of PIC under the supervision of a qualified PIC may be credited toward this requirement.

E. Hours at Night. At least 100 hours must have been accumulated as a pilot at night. An applicant who has made over 20 night landings may thereafter substitute one additional night takeoff and landing to a full stop for 1 hour of nighttime.

F. Hours as PIC at Night. At least 25 hours must have been accumulated as a PIC at night. SIC hours while performing the duties of PIC under the supervision of a qualified PIC may be credited toward this requirement.

G. Instrument Hours. At least 75 hours must have been accumulated as a pilot in actual or simulated instrument conditions. Fifty hours of this time must have been in actual flight.

Wow, so sad, actually requiring new ATPs to have experience as pilot in command.

Yea cuz 250 hours of flying a single engine cessna in circles around your local airport is really going to impact your ability to command a regional aircraft. Make no mistake, any F/O requiring additional hours will do exactly that, although it may be a piper cub instead of a cessna.

It sure will. Being in command, making decisions, and handling unforeseen circumstances is a skill-set you can gain in any type of aircraft.

Most people who say flying a Cessna around is worthless are the people who never flew Cessnas around. Going out there, making a few dumb decisions, scaring yourself a few times, and having to get yourself out of tricky situations is invaluable and will be very handy to have experience at as a PIC on an RJ.

Kids today....
 

Wow; lots of integrity flying your "Cessna" around in a circle to meet x/c requirements. Here's a hint; getting out of the local traffic pattern and actually experiencing some of the GA universe makes you a much better AVIATOR, vs. just being a button-pusher in an RJ. If you had done some of that we wouldn't need to explain the difference to you.:(

I don't understand how people don't get this. How could more flying time not make one an overall better pilot? A pilot who goes out and rents a Cessna for 100 hours is going to be a better pilot overall than before he had those 100 hours. The only way to get PIC experience is to act as PIC, as an RJ FO it is impossible to get that experience.

We've never had any issues with it. We just make sure there is a logbook signoff for SIC as PIC time if used to meet the minimum requirements.

Anyone who has this problem, must have been blessed in their aviation career. The idea that someone even made it to an sic position without 250 hours of pic time makes me jealous, but they also had to fly at least 190 hours for their commercial. I would thank you could get 100 hours of airport to airport time in.

Item B assumes you are rated to act as PIC. Most FO are not type rated on their aircraft. This reg works fine for guys in the right seat of a King Air 200 that doesn't require a type rating. To log PIC you must be rated in the aircraft, and an SIC type (ICAO) doesn't cut it. The FAA is slowly updating thier CMO's and FSDO's.

At our regional affiliate they will not accept SIC time towards the PIC requirement.

I'm not in this predicament, but I have several friends who are and I'm looking for people with FIRST HAND experience in the matter.

I understand many people have opinions but I'm just looking for answers and not snide remarks. Thank you.

I wasn't even thinking about the logging PIC as a SIC part. I just assumed that most people have at least a 100hrs of X-C PIC before they make it to a regional.

Plenty of the train wrecks where I work that went to PFT places don't.

This is an interesting predicament. To get their commercial they would have needed at least 50 hours of XC PIC and that is over 50 nm. the xc requirement for atp is just landing somewhere different from where you took off. They must have some of that from other times in their flying progression. So it cant be THAT much time.

As far as what the company will say/do....well that depends on the company and how many people you talk to in the company.

ATP XC time is minimum 50NM but a landing is not required. You are thinking of the Pt135 definition.

I've never known anybody with a few hundred hours or more in a SE Cessna that just "flew circles" around an airport, and I doubt you do either.

Some pt. 141 programs have way less than 50 hours cross country. I don't remember exactly how much I had when I got my commercial but it was significantly less.

When I first started instructing years ago I received a student from another instructor that was nearing his commercial checkride(pt. 61). We did a cross country and when we were doing his logbook after the flight he had more cross country time than I did!

Interesting! Does the Captain need to sign the FO's logbook now?

Says a lot about the current experience level of many "airline pilots" if we are even having this discussion.

It all depends on which examiner you talk to if you can get a ATP on your own. Each DE interprets the regs differently. Some will give you the atp with restrictions if you don't yet meet the 250 pic or 100 xc pic. Some will want a note signed by captains you've flown with saying: you have X hours under his supervision to meet the pic requirements to hold the atp with no restrictions. And some DE will just give you the atp as long as you are sic 121 with no kind of hassles. You got to find out who is in your area, and talk with them and worst case scenario come to an agreement on what to do. The FAA writes rules with gray interpretations, and each DE does whatever the heck they feel is right. Aviation is messed up in the USA.

sad but true. :eek:

Thanks for you insights! I was once a DPE and just curious how they will handle documentation of this type of flying.

I have been researching and this is what I have found too. At first I was uncomfortable with using SIC time toward the ATP PIC requirement because I talked to one guy at my FSDO and they said people who do that are getting their ATP illegally. Some DPE's interpret...

(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;


....as a way to use SIC for the required ATP PIC mins. Many argue that you must have a PIC type rating and not just an SIC type rating but these people can't prove it. Fact is, it just says "aircraft for which the pilot is rated". No one can just jump in the right seat of a CRJ without a rating. There is a difference with logging PIC and acting as PIC. Just because a guy with only an SIC type rating is logging PIC under this regulation doesn't mean he is acting as PIC or rated to act as PIC. He is rated to act as SIC and is allowed to log PIC when he is the sole manipulator of the controls for an aircraft he is rated in. Just like a student logging PIC while doing a dual commercial lesson with his instructor who is also logging PIC and is the designated PIC for the flight.

Basically I'm saying this regulation does not specify PIC type rating or SIC type rating so to say you need a PIC type would just be making up words that aren't actually in the regulation. Thus making you wrong to assume something like that.

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.

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'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 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.

One more thought. Like you said, it boils down to whether or not you are actually rated in the aircraft with the SIC type rating.

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.