Logging King Air 350
#21
Gets Weekends Off
Joined APC: Jul 2013
Posts: 460
The 135 regs REQUIRE an SIC for Passenger carrying IFR ops. A company Opsspec may give the opportunity to use he autopilot in lieu of an SIC.
The OPSSPECS are a database of possible company rules. Whether or not the company decides (or is authorized to use them) is a coordinated decision between said company and the FAA (the company POI). For example, if two companies have the Autopilot in lieu of SIC authorization, it will be the same number (A015).
The OPSSPECS are a database of possible company rules. Whether or not the company decides (or is authorized to use them) is a coordinated decision between said company and the FAA (the company POI). For example, if two companies have the Autopilot in lieu of SIC authorization, it will be the same number (A015).
#22
Disinterested Third Party
Joined APC: Jun 2012
Posts: 6,006
135.105 allows the use of an autopilot in lieu of a SIC, if operations specifications are issued to that certificate holder allowing such. Even where such opspecs exist, the operator may elect to use a SIC under an approved training program, in accordance with 135.101.
No change at all, and if SIC's under 135 have experience that they've used toward their ATP, it's no threat to them. SIC's have long been required under IFR under 135. It's not the opspec that requires the SIC. It's the SIC that may be used by the certificate holder to eliminate the SIC.
Where do you find an allowance in 61.51 that enables one to log time based on what a private company invents? Where's the allowance for that?
If the company operates under Part 135 and actually has operations specifications issued, that's one thing...but there's no provision in Part 135 that sets the requirement for a SIC. That's found in 135.101.
The original poster isn't working for a 135 company. No opspecs.
A private company operating under Part 91 can make up their own policies; they can even call them "operations specifications," if they want. It doesn't make them an FAA approved document, and doesn't establish any allowance under the regulation pertinent to the logging of time. A private company may set their own requirement for a SIC; this does not entitle one to log SIC.
If you believe otherwise, show it in the regulation.
The OpSpecs under 135 provide an allowance to not use a SIC, by using an autopilot in lieu of a SIC.
The allowance for the OpSpecs to do this is found in 135.105.
A SIC is required under 135. OpSpec authorization for single pilot with autopilot may be issued, but with a training program for SICs, the company may still use a SIC because it's a basic requirement under 135, Operations Specification not withstanding.
If your internal company regs require an SIC, then I would log SIC, as you are Acting, and being paid, to be one. I would lose no sleep over this, as long as you could articulate it in the interview. Are you being paid to sit in the seat ? Does the company provide training or issue SOP's for your actions in that seat? Then I would log it accordingly. My two cents.
There is no allowance under the regulation that allows the logging of SIC based on an "internal company reg."
An applicant who shows up for an interview claiming time logged that isn't loggable shows ignorance of the regulation. When the applicant is found to be claiming time that he or she cannot claim, the applicant looks foolish. The applicant's overall time diminishes, as does his or her experience. Can he or she still meet the job minimums?
There is no provision in the regulation for logging time because one is "paid to be in the seat." If you know of such a regulation cite it.
There is no provision in the regulation for logging time simply because a company provides training, unless that training program is approved under Part 121 or 135. If you're aware of such a regulation, cite it.
There is no provision in the regulation for logging time simply because "company SOP's" dictate that a SIC be on board. If you're aware of such a regulation, cite it.
Last edited by JohnBurke; 02-11-2016 at 08:17 PM.
#23
It's not like there aren't other situations where there is a difference between "acting as" and "logging". I can name a few others right off the bat. That's what the regulations are. I may not agree with it completely, but that doesn't matter, I don't get to make the regulations.
#24
Gets Weekends Off
Joined APC: Feb 2015
Position: Begging for a crew meal
Posts: 233
It's a Part 91 operation. There are no operations specifications. Are you suggesting that the company can invent their own and apply them under the regulation?
Where do you find an allowance in 61.51 that enables one to log time based on what a private company invents? Where's the allowance for that?
If the company operates under Part 135 and actually has operations specifications issued, that's one thing...but there's no provision in Part 135 that sets the requirement for a SIC. That's found in 135.101.
The original poster isn't working for a 135 company. No opspecs.
A private company operating under Part 91 can make up their own policies; they can even call them "operations specifications," if they want. It doesn't make them an FAA approved document, and doesn't establish any allowance under the regulation pertinent to the logging of time. A private company may set their own requirement for a SIC; this does not entitle one to log SIC.
If you believe otherwise, show it in the regulation.
Where do you find an allowance in 61.51 that enables one to log time based on what a private company invents? Where's the allowance for that?
If the company operates under Part 135 and actually has operations specifications issued, that's one thing...but there's no provision in Part 135 that sets the requirement for a SIC. That's found in 135.101.
The original poster isn't working for a 135 company. No opspecs.
A private company operating under Part 91 can make up their own policies; they can even call them "operations specifications," if they want. It doesn't make them an FAA approved document, and doesn't establish any allowance under the regulation pertinent to the logging of time. A private company may set their own requirement for a SIC; this does not entitle one to log SIC.
If you believe otherwise, show it in the regulation.
In this situation, I would agree that SIC time is unloggable unless the PIC has a crew stipulation attached to their licence.
This is why I've always kept two columns in the logbook. Basically "Logged PIC" (sole manipulator) and "Actual PIC" When asked what the total PIC time is - I respond with the "Actual PIC" numbers. When asked total time I respond with all flight time including the "Logged PIC".
If the original poster is technically not required in the plane - I would encourage them to be the pilot flying as much as possible, so they are legal to log the "Logged PIC" flight time.
Those are my thoughts.
#25
Gets Weekends Off
Joined APC: Oct 2015
Position: Inverted
Posts: 402
Been in this situation myself.
Flew for a 135 operation that had a 350, was able to log SIC time on 135 legs only. I flew the airplane on 91 repo legs but had no feasible way to log it. PIC had single pilot type, but per our research and understanding the regs do not say I CANT log the time when there is an autopilot, only an autopilot can be used in lieu of an SIC. I've never been questioned about it once and talked about my King Air time at length with the check airman from the FAA on my CFI ride.
Flew for a 135 operation that had a 350, was able to log SIC time on 135 legs only. I flew the airplane on 91 repo legs but had no feasible way to log it. PIC had single pilot type, but per our research and understanding the regs do not say I CANT log the time when there is an autopilot, only an autopilot can be used in lieu of an SIC. I've never been questioned about it once and talked about my King Air time at length with the check airman from the FAA on my CFI ride.
#26
The OPSSPECS are a database of possible company rules. Whether or not the company decides (or is authorized to use them) is a coordinated decision between said company and the FAA (the company POI). For example, if two companies have the Autopilot in lieu of SIC authorization, it will be the same number (A015).
This is why it makes sense that the OPSPEC *should* be considered regulation. It's just a regulatory chinese menu.
#28
On Reserve
Thread Starter
Joined APC: Nov 2013
Posts: 15
I have a single pilot type rating in the 350. I don't really care if I can log SIC time or not. It's part 91 so it sounds like I can't do that. My company requires 2 pilots. Some of our planes are owned by the military and they also require 2 pilots.
It just sounds like none of my time really "counts". Until I get a certain number of hours I can't be the designated PIC. I have a good amount of pilot flying (left seat) time that I'd like to document to get some credit for.
It just sounds like none of my time really "counts". Until I get a certain number of hours I can't be the designated PIC. I have a good amount of pilot flying (left seat) time that I'd like to document to get some credit for.
#30
Disinterested Third Party
Joined APC: Jun 2012
Posts: 6,006
For a rated military pilot logging time in accordance with military regulation, a military requirement for a second in command is acceptable.
For a contract pilot flying an aircraft in military operations, a military requirement for a SIC is not a FAA regulatory requirement, and is not justification for logging the time, any more than a corporations in house rules.
For a contract pilot flying an aircraft in military operations, a military requirement for a SIC is not a FAA regulatory requirement, and is not justification for logging the time, any more than a corporations in house rules.
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Bill Lumberg
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02-25-2013 09:30 AM