MaxMar

For context, an Op Spec is approval from the FAA to do something under 135 or 121. For example, even though under 135 there's no limitation on what types of approaches can be flown, without the specific, appropriate Op Spec for a given type (e.g. ILS, VOR with DME arc, VOR without DME arc, etc) then the operator is forbidden from performing it. Another way of thinking of it: under part 91, the rules are a list of things you can't do. Under part 135 or 121, the rules are a much shorter list of things that you can do.

Previously under Part 135, SICs could only log time under specific circumstances, either a. the flight was operated under IFR and the operator did not elect to use Op Spec A015 which allows them to use an autopilot in lieu of the required SIC (135.101 and 135.105), or b. the operator was required by law (Op Spec or GOM) to have an acting SIC on 135 flights, therefore making them required crew and opening up loggable time or c. the airplane required two pilots in the first place.

The new ruling formalizes part b into what they are calling a 'SIC Pilot Development Program', which will be allowed via, you guessed it, an Op Spec. Once an operator attains this Op Spec from the FAA, there is no longer a requirement for a 'minimum crew', the person sitting in the right seat is under no obligation to have a legally defensible 'required crewmember' designation, but as long as the rules as defined in the Op Spec are followed, that SIC time is perfectly legal. This extends, for the first time, to part 91 re-positioning legs which can happen frequently in the passenger 135 world. Since these flights are operated under 91, they need not follow the restrictions of 135 or other Op Specs, which means on single pilot airplanes an SIC will never be required. With this new ruling, SICs could log SIC time when conducting a 91 repo leg so long as the conditions in the PDP Op Spec are followed.

Example: A night freight operation that runs Caravans under 135 VFR and IFR can now hire pilots to fly and log time from the right seat to build time towards being a Captain there as well as towards ATP minimums, where previously these types of operations didn't do this because there's no incentive to; prior to this rule, an SIC wouldn't be required since there's no passengers and while a safety advantage may or may not be present, no one really cares about how many pilots are up front when the only thing in the back is boxes (in the 135 world).

This ruling also helps remove any doubt from Caravan and Pilatus 135 right seaters who typically have to sling gear without logging time on 91 legs, and some are suspect of any SIC time at all, even though there is a strong argument that it can be logged if the appropriate documents are accepted by the FAA.

Clear as mud, ya?

For your question about whether the flight time is legal for the regionals, simply ask during the interview or even before for the location, in writing, in their GOM or Op Spec where a SIC is required crew. If they can't provide that, or they give an answer like 'It's company policy / it's in the SOP / it's an insurance requirement' none of those answers will yield legal time. Only an Op Spec or GOM carry regulatory weight and thus you need to see it in writing in one of those documents.

reid

If a company were to have an OpSpec requiring an SIC, do you know what number it would likely be? (A???)

deadstick35

It doesn’t exist yet, but it looks like it will be A062. In reading the AC, I did find this interesting, though...

“10 LOGBOOK ENDORSEMENT FOR EACH FLIGHT. In accordance with
§ 61.159(c)(3), to log SIC flight time while serving as an SIC of an operation conducted in accordance with § 135.99(c), the PIC must certify in the assigned SIC’s logbook that the flight time was conducted in accordance with § 61.159(c). The FAA recommends the following endorsement to certify each flight:”

https://www.faa.gov/documentLibrary/.../AC_135-43.pdf

for every flight...don’t ditch the paper logbooks, yet.

SunnyFL

Thank you very much for the break down and great explanation. That was very helpful and I feel like I understand it a lot more now!

JohnBurke

The basic regulatory standard for IFR operations is an SIC.

An operations specification must be issued to operate single pilot with autopilot, in lieu of a SIC.

The SIC is always required, unless the operator (and pilot) is authorized per OpSpec to fly with an autopilot in lieu of the SIC.

https://www.ecfr.gov/cgi-bin/text-id..._1101&rgn=div8


135.101 has remained unchanged since 1997.

flyingpomba

If a company wants to apply the SIC pilot development program, what do they need to do?

Is there a list of paperwork and documents they need to do?
my chief asked me to find out how to apply the new program for our CJ's and KA.

Thanks.

Toddzilla

Tell your chief to contact your POI, they will be able to point you in the right direction.

Jetlife

AMF needs to fix the systemic issues and stop continually banking on industry stipulations to get warm bodies. This is 10 years in the making and overdue for companies like this. The gettin' was good when the airlines were on furlough, then seemingly overnight AMF and regionals couldn't fill classes and had to raise pay, to which AMF, regionals and other 135s did. The last draw for AMF was to get people in with less than ATP mins and to trap them with a contract. Now that is going to be much harder, its time to really step the game up and do it right, and to stop half assing it if they want to attract half way decent pilots, and to keep them.

JohnBurke

It was cited above, but the most current guidance is found in Advisory Circular AC 135-43, linked below. The purpose of the AC is to guide you through the requirements for establishing a Second in Command Professional Development Program (SIC PDP).

https://www.faa.gov/documentLibrary/.../AC_135-43.pdf

frmrbuffdrvr

Took you long enough to get your AMF slap in, Jet.

Actually, my point on this whole thing is, if the pilots are able to use the time we pay them to get to bolt to the regionals, why would AMF hire them is the first place? Why would we pay them to advance their carriers to only get a couple of months productive work out of them?

If it is going to take the 135 operator getting permission to implement a new pilot development program to allow pilots to log time that doesn't help the operator, why would any of them do it?