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FAA Revises SIC time logging regulations

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Old 07-29-2018, 12:20 PM
  #41  
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Originally Posted by Fr8Thrust View Post
The solution is simple: places like AMF need to incentivize their workforce to want to stay. QOL, schedules, benefits, and pay are far lacking compared to today’s regional offering. It’s not the pilots fault that they left, it’s AMF fault for not being able to retain. Pilots will stay to become PIC only if you offer them good trips, a CBA, schedule/trip trades, non-rev/ZED pass travel, and a glimmer of hope that a legacy airline will even look at them. But as long as the equipment is antiquated, the layovers are embarrassing, and the schedule is crap nobody in their right mind is going to stay.
This is 100% correct.
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Old 07-29-2018, 12:40 PM
  #42  
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Originally Posted by TeamSasquatch View Post
135 cargo Is not as hard as you make it sound.
Did that sound hard to you? I didn't make it sound hard.

Then again, I've done a lot of it, as with a lot of other things in aviation, from hauling bleeding patients off dirt muddy airstrips lit by flarepots at night to chasing bad people at night in the dark, to to thunderstorm penetration atmospheric research to flying down burning canyons in severe turbulence, and frankly, there's nothing more demand and potentially dangerous than single pilot IFR in weather.

As I'm sure you know.
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Old 07-29-2018, 01:10 PM
  #43  
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Originally Posted by JohnBurke View Post
Did that sound hard to you? I didn't make it sound hard.

Then again, I've done a lot of it, as with a lot of other things in aviation, from hauling bleeding patients off dirt muddy airstrips lit by flarepots at night to chasing bad people at night in the dark, to to thunderstorm penetration atmospheric research to flying down burning canyons in severe turbulence, and frankly, there's nothing more demand and potentially dangerous than single pilot IFR in weather.

As I'm sure you know.
You sir are a bad ass!

I guess I should have said, “don’t make it sound so dangerous, 135 cargo is not as dangerous as you make it sound”
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Old 07-29-2018, 01:35 PM
  #44  
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Originally Posted by MaxMar View Post
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.
Mic drop, outstanding explanation. Even for an experienced driver.
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Old 07-29-2018, 04:15 PM
  #45  
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Originally Posted by TeamSasquatch View Post
You sir are a bad ass!

I guess I should have said, “don’t make it sound so dangerous, 135 cargo is not as dangerous as you make it sound”
Did that sound dangerous to you? I didn't make it sound dangerous.

Frankly, there's nothing more demand and potentially dangerous than single pilot IFR in weather.

As I'm sure you know.
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Old 07-31-2018, 11:19 AM
  #46  
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Originally Posted by TeamSasquatch View Post
AMF isn’t in a tough spot... They cash big checks from UPS every day. But, you are on the right track. Perks and pay are all it takes.
AMF has always been able to get people in the door. It is getting people to stay, getting people to leave happy, or stay happy while they work there. AMF is excellent at driving moral into the ground.

Forbes did an amazing article on why people stay or leave a job, and money was not the number one reason people left, poor management was. It has always been an atrociously run company from a middle management and up standpoint. The schedule, the airplanes, the lifestyle, the QOL, the respect, is all lacking, it has always been lacking and has always been a major issue.

AMF will always be stuck in a really weird place. They have no legit flow program that regionals offer, you can either be a 135 captain at 1200 hours for AMF or instruct a few more months and go to a regional where you can pick your poison on the next career step, and at the same time possibly wait for flow or preferential hiring programs, at the same time as getting the most relevant experience to a career airline. AMF does have preferential hiring programs but they aren't that great. Fly at AMF for 3 years then you only get an interview at Frontier? You can go work for any regional and get an interview at Frontier sooner than that.

The market is in an amazing place right now. In 2010 when I hired on at AMF they treated each employee like pure crap, because they could. Nobody else was hiring, and if you didn't like the job you were shown the door, as well, everyone walked on eggshells for fear of being fired for any little thing. Fast forward to 2018 and they are begging for anyone that can fog a mirror, to come work there and stay for a little bit, but they don't want to put the work into changing the culture. At the same time, there is only so much you can do. You can only make a Beech 99 so appealing...
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Old 08-01-2018, 07:56 AM
  #47  
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Originally Posted by Jetlife View Post
...they don't want to put the work into changing the culture.
I am afraid I have to agree. I was offered a job there but I turned it down because of the atmosphere within the company. What really scared me, as Jetlife is saying, is they don't care and they are showing no intention of changing. I now strongly feel no one at AMF would ever admit there is any kind of a problem. How sad.

It does seem the way they are 'dealing with the problem' is to regularly fire all the recruiters and replace them with new recruiters. How they expect this to fix anything is beyond me.
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Old 11-13-2018, 01:56 PM
  #48  
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Originally Posted by MaxMar View Post
The FAA has released a final ruling to create a SIC Professional Development Program that operators may choose to participate in via Op Spec, allowing SICs to log all the flight time towards new certificates and ratings.

Beginning on page 30240, here's some excerpts

"The FAA proposed to revise § 61.159(c)(1) to contain the requirements for logging SIC pilot time in an operation conducted under part 135 that does not require an SIC by type certification of the aircraft or the regulations under which the flight is being conducted."

"...the FAA is revising proposed § 61.159(c) to allow pilots to credit time logged under a SIC PDP not only for total time as a pilot, but also toward the specific flight time requirements for ATP certification set forth in § 61.159(a)(1) through (4) (e.g., cross-country flight time, night flight time, flight time in class of airplane, and instrument flight time). "

" the FAA maintains in the final rule that a SIC logging flight time under § 61.159(c) is not permitted to log this flight time as PIC time even when he or she is the sole manipulator of the controls"

" the FAA has decided to also allow SIC flight time to be logged during part 91 flight operations (e.g., re-positioning flights) conducted for the certificate holder when the operation is conducted in accordance with the certificate holder’s operations specification for the SIC PDP."

"Therefore, in the final rule, the amendments to §§ 61.39, 61.51(e) and (f), 61.159(a) and (c), 61.161, and 135.99(c) will be effective 150 days after publication of this final rule"

Originally the SIC PDP would apply only to multi engine aircraft, but thanks to several contributors (including my company, Tradewind Aviation!) single engine turbine aircraft are included.

Link to the Ruling

Do you know if this applies to Part 91 operations solely? Example: My father in law owns a PC12 (Part 91 only) which he currently flies with 2 pilots due to insurance.
If he were to hire me, would this PDP apply to me and could i log that SIC time?
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Old 11-13-2018, 01:57 PM
  #49  
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Originally Posted by chrisaviator View Post
Do you know if this applies to Part 91 operations solely? Example: My father in law owns a PC12 (Part 91 only) which he currently flies with 2 pilots due to insurance.
If he were to hire me, would this PDP apply to me and could i log that SIC team?
Not applicable for Part 91.
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Old 04-06-2021, 10:03 PM
  #50  
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Originally Posted by MaxMar View Post
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.
Reviving an oldie, but a goodie haha

Specifically asking about OpSpec and GOM. If a 135 operator has it in their GOM that 2 pilots are required then the person who has a SIC type in a citation can log SIC, correct? I reached out to an old colleague who happens to be a director at an another 135 said that SICs can only log time if the company has it in their OpSpec, not their GOM.

I guess the real question would be OpSpec vs. GOM. I always thought of it as OpSpec sets up the parameters of the “game” and the GOM says how the team will “play the game.” FAA doesn’t care about which plays you choose to run as long as you play within the parameters they set forth in OpSpec. Essentially, not allowing GOMs to legalize SICs logging time in a single pilot airplane.
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