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135 Op SIC Logging in Piaggio Avanti

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Old 07-02-2018, 01:13 PM
  #11  
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Originally Posted by deadstick35 View Post
Investigate the differences between “FAA Approved” and “FAA Accepted.” One carries regulatory weight. The other is “ok, that’s nice.”
I guess I was mis-taught about the difference. My understanding was

Op Spec (Approved) - Handed down from the FAA, regulatory

GOM (Accepted) - Operator submits to FAA and receives acknowledgement, regulatory (as in, if I violate the GOM the FAA is mad)

SOP (Neither) - Company policy, FAA doesn't have a hand in it and won't care if it is violated so long as neither the GOM or Op Spec were violated in the process.
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Old 07-02-2018, 02:18 PM
  #12  
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A frequent visitor to the flying subreddit, u/your_friendly_asi is (supposedly) an ASI who replied to a similar question I posted there, and he quoted 135.21

This manual must be used by the certificate holder's flight, ground, and maintenance personnel in conducting its operations
and stated

Therefore, not using the manual or operation contrary to the manual could be in violation of the FARs
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Old 07-02-2018, 03:51 PM
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Originally Posted by deadstick35 View Post
This is correct.

Investigate the differences between “FAA Approved” and “FAA Accepted.” One carries regulatory weight. The other is “ok, that’s nice.”

There’s more to this pending change. OpSpecs have to be issued and it’s not retroactive.

If the AP is used, 1000 hrs PC12 SIC = 0.0 hrs.

Are you saying that all right seat pilots at the 135 Caravan and PC-12 operators out there can only log total time, not SIC time, when the autopilot is on?



This sounds a bit absurd to me. But I suppose what difference does it make, SIC time vs. just total time. Most folks at those operations are just there to build up to 1200/1500 hours of total time and move on.
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Old 07-02-2018, 04:16 PM
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Originally Posted by MaxMar View Post
That is...problematic if true. My employer does quite a bit of 135 VFR trips in the PC-12 and all the SICs are logging that time to my knowledge. I haven't ever heard of it being an issue down the road but that may just be because a future employer wouldn't 1. care or 2. be able to determine if a trip was flown IFR or VFR anyways.
mike sierra used to work for the same employer
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Old 07-02-2018, 04:17 PM
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Originally Posted by ForthFlyer View Post
Are you saying that all right seat pilots at the 135 Caravan and PC-12 operators out there can only log total time, not SIC time, when the autopilot is on?



This sounds a bit absurd to me. But I suppose what difference does it make, SIC time vs. just total time. Most folks at those operations are just there to build up to 1200/1500 hours of total time and move on.
Thing is - there is no 100% previous interpretation about this. The new change requires an OpSpec and is not retroactive. This is actually worrying, because that would imply FAA does NOT accept that time unless you own that OpSpec.
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Old 07-02-2018, 04:33 PM
  #16  
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This is the Nichols letter that some have insisted doesn’t address the issue.

https://www.faa.gov/about/office_org...rpretation.pdf

You can and should read the entire letter, but here’s there money shot.

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Old 07-02-2018, 05:09 PM
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Originally Posted by deadstick35 View Post
This is the Nichols letter that some have insisted doesn’t address the issue.

https://www.faa.gov/about/office_org...rpretation.pdf

You can and should read the entire letter, but here’s there money shot.

The thing Nichols doesn't fully cover are 91 legs, 135 VFR legs, and the relevance of operators GOM and the crew member requirements therein.
Also, if the flight is dispatched with two pilots, are they then choosing to use the autopilot "before the IFR operation" etc. Lots of open questions.
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Old 07-02-2018, 05:37 PM
  #18  
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Originally Posted by dera View Post
The thing Nichols doesn't fully cover are 91 legs, 135 VFR legs, and the relevance of operators GOM and the crew member requirements therein.
Also, if the flight is dispatched with two pilots, are they then choosing to use the autopilot "before the IFR operation" etc. Lots of open questions.

You are right, there are several open questions. It is and has been a gray area for a long time.

Though, it does seem that the Nichols letter suggests that a crew must NOT use the autopilot in order for the FO to log SIC time. But it now appears that this new regulatory advisory that recently came out nullifies the Nichols letter.

As for it taking effect later this year, and not explicitly being retroactive. I seriously doubt the FAA gives a squat about the Alaska Caravan driver still logging SIC time over the next few months before it enters into effect. Another year from now people will not even remember this Nichols nonsense letter. Glad this issue is almost dead. The forums will never be the same.
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Old 07-02-2018, 05:47 PM
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Originally Posted by ForthFlyer View Post
You are right, there are several open questions. It is and has been a gray area for a long time.

Though, it does seem that the Nichols letter suggests that a crew must NOT use the autopilot in order for the FO to log SIC time. But it now appears that this new regulatory advisory that recently came out nullifies the Nichols letter.

As for it taking effect later this year, and not explicitly being retroactive. I seriously doubt the FAA gives a squat about the Alaska Caravan driver still logging SIC time over the next few months before it enters into effect. Another year from now people will not even remember this Nichols nonsense letter. Glad this issue is almost dead. The forums will never be the same.
I've said this same thing for a long time - log PIC time when you can (sole manipulator of controls in a single pilot plane), know the regs, and DO NOT ASK THE FAA ABOUT THIS because you might not like the answer you get.
For now, it's questionable, but widely accepted to log that time. That's probably the best status quo for now, until this new Opspec is more widely issued.
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Old 07-02-2018, 10:30 PM
  #20  
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Dera has a pretty strong and educated opinion on this matter re: logging SIC vs. PIC and I'm not saying they are wrong, but I vehemently disagree with their reasoning for logging PIC because they are the sole manipulator of the controls as the SIC. I could be way off base but as other people in previous threads have said, most airlines assimilate PIC to mean a signature on the release- not being the PF. They don't care that a pilot can hand-fly an aircraft. Anybody can do that. They care that a PIC can take care of the flight planning, make safe decisions, please customers, work with dispatch, etc.

I understand what Dera is saying, but in an interview I just don't see how somebody would be able to explain how they worked for Surf Air, Boutique, Tradewind, etc. for a year as SIC and now have 1200 hours and 500 hours of it is PIC in a pc12. Call me lazy, but I'm not willing to break up my PIC time like that. Maybe that's just because I never had to, I don't know.

Hit 1200, upgrade to PIC and see what it actually means to act as a PIC, not just fly an airplane. I promise you will learn a lot.

If I had been in this situation during my time building experience, I think I would have logged it as total time and left both PIC and SIC blank. If you wanna get fancy, add a column for PF and PM. To me that seems like an easier thing to explain in an interview.

That all being said, log it however you want- it's your book. In my opinion, however, log it in the way that is the easiest to explain to a skeptic. In the current 121 market, It's not like a few extra hours of PIC time is going to help you out much in a regional interview anyway. You'll be in the same ground school as everybody else and upgrade when they pull your number.
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