Derian

Might have a great opportunity to fly SIC in a Piaggio Avanti in the next few months. Did an HR phone interview and asked about time logging toward ATP in a technically single pilot operated airplane.

I was told that due to the operating requirements of 135, a 2 man crew is required and therefore time as SIC can be counted towards ATP mins.

That seems correct to the extent of my knowledge, but can someone verify?

JamesNoBrakes

It depends.

They told you this, but could not cite the regulation they are using? That in of itself is suspicious.

MaxMar

135.101 states that all 135 passenger carrying IFR flights require an SIC. 135.105 states that an approved autopilot can be substituted. Op Spec A015 grants an operator that explicit permission to operate single pilot if necessary. Further, the operator may have an FAA accepted GOM which states that an SIC is required crew and therefore open to loggable time regardless.

PerfInit

The Feds just relaxed the reg on 135 AMEL SIC logging. Please see thread further on down the list. Reg change went into effect earlier this week. Great news for time building towards ATP.

JohnBurke

A pilot seeking a position should know the regulation that governs that position.

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

While 135.105 provides an exception, allowing operations specifications to be issued to the 135 certificate holder to use an autopilot in lieu of a SIC, the overriding basic principle of the regulation remains; that under IFR, 135 requires a SIC. The operator may have opspecs allowing an autopilot in lieu of the SIC, but still retains the requirement to have an SIC in the even the autopilot is not used or is inoperative, and has the option to use the SIC with an approved training program. Remember, SIC is the default requirement. 135.105 only allows an exception, but doesn't alter the basic standard.

It did?

Did you read the Federal Register final notice? Where does it go into effect "this week?"

mike sierra

GOM which states that an SIC is required doesn't make it legal to log.

MaxMar

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.

deadstick35

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.

MaxMar

I think this is correct from a regulatory standpoint, but hundreds of pilots are leaving 135 like Boutique, Surf, Cape, Tradewind, etc. and 121 and other big time places are taking them and their time. Is it a symptom of the pilot shortage or do they really just not care that much about whether the FAA considers the time valid?

MaxMar

Thinking about it, I'm curious about this. This is the exception provided by 135.105 and accompanied with Op Spec A015 which allows an autopilot in lieu of an SIC. But does using the autopilot automatically enact 135.105? As in, takeoff and landing are 135.101, but as soon as AP Master is on 135.105 takes over? I was under the impression that A015 permitted an operator to use it, but like JohnBurke said, the base level is SIC required. For example, an operator has an Op Spec to fly VOR/DME approaches, but that doesn't mean they have to fly a VOR/DME approach, they could fly any approach they are approved for. I always understood Op Specs to be 'clearance cards' that say 'You can do this', not 'You must do this'.

So in this case, the SIC is required, but the FAA says 'You can do this' and substitute the autopilot. The operator is not required to use A015, regardless of whether or not the autopilot is on, making an SIC required crew under IFR.

I think this goes against the Nichols interpretation, unless I misremember and the Nichols interpretation explicitly mentions A015.

Thoughts?