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FAA Revises SIC time logging regulations

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Part 135 Part 135 commercial operators

FAA Revises SIC time logging regulations

Old 06-27-2018, 08:38 PM
  #1  
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Default FAA Revises SIC time logging regulations

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
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Old 06-27-2018, 08:53 PM
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This is huge. This means, that the 135 SIC time in PC12/Caravans is no longer ambiguous, but 100% legit. Great stuff!
Just be careful with the effective by-date! The way I read it is, that it has no retroactive effect. Log that PIC time until that!
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Old 06-28-2018, 06:08 AM
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But the OpSpec has to first allow it? I'm confused.
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Old 06-28-2018, 06:21 AM
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Originally Posted by SonicFlyer View Post
But the OpSpec has to first allow it? I'm confused.

Welcome to 135 operations...where just about everything is disallowed by the FARS unless specifically allowed in your OpsSpecs.
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Old 06-28-2018, 07:13 AM
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At Ameriflight we have had that in our Ops Spec for many years, but of course it was in multi-engine aircraft. The one big difference I see for our FOs is that now they will be able to count the time they log toward their ATP numbers. It's good for the pilot, but not so good for us as a company. Now that we have been hiring pilots into the right seat to help them get hours, the idea was for them to then stay on with us as captains for a time. Not being able to log time toward their ATP has been a bit of a hook to try to keep them from leaving a couple of months after they hit captain mins (1200.)
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Old 06-28-2018, 07:48 AM
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Originally Posted by frmrbuffdrvr View Post
At Ameriflight we have had that in our Ops Spec for many years, but of course it was in multi-engine aircraft. The one big difference I see for our FOs is that now they will be able to count the time they log toward their ATP numbers. It's good for the pilot, but not so good for us as a company. Now that we have been hiring pilots into the right seat to help them get hours, the idea was for them to then stay on with us as captains for a time. Not being able to log time toward their ATP has been a bit of a hook to try to keep them from leaving a couple of months after they hit captain mins (1200.)
I understand what you are up against. However, hooks and contracts might not be the best approach. The right pay, benefits, and QOL will bring you every applicant you need. You won’t even need right seat time building to get them. Of course, the money has to come from somewhere (the customer). 135 feeder freight might someday be a 300hr job if 121 pay out does it. I know people who flight instructed for 2-3000hrs because they had to. Now, many more options open where you can instruct 250hrs, fly jumpers or 135vfr up to 1200.
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Old 06-28-2018, 08:14 AM
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Originally Posted by TeamSasquatch View Post
I understand what you are up against. However, hooks and contracts might not be the best approach. The right pay, benefits, and QOL will bring you every applicant you need. You won’t even need right seat time building to get them. Of course, the money has to come from somewhere (the customer). 135 feeder freight might someday be a 300hr job if 121 pay out does it. I know people who flight instructed for 2-3000hrs because they had to. Now, many more options open where you can instruct 250hrs, fly jumpers or 135vfr up to 1200.
Don't get me wrong. I'm all for getting pay up (I've benefitted nicely from the pay and bonus increases we have had in the last couple of years.) We also have been adding partnership incentives such as our UPS Gateway program to help entice pilots to make longer term commitments. It just frustrates me when we hire someone at 800 hours to a position that primarily benefits them, pay their salary, travel, hotel and per diem and then they don't have the courtesy to stay long enough for us to make a return on our investment. Makes me wonder if it is even worth doing. Oh well, it is what it is.
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Old 06-28-2018, 09:10 AM
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Originally Posted by frmrbuffdrvr View Post
It just frustrates me when we hire someone at 800 hours to a position that primarily benefits them, pay their salary, travel, hotel and per diem and then they don't have the courtesy to stay long enough for us to make a return on our investment. Makes me wonder if it is even worth doing. Oh well, it is what it is.
This is what happens when the government [over] regulates an industry and the market is not allowed to maximize performance and efficiency.
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Old 06-28-2018, 09:12 AM
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Originally Posted by frmrbuffdrvr View Post
Don't get me wrong. I'm all for getting pay up (I've benefitted nicely from the pay and bonus increases we have had in the last couple of years.) We also have been adding partnership incentives such as our UPS Gateway program to help entice pilots to make longer term commitments. It just frustrates me when we hire someone at 800 hours to a position that primarily benefits them, pay their salary, travel, hotel and per diem and then they don't have the courtesy to stay long enough for us to make a return on our investment. Makes me wonder if it is even worth doing. Oh well, it is what it is.
Sounds like a girl I dated...once...
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Old 06-28-2018, 01:58 PM
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Originally Posted by TeamSasquatch View Post
I understand what you are up against. However, hooks and contracts might not be the best approach. The right pay, benefits, and QOL will bring you every applicant you need. You won’t even need right seat time building to get them. Of course, the money has to come from somewhere (the customer). 135 feeder freight might someday be a 300hr job if 121 pay out does it. I know people who flight instructed for 2-3000hrs because they had to. Now, many more options open where you can instruct 250hrs, fly jumpers or 135vfr up to 1200.
The thing is that the right seat meat isn’t required. The company really has no reason to fill that position unless it helps them long-term. They’re an expense that only subtracts from the bottom line unless they stay.

I just realized...this is a perfect way to resurrect PFT/PFJ. I’m NOT advocating it, but if there’s no guarantee the SIC will stick around after they hit ATP mins, why should the company take a huge gamble with salary and training costs? However, if the pilot forks over $xxxxx, then works to PIC qualification AND then works as a PIC for 18 months, they get that upfront money returned plus interest. What about that?

It still sucks, but the company doesn’t need SICs who aren’t required by certification or operation. They need PICs.
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