Good response. And yes it does require it. Fun fun fun

I agree that you should log that time as SIC.

Be prepared to intelligently explain it in an airline interview though. People that have done this with our company have always told me they've been questioned about it when being interviewed. It's never cost anyone the job.

I thought I'd put the reg up and let you guys interpet it. I personally don't think there is much to interpet but that is what discussion is for, eh?
135.109 Pilot in command or second in command: Designation required.

(a) Each certificate holder shall designate a—

(1) Pilot in command for each flight; and

(2) Second in command for each flight requiring two pilots.

(b) The pilot in command, as designated by the certificate holder, shall remain the pilot in command at all times during that flight.

I agree. Not much to interpret. A 135 certificate holder must designate an acting PIC for every flight. If the operation requires two pilots, the certificate holder must designate an acting SIC. And those designations do not change during the flight.

It's connection to the logging question is also pretty straightforward.

The designated PIC "acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted" so she logs PIC under 61.51(e)(1)(iii) whether or not at the controls.

The designated SIC is acting as SIC on a flight where "more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted" so he logs SIC under 61.51(f)(2) whether or not at the controls.

And, of course, completely independent of either of those regs, whoever has the proper aircraft rating and is the sole manipulator of the controls gets to log his or her hands-on time as PIC under 61.51(e)(1)(i).

I interviewed at Atlantic Coast Airlines (1999).... they used to bring in 2 at a time... my interview buddy logged some time as PIC because according to the FAR/AIM "I'm allowed" and he was...he was typed in the excel, however you guys should've see him trying to explain that during the interview... the more he spoke, the uglier it got...

He is discussing flying during '91' legs though, correct?

That was my understanding.

It moved around even the OP went from talking about the empty leg (Par 91) to OpSpecs requirements (Part 135).

You're right though; the logging would be a little different since, according to the posts, the 135 leg would require who an SIC (per OpSepcs) while the Part 91 leg would not. That would mean differences in logging under 61.51(e)(1)(iii) and (f)(2) (ops requiring more than one pilot) although it wouldn't affect logging under (e)(1)(i) (the sole manipulator clause)

On the 135 legs log it all as SIC. because the opspec requires it you are a required SIC. you cannot log pic on a 135 leg.

On the 91 legs log it as pic when you are manipulating the controls but you cannot log sic on a 91 leg. You can only log the time you fly.

I agree with this post. In the example of a 6 hour flight with 3 hours of it being PIC, log it as 3 hours SIC and 3 hours PIC. I think the other person got confused when they said to log 6 hours SIC and 3 hours PIC.

I also agree with the people that stated if you cannot explain the time, don't log it. If it is clear that these are part 91 legs, and you're sole manipulator... I guess you can log it as PIC. And log the 135 legs as SIC..