Nothing in Cato, Nichols, Tarsa etc letters are 100% relevant to this question, they merely touch it but don't directly answer this question. If a company has A015, Tarsa says it does not _mandate_ the operator to use it. But there is nothing in the legal interpretations that says you can use the autopilot while SIC logs SIC time as pilot not flying.

 

Served as PIC does not mean "logged PIC time". So you are high mins.

Served as PIC means you were flying per 61.51(e)(1)(iii). Logged PIC time means you logged time per 61.51(e)(1)(i).

 

thats correct.

so... in a multi crew environment, where one pilot is flying, the other is monitoring - manipulating flaps, gear, subsystems, you may or may not transfer flight controls to brief the approach... you logged pic time

but were you, in essence, the "sole manipulator" of the flight controls.

im assuming thats your basis for logging the pic time

 

There are actually plenty of interpretations about what being sole manipulator means.
I think the general consensus is, that manipulating or causing to manipulate (in case of autopilot) primary flight control surfaces to control the trajectory of the airplane is what is required. So generally, pilot flying is also the sole manipulator of controls. If you log PIC time for 5 minutes while the other guy does paperwork or whatever is murkier than just logging PIC for PF legs and SIC for PM.

Again - I urge everyone to really read into the regs, the PC12/Caravan etc SIC time is not as clear cut as people think. The PIC time as sole manipulator has been established hundreds of times in various cases (such as, being a safety pilot and building time that way etc).
So - logging PIC is safe, legal and appropriate. Logging SIC time is somewhat safe, somewhat legal, and somewhat appropriate.

I know a pilot who's time as a Caravan SIC in Hawaii did not count. He wasn't happy. Had he logged it correctly, he would've been better off.

 

Sounds like I have a few thousand more dollars to spend.

 

I think the barrier here is that a lot of guys are operating in a 121 environment. or in my case, are used to operating 121.

where you have a PIC assigned to the flight, and an SIC assigned to the flight. there isnt any grey area.

You have a regional jet, you have a designated pic logging pic, and a designated SIC logging SIC. Thats pretty cut and dry. I dont see how a 135 air carrier who designates a PIC and an SIC as required crew would be any different.

Its obviously - as one can tell based on a simple web search - a pretty often misunderstood and hotly debated subject. I mean i have been in aviation for over 20 years and i'll admit there are often pitfalls in these sorts of discussions - no matter if they include a 747, or a CFI, a student pilot and a Cessna 150

appreciate the discussion by the way

 

I know very little abour Boutique's operation. I assume all of their aircraft are set up with 9 or less PAX seats?

As far as logging SIC time, for Passenger carrying part 135 ops an SIC is always required. (C172 or otherwise) 135.101
You have to apply for and receive the A015 OPSPEC which is the exception to the rule. So yes you can log SIC in a single-pilot airplane. Now as far as where they already have A015, I don't know if they can pick and choose when they want to use it because I haven't read the verbiage on A015 in quite a while.

As far as general logging of flight time, the only times anyone cares what you log are when you apply for a new certificate or type, when you apply for a job, or what you log for recently of experience (currency).

I can tell you that I log my time based on who the company assigns as PIC/SIC, because I don't want to deal with sorting out the ACTING PIC from the sole manipulator. Not that I'll have to ever do that again.

 

The situation we're discussing is indeed only relevant in a single pilot airplane. The fact that a GOM calls for 2 pilots does not make it required under "the regulations under which the flight is being conducted.", especially if the operator has A015.

Again - there are operators that require 2 crewmembers on 172/182 type equipment, and in no way does anyone think it's appropriate to log SIC time in them. But in regulations, a PC12 and a 172 are exactly the same thing from certification standpoint.

 

Passenger carrying ops _under IFR_ is what 135.101 says, not all passenger ops. Plenty of 135 VFR flying with no SIC. 135.105 allows for A015. Nothing mandates the use of autopilot in lieu of SIC (as the Tarsa letter says), but - and here's the important part - FAA has never said if the company has A015, you can use both - an SIC, required by 135.101, AND an autopilot, as allowed in 135.105.

I guess the point I'm trying to make here is, that the SIC in a single pilot ship is much murkier, than PIC as sole manipulator of controls.

 

Log it however you want, but I personally wouldn't put a single second of PIC time into my logbook at Boutique if I were under 1200 hours and on a 135 leg. Tagging along on a repo? Knock yourself out.

Not worth having to discuss/explain the minute details of a reg to somebody in an interview in my opinion.