Boutique Air
#1841
On Reserve
Joined APC: May 2017
Posts: 24
Reading into the definitions in Part 119, if your operation is not an on-demand (which charter repos are not), or commuter (which empty scheduled flying is), it's not an 135 operation and 135 regulations do not apply to them.
So, in Boutiques example, empty scheduled legs are Part 135, but they are not carrying passengers, so doesn't matter what your GOM says, SIC is never required and SIC cannot log that time, unless SIC is PF and then he can log PIC time as sole manipulator of controls.
So, in Boutiques example, empty scheduled legs are Part 135, but they are not carrying passengers, so doesn't matter what your GOM says, SIC is never required and SIC cannot log that time, unless SIC is PF and then he can log PIC time as sole manipulator of controls.
#1842
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,457
How can you prove when you were the sole manipulator of controls if you didn't start the engine, were listed as SIC on a flight log and flew from the right seat in a single pilot airplane under 135? PF or not, I would log SIC as per the flight log. Many pilots have logged SIC flying right seat in Caravans and PC-12s with no problems.
Many pilots have logged SIC in Caravans, 172's etc, but I'm just saying it's not 100% kosher and clear cut if you read the regs. Logging PIC is. There is zero ambiguity about it. As long as you are honest about it.
I forgot BTQ pilots are "seat locked". At our PC12 operation, PF is always left seat, even though we do get qualified to fly from both seats.
#1843
On Reserve
Joined APC: May 2017
Posts: 24
How can you prove anything in aviation? It's very much a honor system.
Many pilots have logged SIC in Caravans, 172's etc, but I'm just saying it's not 100% kosher and clear cut if you read the regs. Logging PIC is. There is zero ambiguity about it. As long as you are honest about it.
I forgot BTQ pilots are "seat locked". At our PC12 operation, PF is always left seat, even though we do get qualified to fly from both seats.
Many pilots have logged SIC in Caravans, 172's etc, but I'm just saying it's not 100% kosher and clear cut if you read the regs. Logging PIC is. There is zero ambiguity about it. As long as you are honest about it.
I forgot BTQ pilots are "seat locked". At our PC12 operation, PF is always left seat, even though we do get qualified to fly from both seats.
#1844
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,457
What does that mean?
Remember, we are in the reg nitpick land, you've got to be more specific.
To be a sole manipulator of controls, you don't need the 135.243 experience requirements. That's for acting PIC, not logging PIC time.
Remember, we are in the reg nitpick land, you've got to be more specific.
To be a sole manipulator of controls, you don't need the 135.243 experience requirements. That's for acting PIC, not logging PIC time.
#1845
New Hire
Joined APC: Oct 2016
Posts: 5
This is exactly the point. FAA has explicitly stated that you can log PIC if you are sole manipulator of controls, but they have not stated you can log SIC in 135 operation carrying passengers under IFR if you are using the autopilot.
This is the point I'm trying to make here. Logging the PIC time is 100% safe and appropriate and legal, logging SIC time is not.
Logging SIC time is simply widely accepted, but it's murky before someone asks the FAA if it's OK or not.
I don't think anyone should ask the FAA, people might not like the answer.
This is the point I'm trying to make here. Logging the PIC time is 100% safe and appropriate and legal, logging SIC time is not.
Logging SIC time is simply widely accepted, but it's murky before someone asks the FAA if it's OK or not.
I don't think anyone should ask the FAA, people might not like the answer.
I've flown with at least a dozen pilots in the 121 world who built 135 SIC time at Planesense, Tradewind, Boutique, and other Caravan operators. There must be thousands of pilots flying 121 today who built SIC hours at these operations. Never heard of anyone ever getting hassled about whether or not they were using their autopilot.
Are you saying that under 135 the the co-pilot can never log SIC time? Then what is he or she supposed to log when they are the pilot monitoring? Just total time?
#1846
Gets Weekends Off
Joined APC: Jul 2013
Posts: 459
I've flown with at least a dozen pilots in the 121 world who built 135 SIC time at Planesense, Tradewind, Boutique, and other Caravan operators. There must be thousands of pilots flying 121 today who built SIC hours at these operations. Never heard of anyone ever getting hassled about whether or not they were using their autopilot.
Are you saying that under 135 the the co-pilot can never log SIC time? Then what is he or she supposed to log when they are the pilot monitoring? Just total time?
Are you saying that under 135 the the co-pilot can never log SIC time? Then what is he or she supposed to log when they are the pilot monitoring? Just total time?
#1847
Gets Weekends Off
Joined APC: Apr 2007
Posts: 867
How does the Nichols letter not address this question?
#1848
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,457
I've flown with at least a dozen pilots in the 121 world who built 135 SIC time at Planesense, Tradewind, Boutique, and other Caravan operators. There must be thousands of pilots flying 121 today who built SIC hours at these operations. Never heard of anyone ever getting hassled about whether or not they were using their autopilot.
Are you saying that under 135 the the co-pilot can never log SIC time? Then what is he or she supposed to log when they are the pilot monitoring? Just total time?
Are you saying that under 135 the the co-pilot can never log SIC time? Then what is he or she supposed to log when they are the pilot monitoring? Just total time?
#1849
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,457
#1850
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,457
Exactly. There is no FAA opinion about this. Tarsa letter says it does not mandate the use of an Opspec, but nothing says you can "have your cake and eat it" with them. That is, operate with A015, SIC, AND autopilot.
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