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Regionals using mil SIC primary for 121 req

Have a friend who just got hired at Envoy and told me they will use all his SIC primary time logged in his ME military aircraft towards his 121 time requirement for Capt upgrade. He’s getting his R-ATP next month and I think he said there taking his few hundred hours primary SIC and applying it towards whatever Envoy requires (believe he said 1k 121 time).

Has anyone else heard of this? Heard of any other carrier doing it? He didn’t know if anyone other than Envoy was doing it.

§ 121.436 Pilot Qualification: Certificates and experience requirements.

Quote:

(a) No certificate holder may use nor may any pilot act as pilot in command of an aircraft(or as second in command of an aircraft in a flag or supplemental operation that requires three or more pilots) unless the pilot:

(1) Holds an airline transport pilot certificate not subject to the limitations in § 61.167 of this chapter;

(2) Holds an appropriate aircraft type rating for the aircraft being flown; and

(3) If serving as pilot in command in part 121 operations, has 1,000 hours as:

(i) Second in command in operations under this part;

(ii) Pilot in command in operations under § 91.1053(a)(2)(i) of this chapter;

(iii) Pilot in command in operations under § 135.243(a)(1) of this chapter;

(iv) Pilot in command in eligible on-demand operations that require the pilot to satisfy § 135.4(a)(2)(ii)(A) of this chapter; or

(v) Any combination thereof.

Quote:

(c) For the purpose of satisfying the flight hour requirement in paragraph (a)(3) of this section, a pilot may credit 500 hours of military flight time provided the flight time was obtained -

(1) As pilot in command in a multiengine, turbine-powered, fixed-wing airplane or powered-lift aircraft, or any combination thereof; and

(2) In an operation requiring more than one pilot.

Quote:

Originally Posted by hydrostream (Post 3628423)

§ 121.436 Pilot Qualification: Certificates and experience requirements.

I ain’t no lawyer but military SIC would not appear to meet the qualifications:

https://i.ibb.co/7gSWxZW/B3-E2-E181-...75-F595-C7.jpg

If you ain’t the guy with the asterisk on the flight orders, you ain’t the pilot in command.

§ 121.436 Pilot Qualification: Certificates

I had a meet-n-greet with Envoy at TPNx last weekend and the conversation included this very topic. My military experience is predominantly single-seat jets, but my resume also includes one brief experience in a multi-crew/multi-engine aircraft (C-12 = KingAir). He specifically asked if that time was PIC (aircraft commander, not Part 61 "PIC") so he could count it toward the 121.436 clause. It was all SIC, so no-joy.

But he still invited me back to interview the next day, so maybe they anticipate resuming FO hiring soon...?

I agree, mil SIC does not count towards 121 upgrade.

But I wouldn't correct them on that, you might get preferential hiring and FO training placement if they think you can upgrade faster than the CFIs. Of course you'll have to break the news when the time comes, don't let them actually send you to a checkride based on that lol.

For clarity that's for upgrade to 121 PIC, or getting hired as a DEC. You can still get an R-ATP without 1,000 121 hours. You can also get an unrestricted ATP, just can't serve as a 121 CA.

Quote:

Originally Posted by rickair7777 (Post 3628467)

That’s how I understand it and was really surprised when he told me that. He is NOT qualified to hold the “A” code but they are telling him he can use his primary time towards upgrade. I’m still not sure if they were just giving him a line or if he misunderstood.

Quote:

Originally Posted by Kebert Xela (Post 3628505)

The recruiters are not pilots and may not have a firm grasp on the regs. I wouldn’t argue right now if it gets you preferential treatment, there will be time to argue later. There are a few non-cadet, non-part 121 pilots in my training class right now. Hiring is likely competitive since there are so few airlines hiring FOs at the moment.

Quote:

Originally Posted by Kebert Xela (Post 3628505)

They may have misconceptions... civilian SICs, students, etc can log "sole manipulator PIC" when operating the flight controls, and this can be used for various FAA aeronautical experience requirements as PIC.

But I don't see even an implied link to that concept in 121.436(c)