Quote:
Originally Posted by rickair7777
I thought GOM was good enough, that's been the conventional wisdom for a long time. Not familiar enough with 135 OPSPEC to say where it be, if at all. But FAA legal can, and does, cast doubt on long-standing assumptions.
OpSpecs are "cookie cutter" numbered letters that approve the certificate holder to conduct certain operations. For example, to conduct IFR with autopilot in lieu of SIC, you need an OpSpec for it (A015 in this case). A015 allows you to operate this way, but does not mandate every flight will be conducted this way (this is in the Tarsa interpretation). So - SIC is "required" when _carrying passengers_ under Part 135 IFR. Cargo, SIC is not required for that.
GOM is accepted, not approved. You can require a crew of 2 in a 172 in your GOM, but it definitely does not make the SIC a required crewmember "by regulation or aircraft type certificate".
In my opinion, this would need an opinion from FAA legal - if correctly worded, it might even come back with a favorable opinion. Current interpretations aren't clear on this.
Most two pilot single pilot plane (Caravan, PC12) 135 operations log SIC time "illegally", relying only on the long-standing assumption but with no support from FAA legal interpretations or the FARs.
I know someone who destroyed two years of his career by this. He was not a happy camper.
This mainly affects 135 cargo (135 cargo IFR does not require SIC by regs), and 135 passenger VFR ops (135 passenger carrying IFR requires SIC or Autopilot, unclear if you can operate with autopilot and SIC).
As a 135 SIC, you can legally log PIC time for the legs you are pilot flying, but the pilot monitoring "SIC" legs, better know exactly what the regs say and know to defend your logbook if someone starts asking uncomfortable questions.