Logging PIC in King Air 90

[Fly_Unity]

I got a question.. I got a job offer for a FO position in a 135 gig in a King Air 90 medic, Since this aircraft is under 12,500 pounds, could I log this time when Im sole manipulator as PIC turbine time? or what about even SIC time? cause its only single pilot certified,. What about on the Part 91 empty legs?

[tgrayson]

<<could I log this time when Im sole manipulator as PIC turbine time?>>

Yes.

<<what about even SIC time? cause its only single pilot certified>>

Do your op specs call for two pilots?

<<What about on the Part 91 empty legs?>>

Yes on PIC, no on SIC.

[Fly_Unity]

Originally Posted by tgrayson

<<could I log this time when Im sole manipulator as PIC turbine time?>>

Yes.

<<what about even SIC time? cause its only single pilot certified>>

Do your op specs call for two pilots?

<<What about on the Part 91 empty legs?>>

Yes on PIC, no on SIC.

Thanks, I believe the op specs require two pilots on the 135 legs, so even if my title is a FO, I can still log PIC on my leg by the sole manipulator rule?
Is this legit PIC time by other airlines?

[tgrayson]

I can still log PIC on my leg by the sole manipulator rule?

Yes. And there are FAA letters of interpretation available that explicitly say this. Be advised that those involved with the 135 operation will probably tell you that you can't, but most of the piloting world is a bit confused about logging regulations. I wouldn't bring the subject up with them.

Is this legit PIC time by other airlines?

My understanding is that some airlines accept it and some don't. Fedex pilots, for instance, say that their applications expressly say to exclude the "sole manipulator" PIC time. Many people suggest keeping a separate column for the "sole manipulator" PIC time so that you can crunch the data in whichever way the airline wants.

[Fly_Unity]

thanks

[MikeOH58]

You are going to need a high altitude endorsement.

[tgrayson]

Originally Posted by MikeOH58

You are going to need a high altitude endorsement.

Only to ACT as pilot in command.

[MikeOH58]

Thats what I was referring to.

I guess it boils down to the ACTING of PIC and being sole manipulator that was mentioned above...I've got to take a look at the regs, but if one is logging king air PIC as the sole manipulator, if there is in fact a difference in sole manip/ACTING PIC, wouldn't it be in his or her interest to get the high altitude endorsement?

edit...well, reading 61.51, it would appear to me that if you are acting as sole manipulator and logging PIC, then you are also the acting PIC at the time because its single pilot? is that correct? If so, so you would need the endorsement to log any pic

[tgrayson]

Originally Posted by MikeOH58

wouldn't it be in his or her interest to get the high altitude endorsement?

edit...well, reading 61.51, it would appear to me that if you are acting as sole manipulator and logging PIC, then you are also the acting PIC at the time because its single pilot? is that correct? If so, so you would need the endorsement to log any pic

Under the scenario the OP posted, he will never be acting as PIC. And he's probably not qualified to do so under Part 135.

The mere fact of logging PIC time under 61.51 does not presume that he is acting as PIC, although he could be, under Part 91, with the appropriate endorsements. But the endorsements are not required to log PIC time.

Assuming he gets the required SIC training, I'd expect that someone would give him the endorsement, if he were qualified to do so.

[Fly_Unity]

I got my high altitude already, so that is no problem.

I asked the lead pilot about logging PIC using the sole manipulator rule, and I think he thought I was crazy, but he didnt seem to know much himself.

If that is the case, what would keep some of these Regional FO from getting typed and logging their hours as PIC?
Also what about if the autopilot is on during my leg? am I the sole manipulator?

[TFaudree_ERAU]

Originally Posted by Fly_Unity

Also what about if the autopilot is on during my leg? am I the sole manipulator?

Will you be manipulating the buttons, or at least asking the PNF to push them for you?

[tgrayson]

Originally Posted by Fly_Unity

If that is the case, what would keep some of these Regional FO from getting typed and logging their hours as PIC?

They could, except that the majors are probably primarily interested in the time in which the candidate was acting as PIC; in other words, as captain.

Also what about if the autopilot is on during my leg? am I the sole manipulator??

I believe the old Part 61 FAQs said the time was loggable.

[mojo6911]

If it was all part 91, I would say log all the sole manipulator time as PIC. Since it is a 135 op, I wouldn't mess with it, too much of a hassle.

[Dugie8]

Originally Posted by tgrayson

<<could I log this time when Im sole manipulator as PIC turbine time?>>

Yes.

<<what about even SIC time? cause its only single pilot certified>>

Do your op specs call for two pilots?

<<What about on the Part 91 empty legs?>>

Yes on PIC, no on SIC.

I may be wrong, but I just dug through our OpSpec manual and could find no reference to "requiring" an SIC in a single pilot airplane, ie a C90. I don't think there is an OpSpec that will give an operator the "ability" to have a second pilot in C90 type airplanes (single pilot) as a required SIC. The only time(s) I can think of when an SIC on C90 type airplanes is required is when you fly in excess of 8 hours, low vis take off and a couple of other situations (too lazy to dig up the regs).

[wrxpilot]

Originally Posted by Dugie8

I may be wrong, but I just dug through our OpSpec manual and could find no reference to "requiring" an SIC in a single pilot airplane, ie a C90. I don't think there is an OpSpec that will give an operator the "ability" to have a second pilot in C90 type airplanes (single pilot) as a required SIC. The only time(s) I can think of when an SIC on C90 type airplanes is required is when you fly in excess of 8 hours, low vis take off and a couple of other situations (too lazy to dig up the regs).

Two pilots are not required for part 91 in a King Air 90, but part 135 requires 2 pilots unless there is a deviation waiver in the company ops specs.

[Dugie8]

Originally Posted by wrxpilot

Two pilots are not required for part 91 in a King Air 90, but part 135 requires 2 pilots unless there is a deviation waiver in the company ops specs.

You sure about that, plenty of 135 Air Ambulance that run single pilot operations. Unless I am being a total bonehead I can't find a reg that requires two pilots on single pilot airplanes (C90, etc) unless for certain conditions, time, take off vis, etc. Also, Airnet is 135 and operates single pilot.

[WalterSobchak]

Part 1

Pilot in command means the person who:
(1) Has final authority and responsibility for the operation and safety of the flight;
(2) Has been designated as pilot in command before or during the flight; and
(3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.



No, you can not legitimately log the time as PIC either 135 or 91. 135 you have to be required in the op specs to log any of it. It meets the part 61 definition, but not the part 1. At an interview they want to know part 1 time. Hence why IOE doesn't count as PIC for CA's in 121. You are rated, designated, but not ultimately responsible.

[ppilot]

Originally Posted by Dugie8

You sure about that, plenty of 135 Air Ambulance that run single pilot operations. Unless I am being a total bonehead I can't find a reg that requires two pilots on single pilot airplanes (C90, etc) unless for certain conditions, time, take off vis, etc. Also, Airnet is 135 and operates single pilot.

Ummm...not to be harsh, but did you look at all?

§ 135.101 Second in command required under IFR.

Except as provided in §135.105, no person may operate an aircraft carrying passengers under IFR unless there is a second in command in the aircraft.

135.105 talks about autopilots; an appropriate op-spec with an approved autopilot allows this rule to be waived.

[Dugie8]

Originally Posted by ppilot

Ummm...not to be harsh, but did you look at all?

§ 135.101 Second in command required under IFR.

Except as provided in §135.105, no person may operate an aircraft carrying passengers under IFR unless there is a second in command in the aircraft.

135.105 talks about autopilots; an appropriate op-spec with an approved autopilot allows this rule to be waived.

Yup, looked at that, BUT if the company has the autopilot OpSpec, as most do. Can you log SIC since it is not required by the regs.

[ppilot]

Originally Posted by Dugie8

Yup, looked at that, BUT if the company has the autopilot OpSpec, as most do. Can you log SIC since it is not required by the regs.

Absolutely. It (the op-spec) allows you to fly single-pilot, but doesn't require you to.

[wrxpilot]

Originally Posted by WalterSobchak

No, you can not legitimately log the time as PIC either 135 or 91. 135 you have to be required in the op specs to log any of it. It meets the part 61 definition, but not the part 1. At an interview they want to know part 1 time. Hence why IOE doesn't count as PIC for CA's in 121. You are rated, designated, but not ultimately responsible.

Here's a letter from the FAA regarding these issues for Part 135 operators:

March 26, 1992


Mr. Michael G. Tarsa


Dear Mr. Tarsa:

Thank you for your letter of April 3, 1991, in which you ask questions about logging pilot in command (PIC) and second in command (SIC) time when operating under Part 135 of the Federal Aviation Regulations (FAR). We apologize that staff shortages, regulatory matters, and interpretation requests received prior to yours prevented us from answering your questions sooner.

Your letter presents the following scenario: a Part 135 certificate holder conducts operations in multiengine airplanes under instrument flight rules (IFR). The operator has approval to conduct operations without an SIC using an approved autopilot under the provisions of FAR 135.105. The operator has assigned a fully qualified pilot, who has had a Part 135 competency check, to act as SIC in an aircraft that does not require two pilots under its type certification. Although FAR 135.101 requires an SIC for Part 135 operations in IFR conditions, the autopilot approval is an exception to that requirement.

You correctly state that while the SIC is flying the airplane, he can log PIC time in accordance with FAR 61.51(c)(2)(i) because he is appropriately rated and current, and is the sole manipulator of the controls. Additionally, he has passed the competency checks required for Part 135 operations, at least as SIC.

You then ask two questions. The first asks whether the pilot designated as PIC by the employer, as required by FAR 135.109, can log PIC time while the SIC is actually flying the airplane. The answer is yes.

FAR 1.1 defines pilot in command:

(1) Pilot in command means the pilot responsible for the operation and safety of an aircraft during flight time.


FAR 91.3 describes the pilot in command:

(a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft.

There is a difference between serving as PIC and logging PIC time. Part 61 deals with logging flight time, and it is important to note that section 61.51, Pilot logbooks, only regulates the recording of:

(a) The aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of this part.

FAR 61.51(c) addresses logging of pilot time:

(2) Pilot in command flight time. (i) A recreational, private, or commercial pilot may log pilot in command time only that flight time during which that pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or when the pilot is the sole occupant of the aircraft, or, except for a recreational pilot, when acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

(ii) An airline transport pilot may log as pilot in command time all of the flight time during which he acts as pilot in command.

(iii) (omitted).

(3) Second in command flight time. A pilot may log as second in command time all flight time during which he acts as second in command of an aircraft on which more than one pilot is required under the type certification of the aircraft, or the regulations under which the flight is conducted.

As you can see, there are two ways to log pilot in command flight time that are pertinent to your question. The first is as the pilot responsible for the safety and operation of an aircraft during flight time. If a pilot is designated as PIC for a flight by the certificate holder, as required by FAR 135.109, that person is pilot in command for the entire flight, no matter who is actually manipulating the controls of the aircraft, because that pilot is responsible for the safety and operation of the aircraft.

The second way to log PIC flight time that is pertinent to your question is to be the sole manipulator of the controls of an aircraft for which the pilot is rated, as you mention in your letter. Thus, a multiengine airplane flown under Part 135 by two pilots can have both pilots logging time as pilot in command when the appropriately rated second in command is manipulating the controls.

We stress, however, that here we are discussing logging of flight time for purposes of FAR 61.51, where you are keeping a record to show recent flight experience or to show that you meet the requirements for a higher rating. Your question does not say if the second pilot in your example is fully qualified as a PIC, or only as an SIC. This is important, because even though an SIC can log PIC time, that pilot has not qualified to serve as a PIC under Part 135.

An example of this difference is FAR 135.225(d), which raises IFR landing minimums for pilots in command of turbine powered airplanes flown under Part 135 who have not served at least 100 hours as PIC in that type of airplane. Served and logged are not the same in this context, and no matter how the SIC logs his time, he has not served as a PIC until he has completed the training and check rides necessary for certification as a Part 135 PIC.

Approval for single pilot operations with use of an operative approved autopilot system under FAR 135.105 gives an operator an additional option in the conduct of operations. It does not mandate that all future flights be conducted in that manner. The operator can elect to fly trips with two pilots, as is otherwise required for flight in IFR conditions under FAR 135.101, using the second in command instead of the autopilot.

Your second question asks if, under the circumstances given above, the SIC can log time as SIC when the designated pilot in command is flying the aircraft. The answer is yes, as long as the certificate holder is using the SIC as a crewmember instead of exercising the autopilot authorization. In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option, but rather conducts an IFR flight using two qualified pilots. The two pilots are then "required by the regulations under which the flight is conducted", FAR 61.51(c)(3), and the assumption is that the second pilot (SIC) will function as a required crewmember, and SIC time may validly be logged. However, if for some reason another qualified pilot "rides along" and does not function as a crewmember, then second in command time may not be validly logged.

This interpretation has been prepared by Arthur E. Jacobson, Staff Attorney, Operations Law Branch, Regulations and Enforcement Division; Richard C. Beitel, Manager. It has been coordinated with the Manager, Air Transportation Division, and the Manager, General Aviation and Commercial Division, Flight Standards Service.

We hope this satisfactorily answers your questions.

Sincerely,


Donald P. Byrne
Assistant Chief Counsel
Regulations and Enforcement Division

[Dugie8]

Originally Posted by ppilot

Absolutely. It (the op-spec) allows you to fly single-pilot, but doesn't require you to.

Cool, learn something new every day. I would say this thread should go into some kind of sticky or treasure trunk, it has all the appropriate questions, answers and the correct letter of interp from the FAA.

[SteveC]

Done.