Drchaser

New Member
Hi All,

Lets say your an SIC in a 135 operation, that operates a multi engine airplane which does not require a type rating nor a first officer. However, you can legally log SIC time because of OpSpecs. If you are fully rated, meaning you have your multi engine rating, and have completed an SIC ride, can you log pic time to meet cross country PIC time requirements for your R-ATP? Based on my understanding of the regs copied below, it looks like you can. Also see the link to the FAA letter of authorization on the subject. What are your thoughts? Am I missing something?

§ 61.51 Pilot logbooks.
...
(e)Logging pilot-in-command flight time.
(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate

FAA Interpretation

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2012/counsil - (2012) legal interpretation.pdf
 
Let me see if I got this right.

Your crew qualification for the 135 Op is SIC???
For an airplane which requires no SIC?
But you are flying as SIC in a two crew 135 Op? ... Because? The a/c has no autopilot? or...?
But you are fully qualified to operate the a/c as PIC per the a/c type requirements?
But you are not operating it as PIC because you accepted this job in this role in this hiring environment???

You can NOT log time in this or any other aircraft because you have not yet developed adequate aeronautical decision-making skills.

:):):)
 

Drchaser

New Member
Let me see if I got this right.

Your crew qualification for the 135 Op is SIC???
For an airplane which requires no SIC?
But you are flying as SIC in a two crew 135 Op? ... Because? The a/c has no autopilot? or...?
But you are fully qualified to operate the a/c as PIC per the a/c type requirements?
But you are not operating it as PIC because you accepted this job in this role in this hiring environment???

You can NOT log time in this or any other aircraft because you have not yet developed adequate aeronautical decision-making skills.

:):)
Alright Mr FAA I will not. Thank you for your thoughtful and professional answer. :)
 
Alright Mr FAA I will not. Thank you for your thoughtful and professional answer. :)
Oh, son, that was sooooooo far, far, far from the FAA.

Please note the smiley faces. FAA does not possess... or even acknowledge smileys.

Sorry for any butt-hurt I may have caused.

Questions are best considered for their value as tools of reflection and/or self reflection... not as moments for reactive response.
 
Last edited:

milleR

Well-Known Member
Hi All,

Lets say your an SIC in a 135 operation, that operates a multi engine airplane which does not require a type rating nor a first officer. However, you can legally log SIC time because of OpSpecs. If you are fully rated, meaning you have your multi engine rating, and have completed an SIC ride, can you log pic time to meet cross country PIC time requirements for your R-ATP? Based on my understanding of the regs copied below, it looks like you can. Also see the link to the FAA letter of authorization on the subject. What are your thoughts? Am I missing something?

§ 61.51 Pilot logbooks.
...
(e)Logging pilot-in-command flight time.
(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate

FAA Interpretation

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2012/counsil - (2012) legal interpretation.pdf
If you haven’t passed a .299 checkride (and .297 if applicable) then no, you cannot log PIC while flying under part 135. The 91 legs are a different story though.

https://www.govinfo.gov/content/pkg/CFR-2001-title14-vol2/pdf/CFR-2001-title14-vol2-sec135-299.pdf
 

xdashdriver

Well-Known Member
If you haven’t passed a .299 checkride (and .297 if applicable) then no, you cannot log PIC while flying under part 135. The 91 legs are a different story though.

https://www.govinfo.gov/content/pkg/CFR-2001-title14-vol2/pdf/CFR-2001-title14-vol2-sec135-299.pdf
299 and 297 rides only apply to being able to serve as PIC, they do not address logging PIC which is addressed under 61.51. The OPs letter of interpretation omits any reference to competency/proficiency and line checks because 61.51 only speaks about being rated to fly the aircraft.

Based on some preliminary research, if you are qualified to act as at least SIC for that 135 operator in that aircraft and you are PIC rated (Comm, Multi) for the aircraft then yes, you could log PIC for that time you are the sole manipulator. The reason you would have to be at least SIC qualified is for 135.115(a). You're not allowed to manipulate the controls under 135 unless you are employed by the certificate holder and are qualified in the aircraft.
 

Drchaser

New Member
299 and 297 rides only apply to being able to serve as PIC, they do not address logging PIC which is addressed under 61.51. The OPs letter of interpretation omits any reference to competency/proficiency and line checks because 61.51 only speaks about being rated to fly the aircraft.

Based on some preliminary research, if you are qualified to act as at least SIC for that 135 operator in that aircraft and you are PIC rated (Comm, Multi) for the aircraft then yes, you could log PIC for that time you are the sole manipulator. The reason you would have to be at least SIC qualified is for 135.115(a). You're not allowed to manipulate the controls under 135 unless you are employed by the certificate holder and are qualified in the aircraft.
That is how I interpreted it but wanted some clarification before calling the FAA. Boldmethod explains it better than I could here so I have attached the link to the article. I understand they are not the FAA but they are using FAA references.

Your Guide To Logging SIC Flight Time In 'Single Pilot' Airplanes
 

n57flyguy

Well-Known Member
Hi All,

Lets say your an SIC in a 135 operation, that operates a multi engine airplane which does not require a type rating nor a first officer. However, you can legally log SIC time because of OpSpecs. If you are fully rated, meaning you have your multi engine rating, and have completed an SIC ride, can you log pic time to meet cross country PIC time requirements for your R-ATP? Based on my understanding of the regs copied below, it looks like you can. Also see the link to the FAA letter of authorization on the subject. What are your thoughts? Am I missing something?

§ 61.51 Pilot logbooks.
...
(e)Logging pilot-in-command flight time.
(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate

FAA Interpretation

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2012/counsil - (2012) legal interpretation.pdf
Cross country PIC time?
 

Drchaser

New Member
Cross country PIC time?
Yes, I did more research on this and you can in fact log the flight as PIC. Logging and acting as PIC are two different things and there are numerous letter of interpretation on the FAA website that explains the subject with more clarity.
 

nibake

Powder hound
I'm not seeing that in 61.160. Where does it say you need 100 XC PIC?

Also, just curious, how have you gotten enough hours to be thinking about R-ATP and not gotten that?

Also, remember that the cross country time you need for ATP is not the same as Private/Commercial/Instrument, so that could make a difference, too.
 

Drchaser

New Member
I'm not seeing that in 61.160. Where does it say you need 100 XC PIC?

Also, just curious, how have you gotten enough hours to be thinking about R-ATP and not gotten that?

Also, remember that the cross country time you need for ATP is not the same as Private/Commercial/Instrument, so that could make a difference, too.
61.160 (d)(e)
(e) A person who applies for an airline transport pilot certificate under the total flight times listed in paragraphs (a), (b), and (c) of this section must otherwise meet the aeronautical experience requirements of§ 61.159, except that the person may apply for an airline transport pilot certificate with 200 hours of cross-country flight time.

61.159 (5)(I)
(5) 250 hours of flight time in an airplane as a pilot in command, or as second in command performing the duties of pilot in command while under the supervision of a pilot in command, or any combination thereof, which includes at least -
(i) 100 hours of cross-country flight time; and
(ii) 25 hours of night flight time.

I was an SIC in a part 135 operation so I did not get the chance to get a lot of cross country PIC. But I am all set now!
 

MidlifeFlyer

Well-Known Member
Also, remember that the cross country time you need for ATP is not the same as Private/Commercial/Instrument, so that could make a difference, too.
True, but there aren't a lot of situations in which you go more than 50 nm from your starting point without landing. Military (the reason for the rule) and pipeline patrol are two situations in which you might get a bunch of it, but otherwise, they are few and far between in the normal course of flying.
 

nibake

Powder hound
61.160 (d)(e)
(e) A person who applies for an airline transport pilot certificate under the total flight times listed in paragraphs (a), (b), and (c) of this section must otherwise meet the aeronautical experience requirements of§ 61.159, except that the person may apply for an airline transport pilot certificate with 200 hours of cross-country flight time.

61.159 (5)(I)
(5) 250 hours of flight time in an airplane as a pilot in command, or as second in command performing the duties of pilot in command while under the supervision of a pilot in command, or any combination thereof, which includes at least -
(i) 100 hours of cross-country flight time; and
(ii) 25 hours of night flight time.

I was an SIC in a part 135 operation so I did not get the chance to get a lot of cross country PIC. But I am all set now!
Awesome. Glad you got what you needed.

True, but there aren't a lot of situations in which you go more than 50 nm from your starting point without landing. Military (the reason for the rule) and pipeline patrol are two situations in which you might get a bunch of it, but otherwise, they are few and far between in the normal course of flying.
I used to instruct in Cirrus. They were fast enough that it was nothing to cross the 50NM threshold without landing while doing airwork, so if a person wanted to, the XC time could be built faster without any detriment to the student. I didn't care that much and just got the R-ATP anyway. I also had a fellow instructor who did smoke patrol without landings at other airports.
 

Roger Roger

Paid to sleep, fly for fun
True, but there aren't a lot of situations in which you go more than 50 nm from your starting point without landing. Military (the reason for the rule) and pipeline patrol are two situations in which you might get a bunch of it, but otherwise, they are few and far between in the normal course of flying.
My old flight school we had 2 or 3 airports that were about 48-50 NM away and had ILSs, they were frequent IFR practice destinations when the home field ILS was down. I pretty much figured if we did multiple approaches at any of those airports we crossed the 50 NM line.
 
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