ATP Second In Command Type Rating

I have to disagree. I don't see anywhere in the regulations stating that the training HAS to be done under part 135/121. I've read this section many times and don't believe it says anything of the sorts. Also, the FAA Office of Chief Council issued issued a letter dated July 2016 about this very thing. It clearly states that a properly qualified and typed part 91 PIC may do ALL the training required by 61.559(b) as well as the required endorsements and signing of 8710. The same PIC is authorized to do all of this even without having any sort of CFI.

https://www.faa.gov/about/office_or.../2016/Axton - (2016) Legal Interpretation.pdf

So unless there is something I'm missing, its not sketchy at all. It is perfectly legal to do so. I'm not going to argue whether it is prudent or not, but it is definitely legal.

That link leads to a 404 not found page.

At the moment I am unable to post the references, many of them refer to definitions. However in a nutshell: ATPs may instruct while in engaged in air transportation service [61.167(a)(2)] (Part 91 is not defined as an air transportation service). SIC training does not have to be under 121/135 but if the training is being conducted under 61/91, then the person providing the training must be an instructor. This is how The staff at a 142 sim center may not be CFIs but they are permitted to instruct based on their ATP and the authority of the training center.



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91 - ground school, 3 bounces and single engine ops

135 - same, plus we did all the steeps/stalls/etc, much more in terms of single engine ops and the instrument part (including single engine approaches and go-arounds), although that might have been to satisfy other 135 things

Doesn't 135 SIC require a 293? They can get a 297 on their checkride but that's essentially pointless every six months.
 
Yup. Just ground school, memory items,
Imitations and three successful bounces.

In the wonderful world of sketchy part 91 operations many people think they can get the SIC sign off from an ATP. That is incorrect unless both the ATP signing off the pilot and the student are conducting training under an approved 135/121 program or the ATP is also an instructor and signing off as a CFI rather than ATP.
This is not reserved for 135/121 operators. Although NOT required, many Part 91 operators have an FFA approved training program that allows a Company ATP to instruct for SIC. The SIC candidate must be a company employee, the training must comply with the approved training, and it must support company operations.
 
That link leads to a 404 not found page.

At the moment I am unable to post the references, many of them refer to definitions. However in a nutshell: ATPs may instruct while in engaged in air transportation service [61.167(a)(2)] (Part 91 is not defined as an air transportation service). SIC training does not have to be under 121/135 but if the training is being conducted under 61/91, then the person providing the training must be an instructor. This is how The staff at a 142 sim center may not be CFIs but they are permitted to instruct based on their ATP and the authority of the training center.

Not sure why the link didn't work for you. Just tried it again and it works fine for me. I'll attach the FAA letter I referenced to this post. The letter is quite clear that no CFI is required and that an qualified and typed 91 PIC is sufficient for giving the training required by 61.55b as well as the logbook endorsement and signing of 8710 on IACRA.
 

Attachments

I did a Lear SIC ride for part 135 and it was really the hardest checkride that I've ever done, even more than my CRJ part 121 ride. No hyperbole there! I have two further SIC types though and I agree, the latest one that I did was a joke. Not even an official checkride for that one.
While going through LRJ initial there was a guy there to get an SIC "type". He was employed by a certain cargo company as an FO. I felt really bad for this guy. He was sharp and presented as dedicated. He was a sim partner to one of us "full type" applicants and had to do everything we "full type" applicants did, but at the end he got only some amorphous, pseudo type rating.
 
Not sure why the link didn't work for you. Just tried it again and it works fine for me. I'll attach the FAA letter I referenced to this post. The letter is quite clear that no CFI is required and that an qualified and typed 91 PIC is sufficient for giving the training required by 61.55b as well as the logbook endorsement and signing of 8710 on IACRA.

That is an interesting departure from the previous position. Also, I didn't see anywhere in his letter that mentioned instruction by an ATP, but rather qualified trainer, with reference to management pilots. To me, since they omitted any reference to ATP, it seems as if they left the door open to continue allowing 142 sim center employees and in-house management pilots perform training.

Overall, an interesting discovery.
 
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