Logging SIC in a Single Pilot Aircraft 91 Operation

[caliginousface]

Hello mangs,
Lets say there's a company who flies a Caravan under 135, and due to insurance and/or ops specs, an SIC is required. This is not to be confused with CapeAir style "if autopilot is inoperative, SIC required," but just plain ol' required.

Then, lets say there's another company who lets say flies a 210, but its part 91, and due to the nature of the operation, it was determined two pilots were required by the company and/or insurance.

I already know the consensus on logging SIC in single pilot aircraft, and heard of people interviewing at SkyWest and other operators being laughed out the door for logging such time.

What makes it ok for an operator like Cape Air to have an SIC and have them log in a 402 even though it's certified single pilot, and not ok to have a part 91 single pilot aircraft have an SIC and log it?

 

[jtrain609]

It's all about the rules you operate under.

Part 135 regulations say that for passenger carrying operations (and I'm being brief here and going off what I know about this, mostly because I'm too lazy to look up the actual regs and quote them to you) you're required to have two pilots.

In lieu of the second pilot, you can *POSSIBLY* use an autopilot. There's nothing saying the FAA has to grant you the ability to do this. Now you can operate that single pilot airplane with pax on board with one pilot instead of the required two. Remember, the AIRPLANE is single pilot, the REGULATION YOU WORK UNDER requires two.

Under part 91 there is no such provision. If an airplane is single pilot certified, then you fly it single pilot with or without people, with or without compensation.

If you want to understand WHY, I think this all makes a tiny bit more sense. Part 135 companies can hold out and say to the public "HEY! Wanna go fly somewhere!? We'll take you there for a fee!" where a part 91 commercial operation is either subpart K., which is fractionals and a whole different can of worms, or it means it's a corporate, but in essense, private owner/operator.

Basically by requiring two pilots for part 135 operations the FAA is attempting to protect the public, where in part 91 operations there's no public to protect, and therefor less rules about the issue.

Or at least that's how I've always understood, and taught it. Midlifeflyer is really the guru on this topic around here, but that's how I see things.

 

[MikeD]

How often has this question come up?

There has to be a ton of threads on it already. If you search, you'll find it 10 times over. No slam, just saying that the answer is already in the system here.

 

[jtrain609]

How often has this question come up?

There has to be a ton of threads on it already. If you search, you'll find it 10 times over. No slam, just saying that the answer is already in the system here.

n00b

 

[minitour]

It's all about the rules you operate under.

Part 135 regulations say that for passenger carrying operations (and I'm being brief here and going off what I know about this, mostly because I'm too lazy to look up the actual regs and quote them to you) you're required to have two pilots.

135.101

In lieu of the second pilot, you can *POSSIBLY* use an autopilot. There's nothing saying the FAA has to grant you the ability to do this. Now you can operate that single pilot airplane with pax on board with one pilot instead of the required two.

135.105

Remember, the AIRPLANE is single pilot, the REGULATION YOU WORK UNDER requires two.

61.51(f) - Allows logging of SIC if the operating regulation requires a second pilot, be it a 172 or a Hawker 800.

Under part 91 there is no such provision. If an airplane is single pilot certified, then you fly it single pilot with or without people, with or without compensation.

Depends on the type certificate. The plane I fly is single pilot..........if the pilot has a single pilot type, and the aircraft has certain equipment and the equipment is functioning properly. If not, it becomes a two pilot airplane and the pilot must have a current 61.58 PC within the past 12 or 24 months...depending on what else you're flying.

So it really depends on how the type certificate requires the flight crew.

Basically by requiring two pilots for part 135 operations the FAA is attempting to protect the public, where in part 91 operations there's no public to protect, and therefor less rules about the issue.

Except that under part 91, I need the weather at an alternate to be at least 600/2, vs 400/1 under 135. That one still confuses me. No, not the reg itself...the intent of the reg. You'd think to protect the public, we'd have higher weather mins for alternate airports than part 91, not lower.

-mini

 

[caliginousface]

How often has this question come up?

There has to be a ton of threads on it already. If you search, you'll find it 10 times over. No slam, just saying that the answer is already in the system here.

I looked

I guess what I was looking for was how SIC C208 time is sometimes maybe ok, but anything lower, whether it be 135 or 91 is not.

I have some people telling me they're logging SIC in a less than C208 aircraft as our ops manual require two pilots, we are 91.

 

[MidlifeFlyer]

I have some people telling me they're logging SIC in a less than C208 aircraft as our ops manual require two pilots, we are 91.

If your OpSpecs in fact =require= (not just authorize) two pilots for all flights, then those flights have more than one pilot required by the regulations under 61.51(f). Generally speaking, OpSpecs are legal flight requirements for the company they apply to.

OTOH, a Part 91 operator's choice to use two pilots (or even a mandate of the operator's insurance company) does not make the flights ones that require more than one pilot under the regs, even if they are put into a non-required and non-FAA-okayed operations manual.

 

[minitour]

I looked

I guess what I was looking for was how SIC C208 time is sometimes maybe ok, but anything lower, whether it be 135 or 91 is not.

I have some people telling me they're logging SIC in a less than C208 aircraft as our ops manual require two pilots, we are 91.

As a 91 operator, do you have Mspecs issued to you or is this just your company's SOP/FOM?

-mini

 

[phoenix 23684]

Ok how about an operation under part 91 flying ISR missions in Afghanistan under military rules in a single pilot certificated airplen? We are required two pilots per AOR rules, but we log it as P1,P2.

 

[Stone Cold]

Ok how about an operation under part 91 flying ISR missions in Afghanistan under military rules in a single pilot certificated airplen? We are required two pilots per AOR rules, but we log it as P1,P2.

If you are flying under N registration, Part 91, then the military rules, ISR missions, and country go out the window. What does Part 91 say? You are operating an N registered airplane under Part 91. Do you have OpSpec that require 2 pilots? If not, then this thread applies to you also.

And one last thing, P1, P2 stuff is military and JAA world. It has no real correlation in the FAA's CFR's. Just see the logging vs. being PIC threads here...there is no ambiguity who is P1 and P2.

Edit to add: I do not know how AOR rules affect this...hmm, good question there. Is it the same as OpSpecs?

 

[puddlejumper]

Except that under part 91, I need the weather at an alternate to be at least 600/2, vs 400/1 under 135. That one still confuses me. No, not the reg itself...the intent of the reg. You'd think to protect the public, we'd have higher weather mins for alternate airports than part 91, not lower.

-mini

I'd be willing to bet that your OpSpecs don't say that. Most likely, you are supposed to add 400 ft. to the CAT I HAT and 1 sm to the visibility landing minimums. If there are two ILSs to two different suitable runways, you can add 200 ft and 1/2 sm to the higher minimums to determine your alternate requirements.

It's been a while for me, but you may want to look over C055 again when you get a chance.

Sorry for the thread drift. I had a charter flasback!

 

[minitour]

I'd be willing to bet that your OpSpecs don't say that. Most likely, you are supposed to add 400 ft. to the CAT I HAT and 1 sm to the visibility landing minimums. If there are two ILSs to two different suitable runways, you can add 200 ft and 1/2 sm to the higher minimums to determine your alternate requirements.

So two ILSs to two different suitable runways using two separate navaids down to 200-1/2...plus 200-1/2...equals 400-1. What did we bet?

It's been a while for me, but you may want to look over C055 again when you get a chance.

You might want to do the same.

-mini

 

[RynoB]

Here is the LOI from the FAA just this year. They use a CE-525 for an example. The letter covers logging SIC under both 91 and 135 operations.

http://www.faa.gov/about/office_org...interpretations/data/interps/2009/Nichols.pdf

The last paragraph of the LOI is the one I find the most interesting:

Under sections 135.1 01 and 135.105, two pilots are required when carrying passengers
under IFR unless an operative and approved autopilot system is installed, in which case one
pilot is required. Although section 135.105 allows single-pilot operations with the use of an
operative approved autopilot system, it does not require that all future flights be conducted
in that manner.​

​

​

​

See Tarsa Interpretation (Mar. 26, 1992). In other words, the operator can
elect either to operate under IFR with one pilot using the autopilot system or with two pilots,
with the second pilot acting as SIC, without using the autopilot system. See id. Provided
the certificate holder elects before the IFR operation to not use the autopilot system, then
two pilots are required by the regulations under which the flight is conducted, and the pilot
designated as SIC may log SIC flight time. If the autopilot system is used, then the pilot​

designated as SIC is not a required flight crewmember and may not log SIC time.

 

[phoenix 23684]

If you are flying under N registration, Part 91, then the military rules, ISR missions, and country go out the window. What does Part 91 say? You are operating an N registered airplane under Part 91. Do you have OpSpec that require 2 pilots? If not, then this thread applies to you also.

And one last thing, P1, P2 stuff is military and JAA world. It has no real correlation in the FAA's CFR's. Just see the logging vs. being PIC threads here...there is no ambiguity who is P1 and P2.

Edit to add: I do not know how AOR rules affect this...hmm, good question there. Is it the same as OpSpecs?

Yes, our OpSpecs and the military require two pilots at all times. Even though we are 91, we still have to abide by all the military rules. the good thing here is that we take turns at the seats. We have to be able to fly centerline within 60 ft of our target from 10,000 ft so it wears you out after a 5 hour day. The right seater is busy keeping you out of trouble, radio and airspace.

 

[Stone Cold]

Yes, our OpSpecs and the military require two pilots at all times. Even though we are 91, we still have to abide by all the military rules. the good thing here is that we take turns at the seats. We have to be able to fly centerline within 60 ft of our target from 10,000 ft so it wears you out after a 5 hour day. The right seater is busy keeping you out of trouble, radio and airspace.

Aerial survey grids??

The longest time aloft I had doing this (granted it was a 172, but same tolerances basically) was somewhere around 6 hours in 1 shot. I'd ave to look at the logbook to see exactly how long it was, but I was beat, and ended up going back up after fueling for another 2 or 3 hours. Ugh, I do not miss that day!!!