Logging SIC in Citation II

[tmb1998]

Good afternoon,

I have a question about logging SIC. The PIC will be getting his single pilot exception for the CE500 and I was wondering if I can still log SIC when flying right seat? Specifically, if the flight is conducted under Part 91 with two pilots on board (me being SIC typed).

Thanks!

 

[z987k]

Does it need an SIC per missing/inop equipment?

 

[Deleted member 27505]

Good afternoon,

I have a question about logging SIC. The PIC will be getting his single pilot exception for the CE500 and I was wondering if I can still log SIC when flying right seat? Specifically, if the flight is conducted under Part 91 with two pilots on board (me being SIC typed).

Thanks!

Lawyer/Academic answer... it depends. Generic, all-purpose answer given the facts stated? No, you may not, because you are not required to be there. In general, that's what the legal rationale for logging time boils down to... Does the operation require you to be present and acting in the capacity you're logging?

 

[ahw01]

@MidlifeFlyer

 

[Corporate Pilot]

If the PIC does not have a copy of the exemption on board he can not exercise the privileges of the exemption and requires an SIC.

 

[dustoff17]

The answer lies with @Corporate Pilot above.....
IF the PIC does not opt to carry the exemption form, you may log time. If he carries it, you may NOT because you are not a "required" crew member. The type of operation is not a factor with regards to this question.

Best thing for you to do is to discuss this with the PIC; there is no NEED for him to carry the exemption when you're going to be there. He MUST carry it when he doesn't have an SIC. He should understand and work with you as it doesn't affect him at all as far as his logging.

P.S. I have more than 700 hours of this type of SIC flying. I was there but not "required" under the Cert/FARs. I log this time as "aviation experience" in a separate column in my log book. When asked my total time (i.e. resume, job application, etc.), I do not include these hours but I ALWAYS make sure they are reflected somewhere in my paperwork.

 

[tmb1998]

The answer lies with @Corporate Pilot above.....
IF the PIC does not opt to carry the exemption form, you may log time. If he carries it, you may NOT because you are not a "required" crew member. The type of operation is not a factor with regards to this question.

Best thing for you to do is to discuss this with the PIC; there is no NEED for him to carry the exemption when you're going to be there. He MUST carry it when he doesn't have an SIC. He should understand and work with you as it doesn't affect him at all as far as his logging.

P.S. I have more than 700 hours of this type of SIC flying. I was there but not "required" under the Cert/FARs. I log this time as "aviation experience" in a separate column in my log book. When asked my total time (i.e. resume, job application, etc.), I do not include these hours but I ALWAYS make sure they are reflected somewhere in my paperwork.

Ok, this is exactly what I was thinking. If the pilot does not want to exercise privileges of the single pilot exemption, then he can simply act as PIC (no SP paperwork) and then a SIC would be required. Thanks for all of your comments!

 

[CoffeeIcePapers]

Ok, this is exactly what I was thinking. If the pilot does not want to exercise privileges of the single pilot exemption, then he can simply act as PIC (no SP paperwork) and then a SIC would be required. Thanks for all of your comments!

Keep in mind that you need to meet the training requirements of 61.55(b) to act as SIC under this scenario.

 

[dustoff17]

Another point to make here: IF the PIC decides he wants to carry his exemption and is not willing to work with you on this, find another job.

 

[Corporate Pilot]

I think it is a stupid reg. As long as the SIC is qualified and the flight is conducted as a crew why should it matter that the PIC has an SP exemption? The airplane is type certified requiring two pilots. Why should having a binder of maybe 12 pages, on board, determine if the SIC can log SIC time? I know rules are rules.

 

[knot4u]

I've heard rumors of a certain pilot that used to routinely put a warm body in the right seat of a lear for personal flights. Never crashed, maybe it isn't that hard.

 

[MidlifeFlyer]

@MidlifeFlyer

The question seems to be addressed in the 2009 Nichols Letter. The interpretation discusses both (1) a pilot type-rated single pilot in a Citation and, separately, (2) the Part 135 rule about using an autopilot instead of a SIC in IFR passenger ops. It treats the two very differently. Electing not to use the autopilot allows the use of the required SIC. But there doesn't appear to be any basis for electing to "unqualify" the single-rated pilot so the SIC becomes required.

Just passing it on. Doesn't sound like the most well thought-out interpretation I've seen.

 

[dustoff17]

The question seems to be addressed in the 2009 Nichols Letter. The interpretation discusses both (1) a pilot type-rated single pilot in a Citation and, separately, (2) the Part 135 rule about using an autopilot instead of a SIC in IFR passenger ops. It treats the two very differently. Electing not to use the autopilot allows the use of the required SIC. But there doesn't appear to be any basis for electing to "unqualify" the single-rated pilot so the SIC becomes required.

Just passing it on. Doesn't sound like the most well thought-out interpretation I've seen.

At the risk of getting into an "argument"...……

It's important to point out that Nichols and several other Interpretation Letters on this particular subject are based on the Citation 525 Series of aircraft and NOT the 500 Series. The difference is that the 525 are Type Certificated as Single-Pilot Aircraft and the 500 Series are "two pilots required". In a 525, no exemption letter is required to fly single pilot.

In Nichols, the Certification of the PILOT was an integral part of the question presented to the FFA (yeah, I know). In a 525, I can hold a 525 Type Rating and an SIC is required. IF (big IF), I hold a 525S type rating, I do NOT "require" an SIC.....UNLESS the autopilot is inop. If I hold a 525S type Rating, then, as @MidlifeFlyer mentioned, I can't "unqualify" myself just so the pilot next to me can log time, this isn't an option. I can't unqualify myself because the training, and the "S" in this discussion, are part of my type rating and qualification to operate the airplane.

A pilot can not achieve a 500S type rating as it does not exist. In a 500 series, the only way to fly single pilot is with an exemption letter. A pilot holding an exemption has the option to NOT exercise the authority of the exemption by simply NOT having the Letter in their possession during the flight.

 

[MidlifeFlyer]

At the risk of getting into an "argument"...……

It's important to point out that Nichols and several other Interpretation Letters on this particular subject are based on the Citation 525 Series of aircraft and NOT the 500 Series. The difference is that the 525 are Type Certificated as Single-Pilot Aircraft and the 500 Series are "two pilots required". In a 525, no exemption letter is required to fly single pilot.

In Nichols, the Certification of the PILOT was an integral part of the question presented to the FFA (yeah, I know). In a 525, I can hold a 525 Type Rating and an SIC is required. IF (big IF), I hold a 525S type rating, I do NOT "require" an SIC.....UNLESS the autopilot is inop. If I hold a 525S type Rating, then, as @MidlifeFlyer mentioned, I can't "unqualify" myself just so the pilot next to me can log time, this isn't an option. I can't unqualify myself because the training, and the "S" in this discussion, are part of my type rating and qualification to operate the airplane.

A pilot can not achieve a 500S type rating as it does not exist. In a 500 series, the only way to fly single pilot is with an exemption letter. A pilot holding an exemption has the option to NOT exercise the authority of the exemption by simply NOT having the Letter in their possession during the flight.

No argument from me. I realized immediately that the exemption vs rating issue could lead to a different result. That's why I was just "passing it on" and not trying to interpret it for this situation.

The letter presents two permutations. In one the autopilot condition for single pilot use can be "waived" by the operator; in the other the pilot's type rating can't.

The question is whether the exemption letter is closer to one or the other. Is the letter about equipment vs pilot qualification in general? Or is it only about ratings vs anything not involving ratings (including not having a piece of paper in possession).

I don't claim to have a solid answer on this one.

 

[MikeOH58]

How about this. The industry is so good right now, go take a damn job in an airplane that requires two pilots and is going to advance your career and pay more than a citation II.

No offense but it’s 2019 - Citation II time isn’t doing much for your future or making you stand out amongst your peers. Money is money and we all have to pay the bills but if I were in your shoes I would be actively seeking employment in a more relevant type where I didn’t have to wonder if Tom in the left seat has his single pilot paperwork today.

 

[nibake]

So does the exemption paperwork say something about it must be in the pilot's possession to be exercised? If so, that is a funny and probably unintentional loophole that the FAA blundered into. If it's there, though, you might as well use it!

 

[MidlifeFlyer]

So does the exemption paperwork say something about it must be in the pilot's possession to be exercised? If so, that is a funny and probably unintentional loophole that the FAA blundered into. If it's there, though, you might as well use it!

It is. Here's an example of the exemption letter (you may have to tap the acknowledgment before viewing). The relevant part is #19 (the exemptions are actually issued to the training facility):

19. Each person must carry a copy of this exemption and a record from VUE documenting successful completion of its training and checking requirements aboard the airplane when operating under the terms of the exemption.

Now, this does not necessarily create a loophole. Most "loopholes" are in the mind of the person who sees it.

The requirement to carry a copy means that a single pilot who is ramp checked can be busted for not having it, just like he can be busted for not having his pilot or medical certificate accessible. That doesn't automatically mean a lack of qualification. Having a required document in possession is a distinct violation from not having the proper qualifications to begin with. Even away from aviation, driving a car without license in possession is a completely different offense than being an unlicensed driver.

To continue with a pilot certificate example with an extreme version, suppose a Part 121 airline captain lost his wallet on his way to the airport, and did a scheduled flight. The captain would be in violation of 61.3. But that would not suddenly mean he wasn't pilot in command, the FO was transformed into captain, the whole flight was illegal because it had only one pilot, etc, etc.

 

[mastermags]

I think it is a stupid reg. As long as the SIC is qualified and the flight is conducted as a crew why should it matter that the PIC has an SP exemption? The airplane is type certified requiring two pilots. Why should having a binder of maybe 12 pages, on board, determine if the SIC can log SIC time? I know rules are rules.

Because the SP certification is more important in the grand scheme of things than whether or not someone can ‘log’ SIC time.

 

[Cessnaflyer]

At the risk of getting into an "argument"...……

It's important to point out that Nichols and several other Interpretation Letters on this particular subject are based on the Citation 525 Series of aircraft and NOT the 500 Series. The difference is that the 525 are Type Certificated as Single-Pilot Aircraft and the 500 Series are "two pilots required". In a 525, no exemption letter is required to fly single pilot.

In Nichols, the Certification of the PILOT was an integral part of the question presented to the FFA (yeah, I know). In a 525, I can hold a 525 Type Rating and an SIC is required. IF (big IF), I hold a 525S type rating, I do NOT "require" an SIC.....UNLESS the autopilot is inop. If I hold a 525S type Rating, then, as @MidlifeFlyer mentioned, I can't "unqualify" myself just so the pilot next to me can log time, this isn't an option. I can't unqualify myself because the training, and the "S" in this discussion, are part of my type rating and qualification to operate the airplane.

A pilot can not achieve a 500S type rating as it does not exist. In a 500 series, the only way to fly single pilot is with an exemption letter. A pilot holding an exemption has the option to NOT exercise the authority of the exemption by simply NOT having the Letter in their possession during the flight.

Good information. I've been contacting for right seat in CJ2s and 3s and was going to ask this question. I am only doing to for money so hours aren't too important to me.

 

[Deleted member 27505]

Ok, this is exactly what I was thinking. If the pilot does not want to exercise privileges of the single pilot exemption, then he can simply act as PIC (no SP paperwork) and then a SIC would be required. Thanks for all of your comments!

I don't think the 500 type provides for an "SP Exemption". That comes into play with certain of the 560 models. In the 500 and 525 series, I believe you are either typed SP... or not. Upon receiving the type as a single pilot, your new certificate will have CE-500S, or CE-525S listed in your type rating list. Therefore, if your PIC is carrying his certificate, he's qualified as SP.