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6 Answers

SIC time counting towards ATP flight time

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FAA Regulations

Hello.  First off, I wouldn't even be asking this question had I realized that my aviation degree isn't eligible for the R-ATP, but I am currently time building as an SIC with one of those Line Training part 135 cargo programs that have become super popular due to the new flight rules.  Since I have recently determined that I am not eligible for the R-ATP and my school will not have approval before I hit 1500, I have been looking for other ways to make the FAR's work for me. Recently I have determined that I am eligible for about 100 of FTD time under 61.159, but it also mentions my SIC time counting towards the 1500 hours that I need for the ATP.  If so (I have over 500 hours of SIC time) it would mean I would be done and hence save some money (a lot of money, I now know why people become CFI's).  But it also may mean counting flight time twice, hence my confusion.  This falls directly above the Flight Engineer time which I know 1/3 counts towards your total time and up to 500 can be used for you ATP.  I just need to know how I can make this work for me, if it can work for me at all. I already know I can log Total Flight time, but, does my SIC count towards my 1500 hour time (as in I now only need 1000 hours of actual flight time) or does it not.

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6 Answers

  1. Kris Kortokrax on Feb 17, 2014

    I need more information to answer your question.

    What kind of airplane are you flying as SIC?

    What kind of FTD was used and under which part of the regulations was the training done?

    What is an example of the double counting to which you refer?

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  2. Aleks Udris on Feb 17, 2014

    The “1500 hours” associated with the ATP (with or without restricted privileges) refers to total flight time. So, if you’re legally logging SIC time, that counts toward the 1500. You also need 250 hours of PIC, for an ATP with restricted privileges, which also counts toward the 1500.

    Even if you don’t qualify for a total time reduction for the restricted ATP, all pilots can get the certificate with restricted privileges.

    We wrote a detailed breakdown here: https://www.boldmethod.com/blog/2013/08/1500-hour-rule-restricted-atp/


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  3. Mark Kolber on Feb 17, 2014

    The problem with “SIC time” that makes it difficult to answer your question is that some people log SIC time in operations they are not entitled to. Assuming your SIC time qualifies and is logged under 61.51(f) — essentially qualified and acting as SIC in an aircraft or operation that requires (under FAA rules, not a company’s or insurer’s rules) more than one pilot — the flight time counts toward total flight time for the ATP.

    One item in your question is a bit confusing:

    But it also may mean counting flight time twice

    That’s not going to happen. If you, for example, are the legitimate SIC on a 2 hour flight but also entitled to log PIC because you are the rated flying pilot for that flight, while you may be able to put the 2 hours in two different columns in your logbook, it’s still only 2 hours of flight time, not 4.

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  4. Kris Kortokrax on Feb 18, 2014


    61.51 (f) allows logging SIC time only if:
    the type certificate for the aircraft requires two pilots or
    the regulations under which the flight is conducted require two pilots.

    61.159 (c)(1) allows you to count SIC time toward the 1500 required by 61.159 (1) if:

    i) more the one pilot is required by the AFM or Type Certificate or the regulations under which the flight is conducted,

    ii) the flight is conducted under 91K, 121 or 135 and an SIC is required under the appropriate part

    iii) there is more the one pilot required by the operating rules of this chapter (Chapter I, which emcompasses Part 1 through Part 199).

    135.99 (b) No certificate holder may operate an aircraft without a second in command if that aircraft has a passenger seating configuation, excluding any pilot seat, of ten seats or more.

    135.101 “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 allows use of an autopilot in lieu of an SIC in certain circumstances.

    What does all this mean? I means that for a cargo operation, unless you are flying an airplane whose type certicate requires two pilots, you can’t log SIC or count it towards the ATP because there is no regulation which requires an SIC for 135 cargo operations. An SIC is only required if there are passengers on board on an IFR flight or passengers on board an airplane with ten or more passenger seats. It is unlikely that a cargo plane would have any passenger seats. If you are flying right seat in a Caravan or a 421 or a King Air 100 for example, you could not log SIC time or use it for an ATP as a result of a 135 cargo flight.

    Further, see the Nichols (2009) legal interpretation which discusses 91 and 135 SIC matters. It appears to state that if the operator has OpSpec A015 and may operate as a single pilot with an autopilot and chooses to use an SIC, that if the autopilot is engaged, the SIC is no longer a required crewmember and may not log SIC time.


    As regards the FTD time, 61.159 (a)(6) does allow up to 100 hours if the time was “accomplished as part of an approved training course in parts 121, 135, 141 or 142 of this chapter.” The other references to FS/FTD (61.159 (a)(3) and 61.159 (a)(4)(ii)) contain similar restricting language.

    If you got your FTD time under part 61, it appears that it cannot be used.

    Whenever something sounds too good to be true, it usually is.

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  5. Kris Kortokrax on Feb 20, 2014


    There is one other situation that might backfire on you. If, for instance, the Part 135 cargo hauler flies something like a Beech 1900 and they train you for an SIC type rating, they might lead you to believe that you could log PIC time based on manipulating the controls of an aircraft for which you are rated (category/class/type). There is a legal interpretation which deals with this scenario and it states that the holder of an SIC type rating may not log PIC time.


    They do allow logging PIC under 61.51(e)(4), but the Part 135 operator would need to have an approved Pilot in Command training program. The training program would need to specify the number of training hours. It could not be an open ended proposition which would allow one to log an unspecified number of PIC hours.

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  6. prakash on Mar 29, 2014

    Hello..my situation is I have 1500 copilot time in DHC-6 twin otter .200 hours Single engine ..15 HOUR PISTON ENGINE MULTI IN TOTAL 1700 Hours ..I have Only 11hour of night but I m planning to fly night time in Usa as required..I have all other IFR and cross country requirements including 250 pic hours …my question is do my flight experience meet Atpl requirement…??if it meets I am planning to get Faa atpl before august when new rules kicks in…my country does not issue atpl directly they need icao license before issuing local atpl ..

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