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6 Answers

Legally Logging SIC time in a single pilot airplane??

Asked by: 3784 views Commercial Pilot, FAA Regulations

I have recently been offered a job to fly right seat in a King Air (BE20). I understand the 200 is a single pilot airplane. The company is part 135 and wants me to go through 135 training (computers, ground, then sims). They said by doing this I could legally log SIC during all flights that had passengers. This seems to be a grey area that everyone debates. Can i legally log SIC this way? When I go to interview with a airline at 1500 hours, will they accept this SIC time? 

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6 Answers



  1. Tom on Apr 23, 2018

    I think, not saying 100% but if the 135 Operation requires, or insurance requires a second pilot for the airplane, you can log the SIC time.

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  2. Mark Kolber on Apr 24, 2018

    The FAR 61.51 rule on logging SIC is pretty straightforward – “more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted.”

    For Part 135, one such regulation is 135.101 which requires an SIC in IFR passenger-carrying operations. Another is OpSpecs. Once issued by the FAA for an operator, they have the force of regulation. So if the OpSpecs require more than one pilot, SIC time can be logged.

    But no, insurance company rules are not “regulations”. Nor is the desire of a company or a particular passenger to insist on two pilots.

    That, btw, may be in the process of changing. A Notice of Proposed Rulemaking (NPRM) in 2016 proposed a number of changes to the current rules. The ones about IFR currency – not requiring an instructor to maintain currency in a sim or FTD – have gotten the most discussion, but there is also one authorizing logging SIC time if the flights are part of an approved Part 135 SIC training program. Final issuance of the rule has been expected for months but we haven’t seen it

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  3. Kris Kortokrax on Apr 24, 2018

    Here is a link to the Nichols legal interpretation:

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2009/nichols%20-%20(2009)%20legal%20interpretation.pdf

    The wording appears to allow a 135 operator to elect to utilize an SIC or have the PIC fly using an autopilot (as authorized by OpSpec A015). It goes on to say that if the operator elects to use an SIC and the autopilot is used, then the SIC cannot log SIC time. This, to me, is absurd and goes against any concept of safety, but that is the way they worded the interpretation.

    So, since the BE200 is a single pilot airplane, you could not log SIC time while acting as an SIC if the autopilot is used.

    By the way, is the 135 operator going to pay for your training? It would seem odd that they would, if you are merely going to log SIC time until you can go to the airlines.

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  4. Clemson_Pilot on Apr 24, 2018

    Kris, The agreement discussed would be that I would pay for the initial training and every month I worked for the company I would receive part of the cost back over a years time.

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  5. KDS on Apr 24, 2018

    The FAR 61.51 rule on logging SIC is pretty straightforward

    Mark, you got a chuckle out of me when you wrote that one. Yes, to a lawyer, it may seem straightforward, but based on the amount of confusion I’ve seen on that an many other “logging” rules I’d say that what is straightforward to you confuses the heck out of a lot of folks.

    BTW, if you get a minute, look at the question about insurance in Alaska.

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  6. Mark Kolber on Apr 25, 2018

    KDS, I always chuckle internally when I say that. As a veteran of many discussions on that confusion, I’ve come to the conclusion about 90% of it is based on a refusal to believe the words mean what they say rather than any lack of clarity in the language. As I put in my signature block on a could of forums,

    “‘I don’t understand’ does not mean it’s grey.”

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