Ameriflight has petitioned the FAA to allow pilots to log more SIC time

JimNtexas

JimNtexas

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Jim - In Texas!
cargo operator Ameriflight has petitioned the FAA to allow pilots to log more time when flying as second-in-command (SIC) in Part 135 cargo operations where just one pilot is required. The petition was filed in February but just recently went live for public comment.
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Ameriflight Petition

When I first saw this article my thought was 'Exactly how does Ameriflight plan to use this rule to scam low time pilots'. I was wrong to think that.

Once I read the actual petition I realized that Ameriflight is asking a valid question, and they are doing in exactly the correct manner. They are asking for a formal rule making action from the FAA. They are avoiding the tiny twisty maze of twisty tiny Chief Counsel letters.

By following this path all aviation stakeholders will have a chance to offer comments and suggestions, and whatever final rule (if any) is adopted it will be a real regulation, not a letter in some GS-13's binder.

As far as their actual request, I haven't flown any part 135 so I'll leave it to those who have to comment on the actual SIC logging issue in question.
 
I don't see it as any different as logging time when you have a CFI sitting next to you, whats the big deal ?

Shoot thats how I got my start in helicopters, worked as a ground crew pumping gas, the owner would let me jump in to reposition from the hangar to the fuel pad, ferry flights, maintenance flights. .1 here .3 here and eventually I was flying tours as PIC.
 
There's no provision for logging time just because a CFI is sitting next to you.
 
Thanks for picking nits for no good reason instead of seeing the point, but to be specific -

61.51 (e) (C) (1)

61.51 (e) (D) (4) (iii)

61.129 (a) (4)
 
Jaybee, I think the issue is this. Ameriflight flies a lot of single engine and light twin GA airplanes. These airplanes do not require two pilots. Ameriflight is part 135 freight operator, not a flight school.

61.51 allows SIC logging on single pilot airplanes when two pilot are required by "... the regulations under which the flight is being conducted."

This is the rule that Ameriflight would like to see clarified or expanded. This is probably very much important to them now since the introduction of the 1500 rule for passenger operations.
 
It may also help them get folks up to snuff faster by allowing someone to log time on a revenue flight.
 
Yes sir, Jim in Tx - I get that, also don't need a CFI to sit next to me on a 61.129 (a) (4) flight but I can ;)

EDIT - again with the impressive safety record of aviation, what's the big deal if the guy in the second seat wiggles the stick :dunno:
 
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Sounds like they want people to be able to log time for riding along on a 1-pilot operations without being handcuffed by having two pilots required on all flights. IOW, they want to have their cake and eat it, too. Lotsa luck.
 
I've helped a number of young guys--and some who were not so young--get started in King Airs. They were all multi-rated and it was easy to get them co-pilot qualified under the normal "know the systems and emergency procedures and three takeoff/landings" and none required type ratings.

But since the planes are all single-pilot certified, they couldn't log the right-seat time even though they were trained and capable of doing so and performed them on a regular basis.

All of the trips were part 91 rather than 135, but I always thought the rule to be a bit unreasonable. I assume the operators would stretch any provision to the maximum as they always do, but can make the case for a change.
 
So, would this proposal, if adopted, make it easier for Ameriflight to attract pilots?
 
You will NEVER become a real PIC by having one ALREADY next to you to stomp his foot or loudly clear his throat whenever you are about to make a mistake. Saying that some guy who spent X number of hours flying with another more experienced pilot is the same as a PIC is a grave error.

In commercial operations a new captain flies with a training captain during their IOE. There is a minimum number of hours that must be flown in this configuration before said new captain can be signed off. Some guys make it in just the minimum amount of time, some guys (in the judgement of the IOE captain) need more time, and some guys are deemed unsuitable and will RIGHTLY never be a captain. This system has worked reasonably well for us here in the U.S. Lets not let the starry-eyed co-pilots that have never seen icing count that day as a day of PIC.
 
Palmpilot said:
So, would this proposal, if adopted, make it easier for Ameriflight to attract pilots?
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No, but it would make it CONSIDERABLY cheaper ! As they wouldn't have to pay a rate attractive enough to get someone experienced enough to step over to their operation.
 
Art VanDelay said:
You will NEVER become a real PIC by having one ALREADY next to you to stomp his foot or loudly clear his throat whenever you are about to make a mistake. Saying that some guy who spent X number of hours flying with another more experienced pilot is the same as a PIC is a grave error.
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funny... that's exactly how one becomes a PIC through primary training :yikes: :goofy: :rolleyes: :yes:
 
jaybee said:
funny... that's exactly how one becomes a PIC through primary training :yikes: :goofy: :rolleyes: :yes:
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Yes, but you aren't a real PIC until you fly transatlantic turbine flights in the left seat.
 
Nah, you aren't a real PIC until you turn the autopilot on, go out on the wing and knock the ice off with a hammer and chisel !!!

:rofl:
 
I see that they wrote their request in the form of a petition for exemption from the existing regulation, not a proposal for a change in the regulation.
 
In that case I'll expect a bit more deference in the future--sonny.:p

EdFred said:
Yes, but you aren't a real PIC until you fly transatlantic turbine flights in the left seat.
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So....here is my question...is Ameriflight having a hard time finding pilots who meet 135 PIC mins? In other words, are they proposing this so that they can hire folks below that and get them up to speed to put them in the left seat? Seems strange, because as far as 135 operators go, I have only heard good things about them from those who worked there. Kind of like the Southwest or FEDEX of 135 box haulers.

Maybe I am missing something, but it doesn't make whole lot of sense for them to care about getting guys hours to meet the new 121 mins.
 
JimNtexas said:
Jaybee, I think the issue is this. Ameriflight flies a lot of single engine and light twin GA airplanes. These airplanes do not require two pilots. Ameriflight is part 135 freight operator, not a flight school.
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No they don't. AMF only has twin engine equipment. PA-31-350's and the rest is turbine. BE-99, B1900, SA227 and EMB120. The only airplane that expressly requires an SIC is the EMB120
 
KSCessnaDriver said:
No they don't. AMF only has twin engine equipment. PA-31-350's and the rest is turbine. BE-99, B1900, SA227 and EMB120. The only airplane that expressly requires an SIC is the EMB120
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The B1900 and the SA227 may require a SIC if the PIC has the limitation on his type "SIC Required".

With that being said I'm not sure how Ameriflight does their type training, whether it's dual pilot or single pilot.
 
RotorAndWing said:
The B1900 and the SA227 may require a SIC if the PIC has the limitation on his type "SIC Required".

With that being said I'm not sure how Ameriflight does their type training, whether it's dual pilot or single pilot.
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Single pilot qualified.
 
Art VanDelay said:
You will NEVER become a real PIC by having one ALREADY next to you to stomp his foot or loudly clear his throat whenever you are about to make a mistake. Saying that some guy who spent X number of hours flying with another more experienced pilot is the same as a PIC is a grave error.

In commercial operations a new captain flies with a training captain during their IOE. There is a minimum number of hours that must be flown in this configuration before said new captain can be signed off. Some guys make it in just the minimum amount of time, some guys (in the judgement of the IOE captain) need more time, and some guys are deemed unsuitable and will RIGHTLY never be a captain. This system has worked reasonably well for us here in the U.S. Lets not let the starry-eyed co-pilots that have never seen icing count that day as a day of PIC.
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However, in the "commercial operations" you're talking about, the guys in the right seat can log SIC all day long because of the fact that 121 requires the second guy. Why shouldn't a non-required SIC at Ameriflight who is legitimately learning things be able to log SIC flight time? Nobody's talking about logging PIC here (for once).

I would prefer that the FAA simply change the rule for logging SIC such that this doesn't only apply to Ameriflight.
 
flyingcheesehead said:
However, in the "commercial operations" you're talking about, the guys in the right seat can log SIC all day long because of the fact that 121 requires the second guy. Why shouldn't a non-required SIC at Ameriflight who is legitimately learning things be able to log SIC flight time? Nobody's talking about logging PIC here (for once).

I would prefer that the FAA simply change the rule for logging SIC such that this doesn't only apply to Ameriflight.
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Being a PIC isn't just about being aeronautically knowledgeable and proficient it's about making good decisions when something goes wrong and having a HISTORY of making good decisions ON YOUR OWN.

When "something" goes wrong in the Ameriflight example there will always be the "actual" PIC there to make the decision - having that crutch is not the same as making the decision yourself. Who knows what course of action this "training PIC" would have made absent the other more experienced pilot in the cockpit.

It's VERY necessary for a pilot to have this period of mentoring whereby they can see how a PIC acts in lots of different situations but that's called being a COPILOT and logging that as being the same thing as being a captain is nowhere close to the same thing. I don't know how else I can get you to understand that.
 
But the same crew flying the same plane but with different opspecs could log both pic and sic time. How does that make sense?

Art VanDelay said:
Being a PIC isn't just about being aeronautically knowledgeable and proficient it's about making good decisions when something goes wrong and having a HISTORY of making good decisions ON YOUR OWN.

When "something" goes wrong in the Ameriflight example there will always be the "actual" PIC there to make the decision - having that crutch is not the same as making the decision yourself. Who knows what course of action this "training PIC" would have made absent the other more experienced pilot in the cockpit.

It's VERY necessary for a pilot to have this period of mentoring whereby they can see how a PIC acts in lots of different situations but that's called being a COPILOT and logging that as being the same thing as being a captain is nowhere close to the same thing. I don't know how else I can get you to understand that.
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Art VanDelay said:
Being a PIC isn't just about being aeronautically knowledgeable and proficient it's about making good decisions when something goes wrong and having a HISTORY of making good decisions ON YOUR OWN.

When "something" goes wrong in the Ameriflight example there will always be the "actual" PIC there to make the decision - having that crutch is not the same as making the decision yourself. Who knows what course of action this "training PIC" would have made absent the other more experienced pilot in the cockpit.

It's VERY necessary for a pilot to have this period of mentoring whereby they can see how a PIC acts in lots of different situations but that's called being a COPILOT and logging that as being the same thing as being a captain is nowhere close to the same thing. I don't know how else I can get you to understand that.
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How is that relevant? The Ameriflight petition is to allow the second pilot to log SIC, not PIC. :confused:
 
I've thought all along that Ameriflite is doing exactly that, although I don't pretend to understand all of the inner-workings that would make it happen.

Art VanDelay said:
Wayne,
That's one to ask the FAA - doesnt make sense to me either.
Art
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wabower said:
I've thought all along that Ameriflite is doing exactly that, although I don't pretend to understand all of the inner-workings that would make it happen.
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They could re-write the op-specs to require a SIC on the piston twins and everyone would be able to log. But then they would HAVE to have a SIC on every flight which is something they want to avoid.
 
I understand that part, having been in the unenviable position of explaining the vagaries of the current regs to pilots for many years.

My lack of knowledge is related to the various strategies and methods that they can employ to allow them to do it as they deem appropriate.

weilke said:
They could re-write the op-specs to require a SIC on the piston twins and everyone would be able to log. But then they would HAVE to have a SIC on every flight which is something they want to avoid.
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Art VanDelay said:
Being a PIC isn't just about being aeronautically knowledgeable and proficient it's about making good decisions when something goes wrong and having a HISTORY of making good decisions ON YOUR OWN.

When "something" goes wrong in the Ameriflight example there will always be the "actual" PIC there to make the decision - having that crutch is not the same as making the decision yourself. Who knows what course of action this "training PIC" would have made absent the other more experienced pilot in the cockpit.

It's VERY necessary for a pilot to have this period of mentoring whereby they can see how a PIC acts in lots of different situations but that's called being a COPILOT and logging that as being the same thing as being a captain is nowhere close to the same thing. I don't know how else I can get you to understand that.
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Again, this is not about PIC. This is about SIC. Whether Ameriflight has their people do IOE with a training captain in the right seat or not, I don't know - But their captains won't have anything different than they do now if the regs are changed.

I'm thinking that they're trying to come up with a better way for people to get to the amount of experience they need. Which is better preparation for a new Ameriflight captain: A thousand hours in the right seat of Ameriflight's operations, learning about the operation of a twin turbine aircraft at night in weather while going places (which they currently can't log), or a thousand hours of bang-and-goes in the pattern at Podunk Muni in the right seat of a C152, which is loggable?
 
wabower said:
I understand that part, having been in the unenviable position of explaining the vagaries of the current regs to pilots for many years.

My lack of knowledge is related to the various strategies and methods that they can employ to allow them to do it as they deem appropriate.
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I dont think the FAA will be too keen on allowing them to just switch back and forth as they please. Training for single pilot and two-crew is different, switching back and forth between the two concepts on the same airframe may have a negative effect on safety.

A couple of years ago, one of the lab companies that flies part 91 experienced a hull loss at Teterboro when the cockpit responsibilities between the experienced captain and the 'ride along SIC' were not clearly divided. Unless they come up with clear procedures to switch back and forth between single pilot and two-crew, that'll be a difficult sell.
 
flyingcheesehead said:
I'm thinking that they're trying to come up with a better way for people to get to the amount of experience they need. Which is better preparation for a new Ameriflight captain: A thousand hours in the right seat of Ameriflight's operations, learning about the operation of a twin turbine aircraft at night in weather while going places (which they currently can't log), or a thousand hours of bang-and-goes in the pattern at Podunk Muni in the right seat of a C152, which is loggable?
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I posted this earlier, but I will ask it again....is that really what Ameriflight is trying to do here? Get wet behind the ears commercial pilots enough flight hours to hire them for 135 PIC?

If that is true, I am very suprised since Ameriflight has a pretty good rep as an employer and for those that want to go the 135 route, Ameriflight is seen as pretty desirable.

Just seems strange that they would be having trouble finding pilots to hire when the job boards are still full of pilots with 3-5000 hrs looking for work.
 
Fearless Tower said:
I posted this earlier, but I will ask it again....is that really what Ameriflight is trying to do here? Get wet behind the ears commercial pilots enough flight hours to hire them for 135 PIC?
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Actually it looks like they want to hire them for 135 SIC and have them build the hours in-house.
But rather than calling it SIC, they should probably call it 'loader with a license'. Yesterday I saw our local UPS feeder load up his 1900C. The trucks pull up to the plane, the drivers load the bags into the cargo door and the plane crew stows them into the racks along the length of the aircraft.
By having a SIC, they are also allowed to fly certain hazmat as part of their cargo


Just seems strange that they would be having trouble finding pilots to hire when the job boards are still full of pilots with 3-5000 hrs looking for work.
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They are looking forward. 2 years from now, all those people will have jobs better than skippering around a Navajo with little packages at night. They are doing this for the same reason the air-force is throwing money at experienced pilots to lock them into 5 year committments.
 
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weilke said:
I dont think the FAA will be too keen on allowing them to just switch back and forth as they please. Training for single pilot and two-crew is different, switching back and forth between the two concepts on the same airframe may have a negative effect on safety.
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They already do this. A couple airframes can be flown off the same training as single pilot or dual crew.
 
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