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Your Guide To Logging SIC Flight Time In 'Single Pilot' Airplanes

You're sitting in the right seat and flying the airplane, but that doesn't necessarily mean you can log flight time. Here's what we learned from the FAA about multi-crew flying in "single pilot" airplanes.

Did you know that you can log PIC time in your logbook when you're not acting as the Pilot-in-Command? Sounds impossible, right? Find out how...

Solving The Debate

We found the following discussion on Facebook (image below). Second in Command regulations are tricky, and logging flight time from the right seat isn't always as simple as it seems. We'll clarify some gray areas to help you make sure your logbook stays legal.

What Does "Single Pilot Certification" Mean?

For type certification, the FAA divides airplanes into two basic groups:

  • Small Airplanes: The maximum takeoff weight for an airplane under the category "commuter" is 19,000 pounds, carrying up to 19 passengers. Other categories under the "small airplane" group include: gliders, sailplanes, normal, utility, acrobatic, primary, restricted, and very light airplanes.
  • Transport Airplanes: Multi-engine airplanes with more than 19 seats or a maximum takeoff weight greater than 19,000 lbs must be certified in the transport category.

Airplanes in the "small" group are almost always certified to fly with a single pilot. With limited exception, any airplane that falls under the "transport" group requires more than one crew member. To determine whether an aircraft can be flown by a single pilot, the FAA runs a series of ground and flight tests with an FAA-employed pilot. They fly through busy airspace, simulate emergencies, and run all applicable procedures to examine the feasibility and safety of single pilot flight.

Insurance Requirements Don't Trump Federal Regulations

Insurance requirements never trump federal regulations. Many charter insurance policies require two pilots for added safety, even in single pilot certified airplanes. Even if your insurance requires two pilots, unless the airplane or operation legally requires two pilots, you probably can't log flight time from the right seat.

There are hundreds of job opportunities for second-in-command, right seat pilots in 'single pilot' airplanes like Cessna 208 Caravans, Pilatus PC-12s, or most King Air models. It's easy to understand why someone might get confused here.

If it's your first professional pilot job, these airplanes are bigger than anything you've flown before, but still don't quite meet the certification requirements for two pilots.

Many pilots may fall into the trap of logging flight time during an operation that only requires one pilot. Exceptions exist, and we'll cover them below.

Swayne Martin

What About The FAA's 'PIC Time' Definition?

According to FAR 61.51(e), there are four ways you can log Pilot-in-Command (PIC) time:

  • When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated.
  • When the pilot is the sole occupant in the aircraft.
  • When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted. (This is why captains at airlines can log PIC time even when they aren't designated as "pilot-flying")
  • When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command (with a few sub-requirements).
Boldmethod

In a 2012 Letter of Interpretation addressed to Mr. Glenn Counsil, the FAA clarified that ANY pilot who's rated to fly an aircraft as PIC may log PIC time when they're the sole manipulator of the controls, even when they're acting as Second-in-Command (SIC).

In the letter's example, a pilot holds a PIC Type Rating to fly a 757/767. When he acts as designated SIC in the right seat, can he log log PIC time while the sole manipulator of the controls? According to the FAA's letter, yes!

This example doesn't just apply to airliners of course. A Cessna 208 Caravan doesn't require a type rating, so any SIC who holds a commercial, single-engine land pilot certificate can log PIC time when they're the sole manipulator of the controls under this interpretation.

However, don't log both SIC and PIC at the same time. This 2013 Letter of Interpretation from the FAA explains why that would push the limits too far.

Swayne Martin

Time you log can be used to fulfill the PIC requirements for an ATP Certificate, which includes the required 250 hours of PIC time (with 100 PIC cross country hours and 25 PIC hours at night).

But don't jump for joy yet...there are a few things you need to take into consideration before you whip out a pen and start correcting your logbook's PIC column...

Many Airlines Have Their Own Definition Of "PIC Time"

We reached out to American Airlines, and here's what we found out...

Like most airlines, American Airlines has a clearly defined explanation of what qualifies as "PIC" time in a logbook when applying for a job. A distinction is made between "Captain Time" and "PIC Time." When applying for a position at American, PIC time is defined as "Captain/Aircraft Commander" time (including instructor time). They specifically state that PIC time resultant only from "sole manipulator of the controls" does not count for their requirements.

American Airlines

Long story short, if an employer feels like you're attempting to "stretch" out your flight time to make your logbook look more impressive, you probably won't get the job. Think twice before you begin logging everything you fly as PIC time. Just because you can do it, doesn't mean you necessarily should.

Part 91 vs. Part 135 vs. Part 121

Part 91K, Part 135, and Part 121 Air Carriers have a set of documents called Operation Specifications (OpSpecs). Whether it's a Part 135 charter operation or a Part 121 airline, each set of OpSpecs is unique to the individual carrier. The FAA regulates and approves these OpSpecs one-by-one. Based on a combination of air carrier requests, operational considerations, and FAA requirements, there are often differences between airlines flying the same type of airplane.

OpSpecs are legally binding documents and must be viewed as federal regulations. Their contents may be more restrictive than existing FARs, effectively making them the "rule book" for air carriers. Some OpSpecs specifically state when a minimum of one or two crewmembers is required. Keep reading to find out how OpSpecs might help you log flight time in a single pilot airplanes...

Haley Howard

For regular Part 91 operators, there's no such thing as OpSpecs. The FAA is concerned with protecting the flying public, which is why they regulate Part 91K, Part 135 and Part 121 carriers so heavily. If you're attempting to log time while flying a single pilot airplane from the right seat under Part 91 for hire, you only have one hope left.

In a 2009 FAA Letter of Interpretation to Mr. Scott Nichols, the FAA clarifies that when a second pilot is not required under Part 91, they CANNOT log SIC time. However, they CAN still log PIC time when they're the sole manipulator of the controls. Whether or not the pilot is a required crewmember does not affect the legality of logging PIC flight time, according to this letter.

Exception 1: Training Flights

When you receive flight training from an authorized instructor, you're acting as a required crewmember and can log dual-received training time. Because of this, you can log flight time in single pilot airplanes when you're not PIC. This allows student pilots to build required flight time in light airplanes. There's no regulation prohibiting instruction onboard flights conducted under Part 91, commercial operation or not. However, under Part 135 and 121, instruction isn't allowed unless required or allowed by an OpSpec.

KamrenB Photography

Exception 2: Safety Pilots

FAR 91.109(c) says: "No person may operate a civil aircraft in simulated instrument flight unless the other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown."

FAR 61.51 says you can log PIC time when you are acting as pilot-in-command and when more than one pilot is required by the regulations governing the flight. And FAR 91.109 says that when a pilot is under the hood, another pilot - the safety pilot - is required. If the safety pilot is designated as the pilot-in-command, he or she can normally log the time as PIC. Like instruction time, there's no restriction on the use of a safety pilot under Part 91 (commercial operation or not). Operations with safety pilots are generally not allowed under Part 135/121, unless specified by an OpSpec.

Boldmethod

Both pilots can log PIC flight time because:

  • Pilot A is the sole manipulator of the flight controls, and...
  • Pilot B is acting as the required PIC.

Exception 3: Autopilot Regulations

For operations under Part 135, FAR 135.101 and 135.105 state that 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. Nowhere in the regulations does it state that the use of the autopilot is required. Because of this, a Part 135 operator can elect to either:

  • Fly under IFR with one pilot using the autopilot system, or...
  • Fly with a designated SIC without using the autopilot.

According to a 2009 FAA legal interpretation, when the certificate holder elects before IFR flights not to use the autopilot system, two pilots are required by Part 135. Thus, an SIC may log flight time. This is one way that airlines like Cape Air, Tradewind Aviation, Mokulele Airlines, Hageland Aviation (Ravn Alaska), or Air Choice One are able to operate single pilot airplanes with both crewmembers logging flight time.

Tradewind Aviation

The catch? The flights must be conducted under IFR, and if the autopilot system is used, the SIC is no longer a required flight crewmember and can't log SIC time. They can, however, log PIC time when they're the sole manipulator of the controls (per the Letter of Interpretation we discussed above). However, if the SIC autopilot exception is how you plan to log time, keep it legal and follow the regs.

Exception 4: Operations Specifications

Remember how OpSpecs become a set of FAA regulations that air carriers must follow? Company OpSpecs might have specific language stating that a crew of two pilots is required during passenger carrying revenue operations. If that's the case, the second-in-command may log SIC flight time during the entire flight, VFR or IFR, autopilot or not.

Remember, regulations like this are operator-specific and can't be used for guidance outside of that specific company.

Swayne Martin

So, You Don't Meet An Exception. Now What?

Before you accept a job offer to fly SIC, review the company OpSpecs and regulations. If the flight time qualifies as SIC, you're good to go. But if it doesn't, don't push your luck with your logbook.

If you can't explain to an interviewer the requirements of your previous operation and how you logged the flight time, that's a major red flag.

There are lots of ways to log SIC and PIC time. But before you do, make sure you have a clear path to logging the time. Having a logbook that's straight forward and easy to understand will make any future interview a whole lot easier.

Have you ever flown as SIC? Did you run into trouble understanding these regulations? Tell us in the comments below.

Swayne Martin

Swayne is an editor at Boldmethod, certified flight instructor, and an Embraer 145 First Officer for a regional airline. He graduated as an aviation major from the University of North Dakota in 2018, holds a PIC Type Rating for Cessna Citation Jets (CE-525), and is a former pilot for Mokulele Airlines. He's the author of articles, quizzes and lists on Boldmethod every week. You can reach Swayne at swayne@boldmethod.com, and follow his flying adventures on his YouTube Channel.

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