RACCA Spotlight - July 3, 2013
Urgent Request for Member Participation! - John Hazlet, Vice President
A Petition for Exemption has just been posted for comment on the Regulations.Gov website docket that seeks to clarify a Second in Command experience logging issue, that will have important long-term ramifications for the supply of pilots to Part 135 cargo carriers -- and operators on up the Part 121 ladder from our part of the industry.
This petition will likely get granted provided (a) that a sufficient number of favorable comments are posted on the docket, and (b) that they are not overwhelmed by significant opposing comments. Once granted, other operators can jump on the coattails of this exemption and get exemptions of their own. Eventually, this may result in a couple of slight rule changes to straighten out the whole issue. Therefore RACCA urges all members to submit their comments ASAP! Instructions for doing so are below.
Opinion within and outside of the FAA is divided as to whether a properly trained and checked SIC can log time in a Beech 99, Fairchild Metro, or other similar airplane approved for single-pilot Part 135 cargo operation.
Position 1: Some folks (including people at FAA Headquarters) say that the time can only be logged during specific operations where regulations that require an SIC, such as the few moments of a low-minimum takeoff, an hour or so when Part 135 allows crew time limits to be extended with a two-pilot crew, or on a flight leg when a particular type of HazMat is aboard where 49CFR175 requires a two-pilot crew so one person can leave the cockpit to view and/or handle the Haz package in the cargo bay.
Position 2: Other people inside and outside FAA say the copilot can log all of the flight time as long as s/he is properly trained and has a current checkride.
Unfortunately, the official FAA Headquarters view is Position 1 -- which means copilots don't want to play, if they'll only be able to log a few minutes of time in any given week.
This Petition for Exemption (a revision of a previously-granted, but very restrictive petition) will clarify the matter once and for all. It is also important in these days of increasing pilot shortages because it will help fill the pipeline with aviators who have much richer and more applicable flying experience than they'll ever get giving flight instruction, towing banners, patrolling pipelines, flying traffic watch, or the other, similar commonly-used VFR flight time builders.
To see the petition itself, go to:
To submit your comment, go to the same location, click on "Comment Now," and follow the instructions there. You can either type in your comment in the window provided, or attach a file per the instructions below the window.