No More Empty Right Seats: SIC PDP

No More Empty Right Seats: SIC PDP

  • August
  • 22
  • 2023
  • Advanced Aircrew Academy

With the dire need in the business aviation industry for alternative methods of getting the next generation of pilots' experience, no right seat should go to waste. Having two pilots in the cockpit is exponentially safer, even if the aircraft is certified as single-pilot, but only if the Second-in-Command (SIC) is trained and qualified to be there—and more importantly, if the Pilot-in-Command is trained on how to work with an inexperienced SIC.

After listening to the industry, the Federal Aviation Administration (FAA) amended regulations to create a Second-in-Command (SIC) Professional Development Program (PDP) that allows pilots employed at approved 135 operators to log SIC time during operations that do not normally require a first officer.

What has been lacking is training for the Pilot-in-Command during these operations. How do you instill technical competence, airmanship, and professionalism in new right seaters by captains who might not also be Certified Flight Instructors? Part of every captain's responsibility is to help prepare SICs for type ratings and upgrades. Being a successful captain of a crew means conducting a safe flight with passengers, while also setting an example for a new copilot by providing guidance. It's a unique skill and more challenging than most realize. Done incorrectly, having a new SIC could be a safety risk rather than the intended benefit of having two "crewmembers;" so let's break down the elements of this new crew dynamic.

Who's in Command vs Who's Flying

Generally, seniority is the trigger for upgrading to captain. Just because your number comes up, doesn't necessarily translate into being a good captain. Insurance requirements often set the crew flight time dynamics of experience for two-pilot-certified aircraft, but what happens when you're the PIC on an aircraft that is certified one-pilot and you have a "co-pilot"? How do you each log your flight time? Can an SIC legally log time in single-pilot-certified aircraft? The answer is: it depends.

Pilot-in-Command time is fairly straightforward, or is it? In the Part 121 world, the FAA has clarified that any pilot who is type rated to fly an aircraft as PIC may log PIC time when they are the sole manipulator of the controls, even if they're acting as Second-in-Command (SIC). Wait, really? Yes. In the 2009 letter of interpretation from the FAA's Assistance Chief Counsel for Regulations, if you have a PIC Type Rating to fly a B757, for example, when that pilot acts as designated SIC in the right seat, they can still log PIC time, but only when they are the sole manipulator of the controls.

That interpretation also holds true for other aircraft. A Pilatus PC-12 doesn't require a type rating, so any SIC who holds a commercial, single engine land pilot certificate can log PIC when they're the sole manipulator of the controls. The captain and co-pilot might both be logging PIC time, but you cannot use that time to fulfill PIC requirements for an ATP or to meet minimum hours to get hired at the airlines. Actual PIC time results ONLY from being the sole manipulator of the controls.

Peek at the Parts

For Part 91K and 135 operators, each has a unique set of Operating Specifications (Ops Specs). The FAA regulates and approves each of these for every operator, individually, so no two Ops Specs are the same. They are legally binding agreements with the FAA, so they are considered each operator's own regulations and are equal to or more restrictive than the FARS.

For safety, some Ops Specs state two crewmembers are required during passenger carrying revenue operations, even in single-pilot airplanes. That means the SIC may log SIC flight time during the entire flight. Woohoo for the newbies!

Part 91 doesn't have Ops Specs, so if you're trying to log time in a single-pilot airplane in the right seat, the FAA is clear that when a second pilot is not required, they cannot log SIC time, unless they're the sole manipulators of the controls. According to the FAA interpretation, the legality of logging PIC flight time doesn't coincide with whether or not the pilot is a "required crewmember."

Clear as Mud?

In 2018, the FAA finally decided to give guidance to Part 135 Operators who operate a single-pilot-certified multi-engine or turbine-powered airplane with less than 10 seats. The result is the current Part 135 Second-in-Command Professional Development Program (SIC PDP) which is detailed in the following:

  • FAA-issued Operations Specification A062
  • FAA Order 8900.1, Volume 3, Chapter 68, Section 1
  • 14 CFR 135.99
  • FAA Airman Certification Standards

PDPs must be approved by the company's Flight Standards District Office (FSDO). Once authorized, the FSDO will issue Operations Specification A062. Remember that most SICs in the PDP do not have their Airline Transport Pilot Certificate. This is an important distinction, because Commercial-certificated SICs do not have to meet the ATP standards. However, pilots using SIC PDP time to apply for an ATP (FAA) will have a limitation on their pilot certificate until they demonstrate to the FAA that they have additional required hours outside of their SIC PDP.

The FAA believes a PDP can provide valuable operational experience for pilots in a multi-pilot environment that may not otherwise exist. As such, the FAA limits PDPs to operators that meet the following specific Ops Specs requirements:

  • The operator MUST be authorized to conduct instrument flight rules operations under Part 135.
  • The operator MAY NOT be certified under any of the following:
    • Ops Specs A037, Basic 14 CFR Part 135 Operator – Commuter and On-Demand Operations
    • Ops Specs A038, Basic 14 CFR Part 135 Operator – On-Demand Operations Only
    • Ops Specs A039, Single Pilot-In-Command Operator
    • Ops Specs A040, Single Pilot Operator

If an operator meets the requirements, then there are numerous other obligations in aircraft, manual, pilot, flight, record keeping, and mentor training. Good thing that Advanced Aircrew Academy's new 135 SIC Professional Development Program (PDP) eLearning module covers each requirement.

The 135 SIC Professional Development Program module is for captains who are selected to be a Mentor PIC for your company. They should be chosen based on their knowledge, experience, and demeanor. The eLearning module covers key topics that include the following:

  • All requirements including flight, duty, rest, record keeping, and program analysis
  • Two-Pilot Standards and Procedures
  • Mentoring
  • Mentor Resources
  • Role-Playing Exercises and Scenarios that can be used at your next company safety meeting

We'll make it easy if you want to learn more. Just email or go to our website.