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Old 1st May 2020, 20:59
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Calling MarkerInbound !

Got a license/type rating question. Iíll try to give the Readerís Digest version of the ramp up to the question.

Many years ago, pre-1500-hour rule but post-Part 121-SIC-type rating required, a guy gets a DHC-8 rating on his CPL with this limitation: ďDHC-8 SIC PRIVILEGES ONLYĒ.

He later moves on and down the road gets a full ATPL, to which the DHC-8 rating is transferred, with a few other type ratings but the DHC-8 rating still carries the above limitation.

So the question: Is there a way to have that SIC limitation removed via FAA paperwork or is a full sim rating ride required ?

Iíve seen FAR Part 61.64(g) which mentions something perhaps related to my question but Iím not sure itís exactly the same situation.

I tried to find an FAA interpretation on this but couldnít.

Any official, documented wisdom on this ?
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Old 2nd May 2020, 11:32
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See PM, can’t add link to this post.

5-2-22-11 C

Summary;
Require full PIC Check-ride
Can only log SIC hours
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Old 2nd May 2020, 12:00
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awair,


Thanks for the info. So much to know...so little time.
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Old 2nd May 2020, 12:26
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Good question. Other than "I just know SIC rating does not count for the real PIC type rating," not sure where to find it.
Just a stab at it, 61.63(d) spells out the type rating requirements, basically "alludes" to the practical test at the ATP level. 61.55 is where the SIC type rating stuff is listed, and, obviously falls well short of the full ATP requirements, as in the ACS and 61 Subpart G for ATP, 61.155(b), 61.156, 61.155(b), etc. but I really don't know exactly where or if the difference is written.
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Old 2nd May 2020, 12:40
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Originally Posted by 340drvr View Post
Good question. Other than "I just know SIC rating does not count for the real PIC type rating," not sure where to find it.
Yes, the DHC-8 SIC type came via an established Part 121 training syllabus rather than some self study of the manual and three bounces. I thought it might make a difference in getting rid of the SIC limit but it appears it doesn't.

Now is a good time to not have anything on your ticket that might limit your options...as if you're going to have many.
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Old 2nd May 2020, 13:19
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Going back to the original question, I think it would really depend on how the original check-ride was performed and why the restriction;
1) Was it a full PIC rating?
2) Was the restriction solely because the candidate did not meet ATP criteria?

If that is the case, FAA records will show the completion of the appropriate check-ride (PTS items), and this may possibly be fixed by licensing action only?

bafanguy You also mentioned 61.64: my read of this is, that this section is not appropriate. This details the scenario where a Simulator is used, that is not fully qualified. IE a qualified candidate may not act as PIC, because the Sim cannot be used to check all required items.

340drvr To clarify:
61.31: PIC requirements, and when a Type Rating is required (“large” and/or Jet)
61.55: SIC requirements & SIC Type Rating requirements
61.63: Additional Type Rating (IE use the ACS to determine check-ride contents)
61.155: Knowledge Test requirements (not required, in example given by OP)
61.156: ATP-CTP course (not relevant for existing ATP)
61.157: Initial ATP or Type Rating standards (again, check the ACS)

Analysis: based on 61.157(d)
“Upgrading of Type Ratings” I believe that this only refers to a candidate who held a Commercial (or Private), with a Type Rating who upgrades to ATP. They would have held a full (PIC) Rating, to fly as PIC in operations other than 121/135.
So a SIC rating does not automatically get upgraded, unless it was incorrectly issued, as considered above.
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Old 2nd May 2020, 15:31
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Originally Posted by awair View Post
Going back to the original question, I think it would really depend on how the original check-ride was performed and why the restriction;
1) Was it a full PIC rating?
2) Was the restriction solely because the candidate did not meet ATP criteria?

If that is the case, FAA records will show the completion of the appropriate check-ride (PTS items), and this may possibly be fixed by licensing action only
awair,

Hard to say if the items checked on the SIC rating ride at the time were identical to the PIC. It was a formal Part 121 training program with whatever comes with that. It was almost 15 years ago so there's some doubt if the training records for a former employee even exist. I doubt the employer would be in any frame of mind to dig for them.

I don't know if FAA records for this specific rating ride would be available from the Feds.

The SIC rating was placed on a CPL because the person getting the rating didn't have ATP mins at the time (pre 1500-hour rule). And, it was early in the regulatory mandate to type rate SICs in Part 121 so I don't know if a person DID have ATP mins he would've been issued a full PIC type rating anyway if employed as a new-hire F/O.

Just an interesting legal exercise, I guess. The person in question is sitting around at his legacy waiting for the ax to fall after Oct. 1st and was just wondering about this issue. He's not too interested in av forums so I offered to kick it around on his behalf. I appreciate your advice...thanks.
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Old 5th May 2020, 16:36
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I'll take a wild guess (based on a recent conversation) that the FAA do have the records.

1) They will have the pilot certificate/rating record. They are probably required to keep everything til long after we're gone.
2) As 121 is all approved, FAA will have a record of what a SIC training program was required to include, even for defunct carriers.

Good luck
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Old 5th May 2020, 17:29
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Similarly, I've had an attempt to add the dreaded 'CIRC. APCH.-VMC ONLY' to a type rating years later while working for a 121 carrier with the now customary VMC circling restriction in the Ops Specs. I did do the circle on the initial ATP ride decades earlier and on the type rating ride but it was (wisely) subsequently eliminated from the training syllabus of the 121 carrier.

Didn't really matter but I talked my way out of the 'update' to my ticket.


Originally Posted by bafanguy View Post
Now is a good time to not have anything on your ticket that might limit your options...as if you're going to have many.
Probably won't ever make any difference to a domestic employer but those unfamiliar license details can sometimes be a showstopper to a clerk vetting a sea of applications for an overseas carrier. I hope and pray that he doesn't ever have to stoop to what is for an American the last refuge of a scoundrel: expat flying. And yes, I speak from experience.

I remember a while back reading about a colleague who was proudly retiring from a 30-year airline career with only one type rating - the 727. I've kinda had the other problem.
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Old 5th May 2020, 20:39
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Originally Posted by Airbubba View Post
.Probably won't ever make any difference to a domestic employer but those unfamiliar license details can sometimes be a showstopper to a clerk vetting a sea of applications for an overseas carrier. I hope and pray that he doesn't ever have to stoop to what is for an American the last refuge of a scoundrel: expat flying. And yes, I speak from experience.
'bubba,

He's done some of that for DoD contractors in Iraq and Afghanistan. But that's not purely expat flying. The only DHC-8 job I've seen recently was AAR for Iraq. He ain't doin' that ! Wife won't ever agree to it.

This is now just my little project to get an official answer from someone at FAA. I wrote to the Airman Certification Branch in OKC but they offered nothing; told me to contact local FSDO. That's not the first place I'd look for an answer to a fringe issue like this. I don't think you can expect your friendly local ACI to have a definitive answer.

I looked at the web page for the FAA Chief Counsel Office thinking I'd ask for a legal interpretation but don't see how to approach them in a proper way.

Never underestimate a cranky old guy with time on his hands.
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Old 5th May 2020, 23:50
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Hi Guys!!

I hadnít see anything in the NA forum for a while and guess I havenít been checking in as much. This is out of the Flight Standards Information Management System- F-SIMs.

C. Removal of the Type Rating Limited to SIC Privileges. Removal occurs when the applicant accomplishes the appropriate type rating practical test for PIC privileges.


So yes, it would take an ATP checkride to ďupgradeĒ a SIC type to a regular type rating. And if the checkride is going to be done in a simulator under part 142 there has to be a training program before the checkride.

The SIC type was put in place to verify the F/O's qualification to foreign CAAs. And while airline training for F/Os has been about the same as Captain's training, the part 91 world is a bit more relaxed. About the only reason I can think of why air carriers didnít do the full type for F/Os before it was required is they would have needed a Fed to watch the ride or the check airman would have to have been a APD and there werenít as many ADPs in the airline training centers. Now because everyone needs a full type there tend to be more APDs in the training centers.

The official answer to almost any FAA question is in F-SIMs, thatís where the FAA person is going to look for guidance.


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Old 6th May 2020, 01:33
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I've attached a copy of the latest Airline Transport Pilot and Type Rating for Airplane Airman Certification Standards pub from the FAA. Appendix 5 has guidance on removal of type rating limitations like the 'CIRC. APCH.-VMC ONLY' I mentioned above. It mentions removal of the 'SIC Required' limitation which is not the same as the 'SIC Only' you're trying to get removed for someone else.

Being the government, a limitation is probably different from a restriction but my all of my type ratings are unlimited and unrestricted as far as I can tell. I've learned not to ask a fed for clarification lest I be put under the microscope by the paperwork police.

Years ago I had one of them fancy British style ATPL's from an overseas job. It looked like a passport with a picture and a little string and ink stamps for all sorts of base checks, instrument checks, emergency checks and the like. Each stamp had a signature and there were different dates on the stamps and the signatures. A British civil servant's dream document. The dates were written bass ackwards from the American style and it was hard to figure what expired in six months, 180 days or what? Was it the end of the month, was there a grace month? I never could remember. You know where this one is going.

I took a sim check from a sharp young local instructor (years later destined to be CEO of the airline) and things went well. At the debrief he filled out the paperwork and I turned in my license to get updated and picked up later. He asked if I had any questions and I asked if it was the date on the stamp or the date on the signature which determined the expiry date. He showed me my license pages and started to explain. Doh! I had misread the expiry as April 3 and it was actually March 4.

The sim check paperwork was somehow backdated and my license was returned without any expiration. Perhaps wasta and bribes were involved, I knew not to ask any more questions.


Originally Posted by bafanguy View Post
I looked at the web page for the FAA Chief Counsel Office thinking I'd ask for a legal interpretation but don't see how to approach them in a proper way.
Again, I'd recommend not getting FAA legal involved in an administrative or operational issue unless you really need to.

Some years ago my airline colleagues got into a dispute with the company over when the airline could use a cockpit jumpseat to move a pilot when a pax seat wasn't available, if say, a plane broke at an out station. The contract was fairly specific but there were some hypothetical borderline cases that were 'subject to interpretation'.

Traditionally the captain had final authority over who could and couldn't ride the jumpseat so some geniuses down at the union hall decided to use this authority to show the company who was boss.

One of the young Turks got a letter from some guy at FAA legal saying the captain's authority was the last word and folks started writing checks with their egos that their bodies couldn't cash. I had militant FO's lecture me on who I could and couldn't take as an ACM (Additional Crewmember). Commuting FFDO's got bumped by tree huggers. Dispatchers doing required observation flights (without golf clubs ) were bumped for crew comfort.

The company had enough and got another letter from the FAA that clarified the legal status of captain's authority in the company's favor. A few folks got termination letters for ignoring the company's subsequent guidance which the FAA supported. They ultimately got their jobs back after some time off without pay. The guy in FAA legal who wrote the original jumpseat empowerment letter? He went back to private practice.

When the dust settled I felt that I had less authority to bump a jumpseat rider, not more.





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FAA-S-ACS-11.pdf (970.0 KB, 0 views)
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Old 6th May 2020, 09:55
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Airbubba and MI,

Thanks for the info. No doubt you are both correct in your recommendations to leave sleeping dogs alone.
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Old 8th May 2020, 20:29
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Originally Posted by MarkerInbound View Post
I hadnít see anything in the NA forum for a while and guess I havenít been checking in as much.
There sure hasn't been much good to talk about here lately. The next important date seems to be Oct. 1st when the no-furlough mandate expires. Lots of opinion about what happens next but no one can have any facts quite yet. I suspect there's reason for pessimism though.
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