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4 Answers

Private Pilot part 91 SIC for hire

Asked by: 1401 views FAA Regulations, General Aviation, Private Pilot

I am interested in your response.

In FAR 61 sub. E no person who holds a Private Pilot Certificate may act as Pilot in Command PIC of an aircraft for compensation or hire.

What about a person who holds a Private Pilot Certificate and is in the SIC position.  Can this person be compensated or for hire?  FAR part 91 King Air 200.  Our company GOM requires a two Pilot Crew which supersedes the FAR, which the King Air only requires one Pilot.   I am not the Private Pilot Certificate Holder I am an ATP Certified Pilot.  Our company has two foreign pilots who hold an FAA Private License with a Foreign License.  Hope this clarifies.

In order to be a part of ISBAO the company must comply with a GOM for the company.  It is not approved by the FAA, but it does exist and is approved by the company, with rules that are more restrictive than the FARs.  

I see some of the responses as to the King Air 200 is not required to have an SIC.  I understand Required to mean that this Aircraft can be flown Single Pilot.  Required to me does not mean this Aircraft Must Be and can only Be flown Single Pilot, without anyone occupying the SIC position.  If a part 91 operator wants the security of a two Pilot Crew in a plane not requiring two pilots they are allowed to operate a two Pilot crew.

The regulation now on who can occupy the SIC position says a minimum license requirement is a Private Pilot License.  I understand this to mean a owner or anyone not for hire can occupy the SIC position.

Also having a GOM regulations for how the company will operate even though not approved by the FAA.  I think the FAA would look at and the Lawyers would say it definitely has relevance and regulatory responsibility.

Thank you for the interesting responses.  

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4 Answers



  1. vaflyer on Feb 20, 2024

    A couple of points. A B-200 King Air does not require a SIC. It is a single pilot aircraft. §61.55(a) spells this out. The aircraft must be type certificated as requiring more than one pilot (a B-200 is not) or that its operations require two pilots (which would be a §135 or above operation). §135.245 requires an SIC to hold a commercial rating. A part 91 operator can’t just say their operations require two pilots and then require an SIC who can log time.

    If you have someone who is willing to let you fly right seat in a B-200 and is a CFI then they could provide flight instruction to you. They would have to sign your logbook.

    If you have someone who owns their aircraft (so part 91) that is type certificated for two pilots (lets say a Lear Jet) and they are willing to have you fly as SIC then have at it. I seriously doubt that any insurance agency will cover the flight. Could you be paid for it? I guess.

    Finally, if you are trying to be clever then I would say you are being too clever by half. It will catch up to you. Regulations keep us and primarily our passengers safe. Regulations are written in blood. Don’t be the guy who causes the creation of new regulations.

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  2. Mark Kolber on Feb 21, 2024

    Vaflyer,

    >> A couple of points. A B-200 King Air does not require a SIC. It is a single pilot aircraft. §61.55(a) spells this out

    A GOM is a regulatory document (135.23) which is approved by the FAA and must be followed. If it requires an SIC, one is required, regardless of the aircraft certification. But the, the SIC requirements must be met too.

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  3. LTCTerry on Feb 21, 2024

    Isn’t a GOM a Part 135 term? Does the FAA approve manuals for a company’s Part 91 operations?

    Is 135.23 applicable to OP’s Part 91 question?

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  4. Kris Kortokrax on Feb 21, 2024

    Quite a few issues here.

    1. You have overlooked 61.117. It forbids a Private pilot from acting as SIC of an aircraft that requires two pilots per the Type Certificate.

    2. Only a Part 91K Fractional operator would have an Operations manual and it is referred to as a Program Operations Manual, not a General Operations Manual (GOM).

    3. The Private Pilot certificates based on a Foreign License are restricted certificates. They bear a notation stating that the US certificate is subject to the limitations of the foreign license. You would have to become familiar with the regulations from that country to see what is allowed. That is part of the reason that the FAA stopped issuing Commercial certificates based on foreign licenses. They don’t want them flying for hire.

    4. Your “GOM”, which is “approved” by your company is meaningless.

    5. If ISBAO became aware of what you are trying to do, they would probably remove their blessing.

    6. The GOM is only required if the operation is not a single pilot operator. A single PIC operator, which is different, may receive a deviation from some of the GOM requirements. For all other operators, the GOM is required. However, look at 135.21(c). It states that the GOM “must not be contrary to any applicable Federal regulations…”. You could not make up a requirement for an SIC, unless you can find a regulation requiring one. Insurance requirements or company requirements cannot supplant the regulations.

    Take a look at the Cato and Nichols interpretations. They deal with SIC operations in a Cessna 525, that can be flown as a single pilot, with an autopilot and the correct type rating. I know the King Air 200 doesn’t require a type rating, but the theory is the same.

    https://www.faa.gov/sites/faa.gov/files/faa_migrate/interps/2014/Cato_2014_Legal_Interpretation.pdf

    https://www.faa.gov/sites/faa.gov/files/faa_migrate/interps/2014/Cato_2014_Legal_Interpretation.pdf

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