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Brian Jenner

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Everything posted by Brian Jenner

  1. Frewheel I don't quite get what you are trying to say (read into what I have said) but, although I am loath to add another line to the 71 pages, just to make sure that no one misunderstands my opinion I offer the following clarification: 1) as President of HAC both Fred and I express(ed) Association opinion not personnal opinions (that is not to say they are different but rather if there is a difference, perceived or real, you can not hold me personnally to opinions expressed by me as HAC President); 2) in my personnal opinion (something I could not say as HAC President even though
  2. Freewheel, « belaboured » is 71 pages of « huh?????? %&$#@+!!!!!!!! » vs no further comment possible if Canada simply respects the ICAO definition of helicopter flight time « rotors turning to rotors stopped » as per our agreement to adhere to ICAO Standards. The problem is, if TC admits to the ICAO definition of «helicopter flight time», they will then have to deal with TC 100hr commercial helicopter license vs ICAO 150 hr commercial helicopter licence.
  3. Besides being extremely belaboured, it is inconsistent with the quite simple ICAO standard definition of “helicopter flight time”, to which Canada has not filed an exception.
  4. Darcy, I know all those guys too! I liked your novel very much. Your ability to sketch/colour people and places is certainly up there with some very good novelists. Look forward to the next instalment of the Edouard/Mike odyssey.
  5. Invoicing has nothing to do with « flight time » « air time »; it must conform to tarrif which must comply with the National Transportation Act not the Aeronautics Act.
  6. CARS 101 AIR TIME: with respect to keeping technical records is defined as, the time from the moment the aircraft leaves the earths surface until it comes into contact with the surface at the next point of landing FLIGHT TIME: means the time from the moment an aircraft first moves under its own power for the purpose of taking off until the moment it comes to rest at the end of the flight. The term "Leaving the earth's surface" is obviously different from "moves" and the term "comes into contact with the surface" is obviously different from "comes to rest". The fact that the two d
  7. Freewheel, the Federal Court confirmation is cited at length at the end of the decision you refer to. As for the COM being an Aviation Document, the decision can't be much clearer. It's been a while and I was not given the time to push forward based on the Decision, so I had forgotten that simply refusing, directly or indirectly, is grounds for a Tribunal Appeal ( indirecly = ie excessive delay - TC has a Policy Letter setting the maximum time they can take to deliver any service, making unrelated demands (blackmailling) = indirectly.
  8. During the developpement of CARs, 93-96, I tried to convince TC to "eliminate approvals wherever possible ... If you approve it you own it = operators no longer responsible for conformity with CARs ... Make objective standards, make the operator responsible for compliance ... Serious Operators will no longer have to wait forever for approvals ... slipshod operators will quickly fall in line, if you fine the **** out of them everytime you find a non compliance... TC will no longer have to prove everything right before the fact because operators will fear TC finds something/anything wrong, afte
  9. Freewheel, just as a contextual note, TC can not initiate any action before the Tribunal, only Document Holders have that right As for the possibility of another fonding on the subject of your times not being consistent with CARS, that should, theoretically, be impossible because findings are made in reference to the COM not CARs. I believe you've said your logging is consistent with your COM definition of "flight time" which is more or less "rotors turning to rotors stopped". In practice, the lines between findings, COM, CARs are blurred by everyone. So most TC inspectors act on their
  10. So, TC now has a, new "official" interpretation for the "flight time" and "air time" definitions in CARs. But that does not necessarily make it so! All conflicting opinions on the subject not withstanding and TC's opinion remains just one of many, the law remains the law as written and it will take a decision by a Court of Law to provide an authoritative interpretation of what the writing means. Unfortunately, while TC has no dictatorial powers to re-define the CARs definitions as per their latest opinion, TC carries a big stick, which gives their opinion a certain "my way or the highway"
  11. APL 2005-02 was published after a comprehensive presentation that I made to TC on the subject. Essentially "flight time" vs "air time" has nothing to do with what anyone thinks is best. It is a question of properly interpretting the law, as written. First simple rule of interpretation in that regard is "the legislator does not speak for naught". In this case there is no getting around the fact that if the regulation speaks of "air time" and "flight time" it's because they are two distinct regulatory concepts. Ergo, they can not be systematically the same ... Defining the same thing twi
  12. TC is not the problem, it's the politicians. The "business friendly Conservatives" faced with the towering menace of electionearing on the part of industry associations must be shaking n their boots. Afterall there must be at least a couple dozen customers that will be up in arms over the cost of new FDT rules - what the heck lets go for a gross - and then multiply by 10 so as to inlude their minions - plus operators, their families and managers - this thing could involve as many as 5000 votes, if everyone on the calamity side of the issue is interested enough to care and provided the other p
  13. [quote President’s Message Flight & Duty Time Update – The Time to Speak Out to Your MP is NOW .... We have been working with the Minister’s office to emphasis the fact that these proposals will NOT improve safety, but also to emphasis their catastrophic impact on our businesses, if they were to move forward in their current form. Our efforts for now, are being focused on urging Transport Canada resolve our differences through a constructive dialogue - but with the other Coalition Associations we have crafted an Advocacy Campaign that could see this regulatory proposal become
  14. Ya never know, maybe if enough individuals send in cards and letters with recommendations that have potential, maybe they will set up a helicopter table - see you there!
  15. Sorry Paul, if my "shove" seemed vulgar - such misunderstandings are an unfortunate danger of posting - luckily Kevin's uncaracteristically caustic reaction gave the signal that I may have mis-communicated my Opinion as to your previous post. As for your opinions as to how to correct the FDT proposal, I can only hope you send thenm to CARAC since in the absence of representation specific to one aircraft operations, your opinion is all they have or not. That being said I don't think there is much of a chance for that much massaging at this late stage of the consultative process. On the h
  16. And you say that to me! I have never done anything but keep things factual and impersonnal, which can not be said of Paul's comments about me, which follow a long standing tradition of people who attack the messenger, when you don't have an inteligent response to the message.
  17. My guess is you have your head turned back with your mouth open ready to receive the next "shove" - as in "TC shoving new regulations down our throats".
  18. Kevin, you are of course quite right, helicopter pilots were not represented on the FDT working ground. They won't be represented on the next one either. And operator associations chose to play for and continue to play for double or nothing. But you now have a chance to offer your input and it does have a chance of influencing the final product, provided it is clear, focussed and justified. If in your comments on NPA 2014-019 you cry about the spilt milk, you will be ingnored; if you demand they start over again, you will be ignored; if you try to make all the arguments you would have made
  19. There are many facets to the discussion of the impact of the proposed new FDT rules. Competitive dynamics aside, how, exactly do you see these ('airline') rules as being inconsistent with flying helicopters. How will your revenue be affected by a 2X2 schedule as compared to your present 3X3 schedule. And how is it not better (not best, just better), for the industry, to have everyone on a 2X2 rather than having just the lucky ones on a 3X3 sched.
  20. It's not a slogan, it's a factual result of regulatory intervention on the competitive dynamics of FDT. What you say, while true, is simply a fact of competitive dynamics, within the present regulatory framework What people have to chose in regard to NPA 2014-019 is, do you want to continue having the Good operators drawn toward the extremes of the Bad and the Ugly by competitive imperatives or do you want the Bad and the Ugly to be forced, by regulation, to move toward the centre, where the Good want to play.
  21. .When you make the extremes ilegal, the extremists are forced to the centre.
  22. . To suggest, that treating helicopter pilots and their passengers to the same safety regulations as the rest of the world would increase helicopter crew costs by 35% is, to say the least, a gross exaggeration. But one needn't argue the degree of exaggeration to find the truth about the real impact of the proposed FDT regulations. If, just for the sake of argument, you translate the spector of a "35%" increase in helicopter crew costs into a % increase in total cost of helicopter services to customers, the scare mongering loses its punch. To do that, calculate the cost of pilots pe
  23. Hear! hear! You did a great job! Now if others could at least make an effort. Doesn't have tobe great. Just has to be sincere!
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