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Freewheel

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Freewheel last won the day on December 24 2018

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  1. Excerpt from April 16/19 e-mail: “I am responding on behalf of Robert Sincennes who is currently away. TCCA has received many comments on Draft Advisory Circular (AC) 700-052 - RECORDING FLIGHT TME FOR SKID-EQUIPPED HELICOPTERS and it has now completed a disposition of all comments. These will be sent out shortly for all persons and operators who submitted them and when the consultation period and processes are complete, the AC can be issued.” Best Regards,Pierre RuelPierre RuelChief | ChefFlight Standards| Normes des Opérations AériennesStandards Branch| Direction des NormesTransport Canada | Transports Canada330 Sparks St, 4th floor | 330 rue Sparks, 4e étage (AARTA)Ottawa, Canada K1A 0N5pierre.ruel@tc.gc.ca<mailto:pierre.ruel@tc.gc.ca>613-998-9855
  2. And n the form of a stamp of approval on behalf of the minister (in my COM]. Like I said “Good to go” ...for the time being at least. At the rate TC moves, that could be quite awhile.
  3. We’ve already involved all parties and done the work...now it’s up to them. This circus has been going on since 2015. According to Airbus I’m good to go with Class C loads. That’s what their letter says. They have also been advising several operators of this since 2015. According to anything I have in writing from TC, I’m also currently good to go. That includes correspondence from TC Standards, Certification and Regional Operations and my COM approval. I’m confident that constitutes “approval from the responsible authority in accordance with the applicable operational regulations” as indicated n the operating limitations of the Flight Manual. With that being said, standards and my region have advised they will be releasing a CASA to advise of the implications of Airbus’ position. The point of my post was simply to ask if anyone else had received any news on this front (and also pass on what I know to others who may be conducting Class C in AS350s).
  4. Additionally, Airbus has been circulating the attached letter (to Transport Canada and many operators) since June 2015. Also attached is the November 2017 letter from TC certification (to Airbus). In this letter TC Certification states that they have completed their review, validate the "major change affecting Airbus Helicopters AS350B2" and find the changes acceptable. 13530660.pdf AS 350 and EC 130 series helicopter - External load certification.pdf
  5. That it does. So let's look at the Operating Limitations section in the latest amendment (06-17) to the supplement for the Cargo Swing on the AS350 B2, approved by Transport Canada themselves in November 2017. "The cargo hook system is approved for lifting external load which is jettisonable and lifted free from land or water during rotorcraft operation. Operation with an external load which remains in contact with land, water or any fixed structure is not demonstrated by the manufacturer. These operations shall not be conducted without approval from the responsible authority in accordance with the applicable operational regulations." Now, what are your thoughts if an operator has an approval e-mail (like the one in my December 21, 2017 above) from Transport Canada Standards (and have Class C loads approved in their COM)? We also received an e-mail from our Primary Ops Inspector stating approval of Class C loads in the AS350 is granted. Our COM also contains approval for Class C loads, but does not specify in which aircraft.
  6. FYI: Earlier this month, 4 TC inspectors and the Associate Reginal Director advised us (verbally) that TC standards have changed their position with regards to AS350 Helicopters and their certification for Class C external,loads. We asked to receive their position in writing and we’re told that TC is preparing a Civil Aviation Safety Alert (CASA). A follow up email to the standards department garnered this April 19 reply: With respect to operations with Class “C” loads by the AS 350 series helicopters, TCCA will be advising operators through their regional POI’s and through the issuance of a CASA of the implications of the position of Airbus Helicopters on these operations with this series of helicopter, as stated in the Limitations Section of the AS 350 Rotary-wing Flight Manual. Transport Canada is not planning any separate regulatory action on these operations at this time.Best Regards,Pierre RuelPierre RuelChief | ChefFlight Standards| Normes des Opérations AériennesStandards Branch| Direction des NormesTransport Canada | Transports Canada330 Sparks St, 4th floor | 330 rue Sparks, 4e étage (AARTA)Ottawa, Canada K1A 0N5pierre.ruel@tc.gc.ca<mailto:pierre.ruel@tc.gc.ca>613-998-9855 Has anyone received further clarity through their POI? We were advised the CASA was to be released in the very near future, but have yet to see it...
  7. I suspect this is one of those issues where the approach from TC is far from standardized. Depending on what exactly you want to use the IPad for, how you mount it and most importantly, which inspector you ask, the expectation likely varies from “nothing required in the COM” to a very complex system (documented and approved in the COM). if you just went through all of this with TC, care to share your inspectors expectation?
  8. My mistake. It used to be CAW, now it’s Unifor,; aka the “Super Union” lol https://www.unifor.org/en/whats-new/news/caw-cep-merge-super-union
  9. My point was that averaging agreements are not solely intended for “seasonal jobs” and they can be legally implemented for 24/7/365 operations. Heliian clearly stated that it could not be legally introduced since it is only for seasonal jobs. In fact it can be introduced: If the nature of the work in an establishment necessitates irregular hours due to seasonal or other factors. https://www.canada.ca/en/employment-social-development/services/labour-standards/reports/hours-work.html https://www.canada.ca/en/employment-social-development/programs/laws-regulations/labour/interpretations-policies/averaging-hours.html As stated she is in a union (CAW local 103), but the Canada Labour Code still applies equally to unionized work places. The standards in the collective bargaining agreement can differ, but at a minimum, must comply with the CLC. As with most pilots in our industry, the averaging agreement was in place when she was hired. Union or not an averaging agreement must be approved by a Labour Affairs Officers (LAOs) who ascertain whether the criteria that qualify an employer to adopt averaging have been met and whether averaging provisions are being correctly applied. Her hours are averaged over a 4 week period/160 hours. She is regularly required to works 15 hours daily. One recent shift was 21 hours with almost 80 hours worked that week. if you are really interested in their averaging agreement see the following link. Page 11 is where the rules for hours of service and O/T is discussed. While the agreement in the link expired Dec 2018, this averaging system has been in place for decades with no significant changes. https://www.sdc.gov.on.ca/sites/mol/drs/ca/Transport/482-15180-18%20(506-0024).pdf
  10. Without some sort of averaging agreement, you would be generally limited to a maximum of 48 hours of work per week...wouldn’t you? https://www.canada.ca/en/employment-social-development/programs/employment-standards/federal-standards/work-hours.html Then what is the point of the CARs limit of 60 hours Flight Time in 7 days?
  11. My wife is a full time employee at a unionized transportation company (that is also funded by the Ontario government) and operates 24/7/365. They operate under an averaging agreement. Like our industry, Ontario Northland Rail is also federally regulated (and under the Jurisdiction of the Canada Labour Code).
  12. HAC comments on Draft advisory Circular submitted to TC http://news.mediaedge.ca/assets/Flight%20Time%20Submission_%20February%2015%202019%20FINAL.pdf
  13. In accordance with the Canada Labour Code it’s illegal not to pay overtime. Most private operators do,pay overtime, but it’s based on an averaging agreement over 52 weeks. So an employee needs to be paid OT when he works more than 2080 hours in a year (minus vacation, stats etc). Perhaps the question should be: Does ORNGE operate under an averaging agreement similar to almost all private operators? if they are paying huge amounts of OT, then I’d suggest that managent Is not managing as efficiently as they could be. This would hold true for any manager in any sector. Paying OT regularly indicates the justification for additional Human Resources and the hiring of additional pilots.
  14. Thank you for clarifying Brian. I’m not trying to read anything into your statements. Despite the fact you loath responding, you continue to bring up the ICAO minimum requirements (multiple posts).. I was just wondering your personal opinion On the matter because of your posts. 1) no comment 2) agreed. then a risk assessment should easily demonstrate an equivalent level of safety (in accordance with TCs own national objectives (and ICAOs)). 3) agreed. That’s why we directly challenged the the Chief of Standards and Director of Standards...the result is this AC. 4) Agreed.. but even the interpretation offered in this AC is a significant change from Flight time = Air time in that respect. Start and shut down for most operators and FTUs is less significant than the time spent on the ground on intermediate landings. I think Fred’s estimate of 10% difference between flight time and air time is at the low end of the spectrum. Start and shut down might account for 10% (as stated in the TC AC). The multiple landings on many flights accounts for a larger percentage. This is really evident when you use something like an Aerodyne system which calculates air time with a squat switch on the skid gear. Given this fact we have increased the difference between ICAO and Canadian licensing requirements with this AC. Have a nice weekend Brian
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