The question is what is the current minimum in standard as currently written in the CARs for licensing, personal logbooks and Flight time limits....not what you think they should be.
HQ Replied to the survey this week. As expected they refuse to respond to the questions or even discuss those requirements.
Given that the definition for flight time must be consistent throughout, then i’d Say under their interpretation a pilot requires 100 hrs Air Time for a Commervual licence; we know this isn’t happening at many many TC approved FTUs.
Pilots should be using air time only in personal logs. Also not happening with majority of pilots
Pilots should be using Air Time in Flight/Duty Time records required by 700.15 and 700.16. This means that companies who are doing it as per ICAO, would require less pilots to conduct contracts and fewer costly crew changes due to pilots reaching limits.That fatigue that Torque split refers to is also not accounted for.
So is TC fulfillingtheir mabdate if enforcing Regs consistently? I don’t think so; therefore Safety is reduced.
Here is the email:
As you are aware, Transport Canada’s priorities are to promote and develop a safe, secure and efficient transportation system, and aviation safety is of the utmost importance to the Department.Transport Canada is aware of your position, which you have raised on several occasions and we believe we have addressed all of your concerns. As no new issues or any new areas of concern have been raised we will consider this issue closed. As a reminder, Transport Canada's official position regarding air time vs flight time is attached. Sufficient information is provided for you to determine the responses to your survey questions. Again, thank you for writing.Sincerely,Robert Sincennes, P.Eng.Director, Standards BranchDirecteur, NormesTel: 613-991-2738 cell: 613-859-2796 facsimile / télécopieur : 613-952-3298Internet: firstname.lastname@example.org
Here is the attached interpretation:
Definition and Interpretation of air time and flight time as applicable to skid equipped helicopters.
CAR 101.01 – Interpretation
"air time" - means, with respect to keeping technical records, the time from the moment an aircraft leaves the 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;
CAR 605.94 Journey Log Requirements
(1) The particulars set out in column I of an item in Schedule I to this Division shall be recorded in the journey log at the time set out in column II of the item and by the person responsible for making entries set out in column III of that item.
(4) Unless recorded in the operational flight plan or operational flight data sheet, the pilot-in-command of an aircraft engaged in a commercial air service and operating in international flight shall record in the journey log the following particulars in respect of each flight:
(a) the names of all of the crew members and their duty assignments;
(b) the places and times of departure and arrival;
(c) the flight time;
(d) the nature of the flight, such as private, aerial work, scheduled or non-scheduled; and
(e) any incidents or observations relating to the flight.
Schedule I - Journey Log
Item Particulars to be entered
4. Air time of each flight or series of flights and cumulative total air time and, where applicable, number of operating cycles or landings since date of manufacture
1.For commercial international operations, air operators must record both air time and flight time in the Aircraft Journey Log.
2.Skid-equipped helicopters do not ground taxi. Manoeuvring at an aerodrome at low speed and low altitude is referred to by ATC as “air taxi” or “hover taxi” depending on the aircraft altitude. In any event, all movement by a skid-equipped helicopter involves flight.
3.Air time commences when the helicopter lifts from the surface and continues to the point of landing. Flight time occurs when the aircraft first moves under its own power for the purpose of takeoff and continues until it comes to rest at the end of the flight. In a skid-equipped helicopter, takeoff and manoeuvring for takeoff are the same action. Landing and coming to rest at the end of a flight are also the same action. Taxi-time on the ground is non-existent.
Conclusion: As the CARS flight time definition does not apply in the context of skid-equipped helicopter operations, the TC interpretation is that flight time equals air time for purposes of Journey Log entry requirements.
Note/Exception: There are some helicopter operations where the pilot is forced to land on a surface that will not fully support the helicopter’s weight, or may exceed pitch or roll limits, such as deep snow, swamps or rough, uneven terrain. Landings on these surfaces is generally done to permit crew members to disembark/embark or to unload equipment being used for the task at hand, such as firefighting crews and equipment, mountain operations, and external load hook up. In these cases, the pilot maintains aircraft position on a marginal surface by use of engine power (rotor at flight rpm and positive flight control placement including collective and pedal inputs). In summary, the helicopter is essentially still flying while in contact with the ground.
The definition of flight time is “the time from the moment an aircraft first moves under its own power for the purpose of taking off takes off until the moment it comes to rest at the end of the flight”. Our interpretation is that holding a helicopter in a position where the pilot must rely on the aircraft controls and engine power to maintain position and control does not meet the definition of “comes to rest at the end of the flight”.
The time spent in these operations - holding the aircraft in place by means of the controls qualifies and continues to count as flight time. Accordingly, the operator is fully justified in claiming this flight time in the Journey Log Book. If we consider flight time equals air time, then this allowance also addresses the necessity to log component time for the technical records as air time.
With regard to the ICAO definition for Flight Time – Helicopters contained in Annex 6, Part III, reads as follows:
Flight Time - helicopters. The total time from the moment a helicopter’s rotor blades start turning until the moment the helicopter finally comes to rest at the end of a flight and the rotor blades are stopped.
Note 1. The State may provide guidance in those cases where the definition of flight time does not describe or permit normal practices. Examples are: crew change without stopping the rotors; and rotors running engine wash procedure following a flight. In any case, the time when rotors are running between sectors of a flight is included within the calculation of flight time.
Note 2. This definition is intended only for the purpose of flight and duty time regulations.
•The ICAO definition only applies to international commercial operations helicopters – not private operations, whereas our CARS definitions for flight time and air time apply to all operations.
•The ICAO definition (Note 2) is intended only for flight and duty time calculations. This is to provide a means of capturing crew flight time particularly for signatory countries that do not have any flight and duty time regulations. This is not the case for Canada. Our current regulations and standards fully address commercial flight and duty limitations.
•Note 1 authorizes the State to provide guidance and interpretation for other considerations concerning normal practices.
•TC has not incorporated the ICAO definition into our CARS because this would result in inconsistencies in logging flight time between aeroplanes and helicopters and we believe the current definition – in which skid-equipped helicopter operations were considered- fully addresses the industry requirements, provided that one interpretation is used by all concerned.