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Freewheel

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Everything posted by Freewheel

  1. May 8/19 email: Dear Sir, We continue to work the file in addition to a number of other priority files. Please note we do not send back the disposition documents to individual commenters, but will be sending the AC out again prior to being finalized. As such, you will be able to assess how your feedback would have been dispositioned. Regards, Robert Sincennes, P.Eng. Director, Standards Branch Tel: 613-991-2738 cell: 613-859-2796 facsimile / télécopieur : 613-952-3298 Internet: robert.sincennes@tc.gc.ca Transport Canada | Transports Canada
  2. 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
  3. 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.
  4. 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).
  5. 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
  6. 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.
  7. 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...
  8. 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?
  9. 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
  10. 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
  11. 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?
  12. 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).
  13. HAC comments on Draft advisory Circular submitted to TC http://news.mediaedge.ca/assets/Flight%20Time%20Submission_%20February%2015%202019%20FINAL.pdf
  14. 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.
  15. 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
  16. Here’s what your successor at the HAC had to say about the new Draft Advisory Circular. http://mediaedgedigital.com/supplierinsights/hac/flight-time-v-air-time The communique was circulated yesterday. and asks for comments from members; apparently the deadline for comments was extended until today. That doesn’t give much time to comment but members are asked to submit comments to fred.jones@h-a-c.ca. No mention of Canada’s reduced licensing requirements vs. ICAO licensing requirements.
  17. Oh there’s no doubt their handling of this issue since 2011 has been extremely belaboured. I just meant the process described in the AC is not al that belaboured. I also understand that the ICAO licensing requirements are 150 hours vs. canada’s 100 hrs, and that we signed on to harmonize our requirements...but do you really believe that would happen? I’m not saying it shouldn’t, just wondering your thoughts on this.... Answer this: When you were President of the HAC and met with TC in 2005 to discuss this very issue, was that REALLY your intent...to have minimum commercial licensing requirements increased to 150 hours? I don’t recall you ever stating that back then.... Was GAPL 2005-02 not the result of those very discussions ? It was in play for 6 years after that...but I never heard anyone discussing this increase to licensing requirements...not from you...not from TC...NOT FROM ANYONE. It certainly wasn’t written in the Policy Letter. With that being said most people at TC Standards, HQ AND/or Ontario region never acknowledged that document as legit. In fact, those that did, tried to stipulate that it ONLY applied to licensing through Flight Training Units. In fact, recently my POI tried to tell that might be the case with this new guidance material. Who knows...it still might end up that way, given this is a draft. That’s quite odd given what you’re saying now...don’t you think? We all know that the CARs as written doesn’t allow for flight time to be interpreted differently from one regulation to the next. Our licensing requirements are lower than ICAO, yet the only stakeholders who were to benefit from GAPL 2005-02 were those companies who provided training towards a licence. At the risk of sounding like a conspiracy theorist...it sounds unethical.
  18. For those who are interested in compliance, attached is the Draft Advisiry Circular 700-052 - Recording of Flight Time for Skid-Equipped Helicopters The AC has been under development for more than a year. E-mail received today: Please note we extended the comment period at the request of industry associations and members. We will soon initiate a full review of comments and proceed from there as expeditiously as we can. Thank you, Robert Sincennes, P.Eng. Director, Standards Branch Directeur, Normes Tel: 613-991-2738 cell: 613-859-2796 facsimile / télécopieur : 613-952-3298 Internet:robert.sincennes@tc.gc.ca Transport Canada | Transports Canada 330 Sparks St Ottawa (Ontario) K1A 0N5 Government of Canada | Gouvernement du C RDIMS-#14731047-v3-AC_700-052_-_RDIMS-#14407279-V3-RDIMS-#14121971-V1-FL....pdf
  19. I’m not sure that this method is “extremely belaboured”, but I agree it is inconsistent with ICAO. TC seems more concerned with inconsistencies between the method Helicopters and aeroplanes use to log flight time. I don’t know about you, but I think the root cause of this whole mess was TCs failure to recognize there are very few consistencies between aeroplane and helicopter operations. The old “One size fits all” approach. Oh the irony... Additional excerpts from the AC. “Using the ICAO definition for flight time - helicopter which includes an allowance for rotors turning to rotors stopped introduces a significant discrepancy between aeroplanes and helicopters because aeroplanes do not record start up and shut down times as flight time.” “TC determined the existing CARs definition of flight time was more appropriate to ensure regulatory compliance by flight students, pilots, and air operators with the intended personnel licensing requirements. This would also ensure consistency by logging flight time in both aeroplanes and helicopters the method in accordance with the existing common standard. Subsequently, the GAPL was cancelled in 2009 and the Notice of Proposed Amendment (NPA) withdrawn. “ its also inconsistent with their own interpretation of aircraft “in operation” in the Canada Labour Code. Both definitions use the same terminology, so it’s likely the intent of the drafters was for Flight time to be consistent with the time an aircraft is “in operation”. I believe it is for aeroplanes....but apparently not for Helicopters. Yet another inconsistency between aeroplanes and Helicopters...TC AOHS and ESDC interpret a Helicopter as being in operation any time the rotors are turning for the purpose of taking off. its also inconsistent with current case law (Wildcat v Ellis). As I understand it, courts are bound by intent and case law, when statutory law is ambiguous. Question is, does Guidance Material trump both? On the flip side, it’s still a compllete 180 from Flight Time = Air time. The time spent on the ground during intermediate landings dwarfs the time spent starting and shutting down industry wide..
  20. We received a copy of the Draft Advisory Circular, AC 700-052 – Recording of Flight Time for Skid-Equipped Helicopters. This draft has been sent out to the Associations as well for a comment period before it is finalized and released. In its current state the Advisory Circular does not state that Flight Time is the same as Air Time for skid equipped aircraft. in a nutshell, It states Flight Time is from the first take-off to the last landing. Time spent on the ground during subsequent intermediate landings without shutting down shall continue to be logged as Flight Time. Excerpts: “Flight time ends when the skid-equipped helicopter contacts the supporting surface and shutdown actions are initiated by the pilot such as when the collective is fully reduced to the minimum position and moving the throttle(s) from the flight to idle position. The term “comes to rest” has been purposely selected in the definition, rather than “landing”, because “comes to rest” is interpreted to mean the chosen place for shutdown, or where no further flight is intended. In most cases, the shutdown sequence particular to the type will commence at this juncture; any or all intermediate stops where the pilot remains at the controls is to be included in the logging of flight time subsequent to the first take off”. “Air time as defined in the CARs is quite clear in its intent. It is simply the time in the air and is used primarily for technical component record keeping. However, there are exceptional operational circumstances that helicopter pilots must address. In some operations, helicopter pilots may have to hold their position involving partial ground contact by means of power and control inputs. Examples include toe-in operations, slope landings, hover exit with one skid in ground contact, or landing on surfaces that will not support the weight of the aircraft like deep powder snow, swamps or string bogs. In these cases, the pilot continues to literally fly the helicopter in position by manipulation of the controls and engine power lever(s) or throttle(s) set to the flight detent. This time should be logged as air time rather than flight time and applies whenever the aircraft is in partial ground contact, but has not securely landed. Anytime the helicopter position is maintained solely by aerodynamic forces and pilot control inputs cannot be construed as a landing. More simply stated, – if you can’t lower the collective to the minimum stop and reduce the engine(s) to idle, you have not landed”. Comments?
  21. A CARAC board member once told me that (way back) the idea of duty limits for engineers was thrown around. IN 2005, when they began the.implementation of SMS on all sectors, it was decided that this compliance based mindset was contrary to SMS principles. Under SMS, companies would be able to assess the risks at their organization and set their own limits and it would ultimately lead to de-regulation. The FRMS is based on these principles. Here is the problem, it’s 14 years later and they TC still haven’t been able to ensure implementation of SMS in most sectors and air carriers in Canada. I’m guessing FRMS will go about as smoothly as SMS. I also doubt that the average TC inspector, with no helicopter experience will understand the risks in our operations, so getting approval for deviations will likely be a nightmare. I also suspect that regional disparity will be rampant, whereby one operator can receive certain approvals, but others won’t. I for one think that AME’s should have Duty limits in the CARs. It’s a safety sensitive position and they work mostly at night. The “science” suggests they would be prone to fatigue.
  22. The Canada Labour Code has always taken precedence over the CARs for pilots; however the CLC allows for averaging agreements which provide for deviance from many of the regular CLC requirements. Averaging agreements are used in many industries. Case in point: My wife just got home from a 15 hour Duty day (working on a train, under an averaging agreement).
  23. Airbus Helicopters further reiterated that the definition of flight hours (not to be confused with Flight TIME) corresponds to Air Time as defined in CARs Section 101.01: Q1. Engine Start Time/Blades turning: 754 Time Up Time Dn Air Time Starts Comments 800 804 4 min 1 CYMO – Lagoon 809 812 3 min 0 Lagoon – CYMO 816 819 3 min 0 CYMO – Lagoon 822 825 3 min 0 Lagoon – CYMO 829 833 4 min 0 CYMO – Lagoon 838 841 3 min 0 Lagoon – CYMO 844 847 3 min 0 CYMO – Lagoon 850 853 3 min 0 Lagoon – CYMO 855 858 3 min 0 CYMO – Lagoon 904 909 5 min 0 Lagoon – CYMO Engine Shutdown @ 912; Rotors Stopped @ 914 Q2. Engine Start Time/Blades turning: 754 Time Up Time Dn Air Time Starts Comments 800 824 24 min 1 CYCN – CYTS Engine Shut Down @ 830; Rotors stopped @ 831 Airbus Technical support repose below: “Good morning, I am doing ok here I hope you are also. Regarding your question yesterday on flight and air time please review the following. Airbus Helicopters is concerned with limitations expressed in Flight Hours (FH), Calendar time & Cycles. The definition of FH is given in both the Chapter 4 Airworthiness Limitations Section (ALS) and Chapter 5 Master Servicing Manual (MSM) both are available through TIPI and as part of the standard documentation for each model of aircraft operated. This definition of flight hours (not to be confused with Flight TIME) corresponds to Air Time as defined in CARs Section 101.01: Airbus Helicopters does not take into account running time (i.e. flight time by ICAO definition) for purposes of tracking limitations. So in answer to your two questions: A1: answer a. Flight Time = 1.3 / Air Time = 0.6 A2: answer Flight Time = 0.6 / Air Time = 0.4 (Note: rotors stopped at 0831) If you have any further questions regarding Airbus Helicopters requirements for tracking time please let us know. Best regards, Rod Rod TUPALA Technical Support (Ontario) Airbus Helicopters Canada Limited”
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