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Flight Time Vs. Air Time Personal Logbook

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On December 19, 2011 a second CAIRS report was filed sighting "Lack of Response with regards to CAIRS IB-8718 and possible system issues identified with Civil Aviation Issue Reporting System." These system issues included, the inability of Transport Canada to meet the published Service Standards with regards to the CAIRS system and lack of respect for stakeholders who come forward with concerns.

 

On December 23/11, I received the following e-mail:

Dear Mr.Calaiezzi :

 

I am writing to you concerning your Civil Aviation Issues Reporting System (CAIRS) file no. IB-8718. This issue was raised to me as the CAIRS system and processes fall under my responsibilities.

 

At the outset, I apologize for the misplacement of your initial report sent to us by registered mail in April. I have investigated this matter and am reviewing our processes to identify the root cause and make improvements to prevent recurrence.

 

Please rest assured that we do take your concerns very seriously. While we strive to meet the CAIRS service standard of 20 working days for all responses, in this case, you have raised several issues that are quite complex and extra time is needed. I will be working with my colleague Jacqueline Booth, the Accountable Manager for this file, to provide you with a follow up response.

 

If you have any questions please do not hesitate to contact me.

 

 

Lucille Kamal

Director, Civil Aviation Secretariat

Directrice, Secrétariat de l’Aviation civile

Telephone/téléphone 613-991-9964 | Facsimile/télécopieur 957-4208

TTY ATS 613-990-4500 | [email protected]

Transport Canada / Transports Canada

Place de Ville (AARC) Ottawa ON K1A 0N5

Government of Canada / Gouvernement du Canada

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Response to December 23/11 e-mail (from Lucille Kamal):

 

Hi Lucille,

 

Thank you for the reply. I was unsure whether or not CAIRS was still active as I have not received a response to follow up e-mails in quite some time. I understand that the issue has far reaching implications, however there is only one issue here (not several as you suggest). The issue is how to interpret the definition of Flight Time for skid equipped helicopters and how we got to this point where everyone seems to be confused. This issue has been raised numerous times in the past, yet TC has failed correct the confusion (in-house) and industry wide. I refer to GAPL 2005-02 which was recently cancelled as evidence of this.

 

Our inspector made a finding against our COM in a PVI (almost a year ago). The root cause analysis that was conducted identified a much deeper issue as the root cause : confusion Industry wide and throughout TC. We submitted this in our CAP, however it was denied and TC refused to implement any corrective actions against this root cause; instead it was up to us (the operator) to implement corrective actions which did not address the root cause or prevent future recurrence.

 

I respect that the process of conducting your root cause analysis on an issue that has been going on for over 15 years is likely complex, however clarifying TC’s interpretation of the definition should not take a year. Even if, we forget about the initial CAIRS that was “misplaced” in April, the fact is the CAIRS was resubmitted in July; we are going on 6 months now and we still have no clear answer.

 

Our POI conducted a PVI follow up on December 6, 2011 and advised us that he was going to recommend that the PVI report be closed. We advised him that we did not agree with this since no corrective actions that address the root cause of his finding have been implemented. We have certainly, demonstrated that confusion is rampant industry wide (and within TC), so we would like the finding removed or amended to state that the root cause did not originate within our organization, but TC’s.

 

In my opinion, you may require additional time to conduct a thorough root cause analysis within TC; however there is no reason why we the operator should not be advised that indeed our initial root cause analysis was correct and the PVI finding changed. While you delay your response we continue to have an inaccurate or invalid finding in our most recent PVI. We feel this finding insinuates that we have “cut corners” on our flight training, which could not be further from the truth. Since we are audited regularly by large clients, this has a negative impact on scores and our ability to do business. There also serious safety concerns that are not being addressed industry wide while we wait for a response (that is long overdue); how should pilots log there times in the meantime?

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Should we ask our insurers to include a coverage against Transport Canada deficiencies in our insurance policies?

Or should we ask our insurers to state their own flight time definition in our insurance policies?

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We finally received our approved Amended COM to remove the statement "Flight time and Air Time are the same...."

 

The recently approved amendment states:

 

4.18 Flight Records

 

(1) Company Flight Report Forms shall be completed after every revenue flight. The pilot shall ensure that the customer signs the completed Report.

 

(2) The aircraft journey log book shall be completed at the termination of each flight or daily, after a series of flights by same pilot-in-command. Pilots shall ensure that each column of the journey log is completed. Do not use the words "Full" or "Within Limits" actual figures shall be used.

"Air time" with respect to keeping technical records is defined as, 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.

 

NOTE: In the case of flights with multiple landings and take-offs between start and shut down, “flight time” shall continue to be logged while the helicopter is in contact with the surface but still under control by the pilot in command. If the intent is to not terminate the flight and where there is no intent to shut down the helicopter, then the “flight time” should continue to be logged.

 

 

Previous Version:

 

4.18 Flight Records

 

(1) Company Flight Report Forms shall be completed after every revenue flight. The pilot shall ensure that the customer signs the completed Report.

 

(2) The aircraft journey log book shall be completed at the termination of each flight or daily, after a series of flights by same pilot-in-command. Pilots shall ensure that each column of the journey log is completed. Do not use the words "Full" or "Within Limits" actual figures shall be used. Flight Time and Air Time are the same for skid equipped helicopter, accordingly the recorded times shall be identical.

 

For those who's COM still states "Flight Time and Air Time shall be the same...", answer me this: how is it possible for both of our COM's to be in "accordance with the laws and regulations of Canada"?

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We received a formal response to CAIRs IB 8718 a few days ago (from Arlo Speer Cheif/Commercial Flight Standards). Apparently TC has no interest in amending the PVI finding to state the true root cause (TC/Industry wide confusion)or clarifying this issue to the industry. They are treating this like an issue that is confined to our organization. He states that we have received the Clarification from Ms.Booth on september 20th (which is the official response from the accountable manager). No mention of clarification to the industry:

 

Mr Calaiezzi:

 

Your December 16, 2011 email states in part:

 

“…Also, if this CAIRS has been closed I have never been advised. I would suggest this type of ignorance to stakeholders concerns jeopardizes the integrity of the CAIRS system and demonstrates that TC pays nothing more than “lip service” to their own SMS. I will continue to follow-up, and push other operators and pilots to voice their concerns about this threat to aviation safety.

 

Merry Christmas…”

 

Merry belated Christmas Mr. Calaiezzi. CAIRS 8718 is active. Thank you for your proactive approach to mobilizing air operators to operate safely, and thank you for your interest in aviation safety.

 

 

Your December 1, 2011 email states in part:

 

“…There is another aspect that I have not formally discussed yet that I think needs to be brought to your attention. This is how TC approved Flight Training Units in Canada have been interpreting Flight Time and Air Time with respect to licensing and CARS requirements…”

 

Thank you for your concern in regards to Flight Training Units. We will discuss this issue to ascertain if safety is compromised relative to your comments.

 

 

 

Your November 25, 2011 email states in part:

 

“…the Accountable Manager chooses not to provide a response. It has now been 43 working days since I made my last request and 80 days since my initial report was entered into the system on August 2, 2011…”

 

We agree that our response time to your many follow-ups comments is unacceptable. We attempt to respond to air operator’s queries in a timely fashion and as quickly as work load allows.

 

 

 

Your November 4, 2011 email states in part:

 

“…Can you advise me which "appropriate Division" of TC you forwarded my e-mail to?”

 

The “appropriate Division” within headquarters for the majority of your queries’ is Commercial Flight Standards,

 

 

Your November 4, 2011 email states in part:

 

“…At the risk of sounding like a broken record, once again, here is what we would like to see happen:

 

1) the PVI finding removed if invalid or….

 

The Ontario Region indicated that the findings in question were in response to your company not operating according to its Company Operations Manual.

 

 

Your November 4, 2011 email states in part:

 

“…3) I would like to see formal clarification to the aviation / helicopter industry for the following reasons:

- this confusion is industry wide and has serious implications to aviation safety (pilots /operators are using air time when calculating Flight time limit…”;

 

The formal clarification was offered you within our The September 20, 2011 response that stated in part:

 

“…The meaning of the phrases “air time” and “flight time” for Canadian operations are found within Subsection 101.01 (1) of the CARs which are applicable to all parts of the aviation regulations...”

 

“…The meaning of “flight time” within Subsection 101.01 (1)…remains intact…”

 

“…The appropriate “air time”, “flight time” and “flight duty time” for Canadian operations should be logged in accordance with CAR 101 definitions…”

 

“…The reality is that helicopter flights do not end when the helicopter touches a surface, but rather “…the moment it comes to rest at the end of the flight….” as per the meaning within Subsection 101.01 (1) of the CARs…”

 

“…The appropriate “air time”, flight time, and “flight duty time” for Canadian operations should be logged as per the meaning (s) within Subsection 101.01 (1) of the CARs…”

 

 

Your November 4, 2011 email states in part:

 

“…4)I would like to see the statement in COM that states "Flight Time and Air Time are the same" removed from all COM's across the country (including ours)…”

 

Please approach your POI should you wish to amend your Company Operations Manual. Operation issues should be resolved with your POI and/or the Regional “Technical Team Lead of Operations” for your area as per our Sept 20 response to CAIRS# IB-8718.

 

 

Your October 20, 2011 email states in part:

 

“…I am aware that the Accountable Manager has 20 days to respond to a CAIRS submission, however is it really necessary to reset the 20 days after each communication?”

 

Yes it is necessary to reset the “20 day” after each communication. Your desired response may be delayed by posing multiple identical questions to multiple individuals while referencing the same CAIRS number.

 

 

Your October 19, 2011 email states in part:

 

“…Expedition Helicopters Inc. received a PVI Finding with regards to this issue. We believe the finding is not valid as per the CARs definitions for flight time and air time…”

 

“…Can you advise me what kind of time frame I should expect for a response? I’d also like to point out that I have yet to receive any communications from the accountable manager for CAIRS# IB-8718, (or any other TC representative) with regards to my concerns…”

 

The requirement to calculate and log “air time” and “flight time” is referenced within various Parts of the Canadian Aviation Regulations (CAR). The meanings (definitions) of the phrases “air time” and “flight time” for Canadian operations are found within Subsection 101.01 (1) of the Canadian Aviation Regulations (CAR) which are applicable to all parts of the CAR. The appropriate “air time” and “flight time” for Canadian operations should be calculated and logged in accordance with the meanings described within Subsection 101.01 (1) of the CAR.

 

Issues concerning your recent “PVI” should be resolved with your Principal Operations Inspector (POI) and/or the Regional “Technical Team Lead of Operations” for your area.

 

We attempt to respond to air operator’s queries in a timely fashion and as quickly as work load allows.

 

Ms. Booth is the “accountable manager” for the Civil Aviation Issues Reporting System (CAIRS) file number IB-8718. Her September 20, 2011 response to CAIRS 8718 is the official response from the “accountable manager”.

 

 

 

Your September 26, 2011 email states in part:

 

“…Your interpretation of the CARs definitions for Flight Time and Air Time (and whether they should be logged as the same) is of particular interest to me…”

 

“…The September 20, 2011 response to CAIRS# IB-8718 stated the meaning of the terms in question contained within the Canadian Aviation Regulations (CARs). How the meanings of the terms in question contained within the CARs should be interpreted relative to the specifics of your operation, should be discussed and resolved with Transport Canada at the Regional level. The POI is the usual contact for such a discussion involving an interpretation relative to a specific air operator scenario.

 

The September 20, 2011 response to CAIRS# IB-8718 states in part:

 

“…The meaning of the phrases “air time” and “flight time” for Canadian operations are found within Subsection 101.01 (1) of the CARs which are applicable to all parts of the aviation regulations...”

 

“…The meaning of “flight time” within Subsection 101.01 (1)…of the remains intact…”

 

“…The appropriate “air time”, “flight time” and “flight duty time” for Canadian operations should be logged in accordance with CAR 101 definitions…”

 

“…The reality is that helicopter flights do not end when the helicopter touches a surface, but rather “…the moment it comes to rest at the end of the flight….” as per the meaning within Subsection 101.01 (1) of the CARs…”

 

“…The appropriate “air time”, flight time, and “flight duty time” for Canadian operations should be logged as per the meaning (s) within Subsection 101.01 (1) of the CARs…”

 

Your perception of: a discrepancy between the CARs and your Company Operations Manual (COM) and scenarios specific to your operation should be resolved with your POI and/or the Regional “Technical Team Lead of Operations” for your area as per the response to CAIRS# IB-8718.

 

 

The September 20, 2011 response to CAIRS# IB-8718 states in part:

 

“…Transport Canada (TC) assigns a Regional Inspector to each air operator as a Principal Operations Inspector (POI) to liaise on operation matters. This set up is meant to ensure TC offers an appropriate point of contact that is most familiar with the individual air operator’s needs. If the POI encounters situations and/or issues that they are unable to resolve, consultation with TC Regional Management or TC Headquarters may occur. Due to the structure of Transport Canada advice offered by TC Headquarters is considered functional guidance, and is rarely offered directly to the air operator but rather to the POI, thereby avoiding confusion and preserving the relationship between the POI and air operator.

 

If an air operator wishes to discuss a situations and/or issues with a TC representative other than their POI they should consult TC Regional Management…”

 

Thank you for sharing your views and thank you for your interest in aviation safety. Should you have any further questions, please feel free to contact your Principal Operations Inspector and/or the Regional Technical Team Lead of Operations for your area.

 

 

Sincerely,

 

 

Arlo Speer

Chief

Commercial Flight Standards

Civil Aviation

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I guess we'll have to rely on Vertical Forum to spread the word:

 

Dear Mr. Speer,

Thank you for the lengthy response. As you have so kindly pointed out, I have been provided with most of these responses in the past. I thank you, and all involved with the CAIRs process for providing it to me; in some cases the information you provided was very helpful. I believe, Jacqueline Booth’s interpretation of the definition of flight time in particular was helpful in convincing my POI and the Region that my interpretation was correct (and likely eventually led to the recent approval of my COM).

 

Until very recently, my POI argued with me that Flight Time and Air Time should be logged as the same. On March 11/11 he advised me:

“If you believe there is an incorrect definition in the CAR's perhaps you would be wise to submit a CAIRS. I don't see the fact that the regulations as they are, not being to your satisfaction as a valid excuse to operate otherwise.”

 

In June 2011, the Team Technical Lead visited our facility and advised us that he agreed that our concerns were valid and he would forward our concerns to Ottawa. On July 6/11 we received an e-mail from our POI, stating that Mr. Robert Freeman from Ottawa advised him of this very same fact :

“Mr. Freemans office has replied to us that these times should be entered as the same. ”

 

These are only a couple of examples that I could present to you, but these statements seem to be in complete contradiction from what you and the Director of Standards have been advising us. It was only recently,(December 2011) that our POI visited our facility and confirmed that Jacqueline’s interpretation was correct, and that he was willing to approve my manual amendment.

 

Even after I presented my POI with Ms. Booth’s September 26th e-mail, they would not acknowledge that Flight Time and Air Time are different. I believe they stated something to the effect “that her interpretation still had not been officially disseminated throughout TC.” Considering Ms. Booths lack of response to my follow-up e-mail, and statement that “however the majority of flights conducted by commercial helicopter operators are logged as the same time”, I was unsure of the validity of her statements and whether this was Transport Canada’s official interpretation. It is only now that I have received your e-mail that I can confirm this. As I expressed to Jacqueline, I still disagree with this statement, I would say that most flights in Canada should not be logged as the same with respect to Flight Time and Air Time; you made no comment in your e-mail with regards to this statement.

 

Considering these uncoordinated responses and obvious confusion:

 

What has been done to that TC employees across the nation have a clear understanding of the CARs definitions (as it is apparent many do not)?

 

Has there been any formal dissemination of Ms. Booth’s clarification throughout TC to ensure that in the future they are not offering misguided interpretations?

 

The investigation into this finding has also led to evidence that this same confusion exists from one company to the next throughout the country; nowhere in your response does it discuss how clarification to the industry will be accomplished.

 

With regards to your comment (Jan 26/12- e-mail):

“Please approach your POI should you wish to amend your Company Operations Manual. Operation issues should be resolved with your POI and/or the Regional “Technical Team Lead of Operations” for your area as per our Sept 20 response to CAIRS# IB-8718”;

 

We have done exactly this and after a year of attempting to amend the manual, I was advised January 25th, 2012, that it was approved.

 

How is it possible for TC approved COM’s to be in direct conflict with each other? There are several COM’s across the country that still state that Flight time and Air Time are the same for skid equipped helicopters. We see this as more evidence of the disparity throughout the country with regards to this issue.

 

I understand that each COM is tailored to the specifics of each organization, however when it comes to the bare minimum regulatory requirement, a statement that “Flight Time and Air Time are the same” clearly is in conflict to your interpretation of the CARs. It is also my understanding that Transport Canada approves each Company Operations Manual as being written in “accordance with the laws and regulations of Canada”.

 

As recently as last summer a Commercial Operator within the Ontario region, (with whom we are in direct competition) had an approved COM that stated that Flight Time and Air Time are the same, yet their approved MCM contained specific instruction on the differences of calculating the two. How could there be such disparity within one organization? This issue seems to be more than an issue of regional disparity since we are seeing disparity within regions (from one operator to the next).

 

I have also been informed that some operators and pilots are using Air Time in their Flight Time limit calculations (and sighting the statement in their COM as supporting documentation). This is a safety matter that truly concerns us.

 

With regards to your statement (Jan 26 e-mail):

“The Ontario Region indicated that the findings in question were in response to your company not operating according to its Company Operations Manual.”

 

This is correct; what you (or they) fail to acknowledge is that the statement that was in our COM was not valid as per the CARs (as clearly stated by Ms. Booth and yourself), and the Ontario region refused to allow us to remove the statement and amend it to reflect the actual CARs definitions. The statement was placed in our COM by TC when they issued us a template and first approved it in 1999.

 

We also view the PVI report, as it is written, as misleading, and the corrective actions that we were forced to implement do nothing to address the true root cause or prevent recurrence. Is the ultimate goal, not to prevent recurrence? I can assure you, this is the sole purpose that we have pursued this with such vigor.

 

While it is obvious TC intends on closing this CAIRS regardless of these concerns, I will discuss whether we should continue pursue this matter through other established redress mechanisms with our Accountable Executive and Safety Committee. Through past experience, I would suggest that they will likely want to continue to push for answers. I agree with the Accountable Executive when he states, we have a responsibility to our organization not to close a report in our SMS until we are satisfied that the corrective actions that have been put in place that will prevent recurrence; I do not believe this to be the case.

 

Unfortunately, the investigation that was undertaken at our organization while actioning the PVI finding through our SMS has identified a much larger issue throughout the industry and Transport Canada. It is obvious that a great deal of confusion exists with regards to this issue. While early on, we identified confusion throughout the industry and TC, as the root cause of the PVI finding. We were not aware of how widespread this confusion was until we really began to investigate the matter. It’s also clear that that a great deal of disparity exists with regards to interpretation (and enforcement) of the regulation by Transport Canada. We feel it is unfortunate that TC does not see this as an opportunity to correct this issue on a much larger scale (than simply within our company).

 

With all due respect to your suggestion that we should contact our Principal Operations Inspector and/or the Regional Technical Team Lead of Operations; while we look forward to working alongside them with any future concerns that arise, it is obvious they have no intention of correcting the PVI or clarifying this issue to the industry…this is why we filed the CAIRs.

 

I apologize if some of my e-mails are direct and to the point. I have been told in the past that sometimes they come across as rude. I hope you understand that I received nothing but resistance (from various levels of TC) in getting this clarification, and in some cases I was very frustrated in the lack of response and delays. This frustration may be evident in my past e-mails.

 

Yours truly,

 

Chad Calaiezzi

Operations Manager

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Wow just reading the responses is frustrating and as you mentioned freewheel there is obviously still confusion from all aspects of the industry.

 

I was training recently with an FTU on and IFR course. On an average flight with 1 takeoff and landing I was Billed 1.8 for flight time, then was told to log 1.6 for instrument time and when i checked the aircraft logbook, 1.5 hours of airtime in the logbook. I still think if I flew a 1.6 of instrument time on the instruments how did the aircraft only fly 1.5 hours. Is this legit? maybe just standard industry practice? But according to Freewheels response from TC if i was billed flight time in this case shouldn't i have been billed 1.5? Is my rating valid if the aircraft flew less hours than i logged as instrument time towards the IFR rating?????

 

Honestly i don't know what the right way to do it is. and seems niether do a lot of people. Although i am sure a lot of people manipulate it into what favours them best $$$$$.

 

 

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Hey _________,

 

Flight time, airtime, time on the invoice.... lol Schools are famous for ripping off their students like this. Just another customer to take advantage of and if you speak up about it you get the treatment that is so common for low timers in the industry, veiled threats and intimidation and extends to spreading your name around this very small industry that you are a "trouble maker". Welcome to the helicopter industry. Pay attention to this post students, check your invoice and compare it to the log book, don't let them BS you about the flight time being billed to you to take care of the instructors time. Really, should briefings not take place in the class room and would the "flight pay" rate not be enough? No let's charge $600 to $1200 an hour and everyone makes a bit more money because in the end that's what it's all about.

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OK here's how it was done at the school I used to run.

 

Students where charged FLIGHT TIME, the time on the hobbs meter +0.1 hours, for warm up, shut down etc. This was ALSO logged in their LOG BOOK, and in the AIRCRAFTS log-book as FLIGHT TIME. AIR TIME was logged as per hobbs (Robinson R44) and also went in the "AIR TIME" Column in the journey log.

 

for INSTRUMENT time, you HAVE to take off and land visually, thus the region I was teaching in (Toronto Region), would only accept 0.1 LESS than air time for IFR time, and lots of people found this "unfair" but it was not us "the school" taking advantage, it was TC.

 

Now if you look at the Flight/Air Time and what we charged students, I don't think that practice was particularly unfair.

 

Also of note, we NEVER charged for pre/post flight briefings, whether they lasted 2 minutes or 62 minutes.

 

And Ground school was 80 hours paid for, but ALL the students received WAY more, sometimes in the 150 hour range for ground school.

 

But that was how it was done where I used to work.

 

As far as flight time and air time goes, some people at TC needs to pull their heads outta their bee-hinds, and READ, RE-READ and RE-READ again the actual CAR's definition...

 

I think Freewheel is doing a great thing, and only sad that he's meeting so much resistance.

Cheers

H.

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