Flight Time Vs. Air Time Personal Logbook

[Translation]

Cadors Number: 2012P0151

 

If the pilot's record records an accident with regards to the file above, then it most certainly happened during "flight time", wouldn't you think?

 

"The rotors were turning at idle rpm when it was struck by the avalanche. The snow pushed the helicopter on to its side and broke the tailboom. "

[Winnie]

Cadors Number: 2012P0151

 

If the pilot's record records an accident with regards to the file above, then it most certainly happened during "flight time", wouldn't you think?

 

"The rotors were turning at idle rpm when it was struck by the avalanche. The snow pushed the helicopter on to its side and broke the tailboom. "

 

Not necessarily!

 

What constitutes an accident does not necessarily have to happen when the blades are turning.

 

Say for instance you have shut down, you are debarking a passenger who slips and falls, and breaks an ankle, that is considered an aircraft accident, even tho the blades were not turning.

 

Flight time as said before is from First liftoff, to last set down, whilst air time is all time accumulated in the air.

 

Cheers

H.

[Freewheel]

and the saga continues....out of the blue I received an e-mail from the Chief of Standards:

 

In our earlier replies to you about CAIRS # IB-8718 we responded to your many queries. The information we provided with respect to “air time”, “flight time” and “flight duty time” is still valid and still applies to your continued observations.

 

In your most recent submission, you asked about how student pilots log flight time in their personal logs. Observations of our inspectors and licensing officers give us no reason to suspect that student pilots record any time in excess of time from the moment an aircraft first moves under its own power for the purpose of taking off until the moment the aircraft comes to rest at the end of the flight.

 

You also asked if examiners may have conducted licensing flight tests with candidates who have less experience than required. Again, evidence available to our inspectors and licensing officers give us no reason to suspect that student pilots record time in excess of the actual amount flight time they have completed.

 

Any further issues related to the operation of your Company are best resolved with your regional Principal Operations Inspector and/or the Technical Team Lead in the Transport Canada regional office nearest you.

 

Sincerely,

 

Arlo Speer

Chief, Commercial Flight Standards

Standards Branch

Civil Aviation

[Freewheel]

Our Reply to Mr. Speer:

Hi Mr. Speer,

Thank You for your time on this matter, however it seems you misunderstood what I was trying to get across. You have not informed me of anything new; I am aware that most schools have been logging time just as we have been doing…the opposite of what our Inspector and HQ’s have been telling us to do. As a matter of fact, through conversations with the owner of the school that I trained at, I have ascertained that (several years ago) the very same inspector tried to tell him that students should receive 100 hours Air Time (because Flight Time and Air Time are the same). Before he was required to implement this interpretation on a formal level, the inspector was changed and the issue disappeared. That companies COM also had a statement that Flight Time and Air Time shall be the same for skid equipped helicopters. They did however log as you and Ms. Booth suggest.

 

What I am trying to explain to you, is that if we examine the interpretation that my POI was using for Flight Time definition, these students would not meet the CARs as for experience level. I assume that in most cases that you observed, there was indeed a difference between the Flight Time and Air Time being logged. Correct???

 

Until very recently our inspector was advising us that flight time should only be logged “skids up to skids down”; the same as air time. This is in contradiction to what you are telling me. What is being done to correct this common misconception?

 

This is exactly why we received the findings last year: because 2 TC inspectors believed Flight Time to be the same as Air Time and refused to acknowledge the Flight Time column in the logbook when comparing training records to Times in the Journey log book.

 

Here are the facts as we see them:

 

1. The finding says nothing about the statement in the COM : “Flight Time and Air Time are the same…”, it only states that the training records did not match the journey log air time entries; it makes no mention that the training records did match the Flight Time column.

2. The Finding also states that a PCC record does not match the journey log entry (it does match the flight Time column, just not the air time column). I have attached a copy of the Finding. I could also send copies of the journey log and training records if you would like. Perhaps this will clear up our concerns for you.

3. Our approved training program says that 1.0 hour flight Time is required (not air time) for recurrent training .

4. The incorrect statement (i.e. “flight time air time are the same…”) in the COM had already been identified by Expedition Operations Manager and discussed with his POI. The POI advised he believed the statement “Flight Time and Air Time are the same” to be correct.

5. The statement was placed in the COM by Transport Canada before it was given to us by TC in 1999.

6. HQ advised us (through our POI) that Flight Time and Air Time were the same (and the statement in the COM was correct); that is why we received the finding. ( I could also send you some more of the recent correspondence of TC inspectors and HQ (A**X R****ts) telling us to flight time and air time as the same for skid equipped helicopters.)

7. The COM had already been submitted for amendment to remove the statement that “Flight Time and Air Time are the same…” prior to the PVI inspection and finding.

8. It was not until this January 2012 (1 year later) that our inspector agreed to amend our COM to remove this statement and acknowledge that it is possible for Flight Time to differ from Air Time

9. As per your explanation of how flight schools are operating (and the definition offered by J. Booth), each of the training flights identified in the finding would have been completely compliant with the CARs and our approved training program

10. Expedition Helicopters Inc. spent 1000’s of dollars on travelling and training expense to retrain pilots to a minimum level of 1.0 hour air time ( as a part of corrective action that did not address the root cause).

11. The initial Corrective Action Plan that we submitted , suggested that our COM be approved for amendment to remove the statement that “Flight Time and Air Time are the same…” . This CAP was rejected by our POI.

12. The corrective action plan as only approved when we agreed bring all trained pilots up to a standard of 1.0 hour air time. In our opinion these corrective actions (flight training) did nothing to address the root cause and therefore will not prevent recurrence of the event.

13. No corrective actions have been put in place (or documented in the corrective action plan) to address the root cause that was identified (TC/industry confusion). Obviously several TC employees were misguided in their interpretation of the CARS definitions.

14. I suspect the true root cause is directly related to organizational issues at Transport Canada. This is why I submitted this CAIRS, in hopes that TC might be able to identify what causal factors led to this situation where inspectors and headquarters are offering such misguided/conflicting interpretations over such a basic principle.

15. I have recently received copies of several TC approved COM’s (from several other commercial operators) that make the statement that “Flight Time and Air Time are the same for Skid equipped helicopters”. How is possible that these COM’s are approved as a valid representation of the CARS, while mine was recently approved with a statement that directly conflicts them????

 

 

Regardless of who was right with regards to logging time, the fact of the matter is, I have demonstrated that a great deal of confusion exists amongst TC and the industry. All we have ever asked is that the finding be amended to state the facts and true root cause of this issue. We believe this to be the only true way to prevent recurrence. If this finding was made against our COM, should it not state that our COM was not valid? Should it not be worded to state that the statement in our TC approved COM was not valid and the COM required amending (as opposed to stating our training was fudged)? Also, should it not state the true root cause? We have asked TC to explain what that might be. We know that our inspectors believed it to be a valid statement, but Why? Why? Why? Why?Why?

 

In our opinion, this type disparity with regards to the enforcement of the regulations (from one operator to the next) challenges national objectives and is contrary to the principles that sustain our system of governments. The Canadian Charter of Rights guarantees that every individual in Canada is equal before and under the law and has the right to equal protection and equal benefit of the law. It’s unfortunate that TC does not see this as an opportunity to rectify this disparity. I ask again, who’s COM is correct? It seems to me that operators are not being held to an equal standard as per the CARs. We are considering presenting this case to the Transportation Appeal Tribunal of Canada in an effort to have the PVI report amended to reflect the actual facts.

 

The process of actioning this issue through the CAIRS has identified several other systematic issues at TC and has been very disheartening as a stakeholder. I believe TC has some serious cultural issues to deal with before advancements in SMS will be evident.

 

As stated in earlier e-mails, we intend on pursuing this matter through other formal redress mechanisms.

 

 

Regards,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

[Freewheel]

Follow up (Some Names blocked to ensure compliance with Vertical Code of Conduct):

 

Hi Arlo,

 

Please see the e-mail string below whereby our POI advises us that Headquarters (AXXX RXXXXX/RXXXXX FrXXXXX) has informed them (POI and Technical Team Lead XXXX XXXXXXXX) that the statement (that flight Time and Air Time are the same for skid equipped helicopters) in our COM is correct and that Flight Time and Air Time should be logged as the same. Our POI suggested that we contact Mr. FXXXXXX ourselves if we further wish to challenge the statement in the COM. This e-mail is dated July 6/11 and clearly demonstrates that headquarters and our POI were not offering correct guidance with respect to this issue as recently as last summer.

 

When I contacted Mr. FXXXXXX I was advised that any communications from his office would have to be through our POI.

 

Again, this e-mail correspondence seems to contradict what you and J.Booth have been telling us. Would like to comment on Mr. RXXXXXs opinions and there validity? Perhaps I am missing something here.

 

I have also attached a document that contains exerts from our COM in hopes to clarify our concerns to you. I have been trying to do just that for 16 months now; yet I don't seem to be successful at getting through. You don't seem to understand that we were not permitted to remove the statement, yet we knew that if we logged our Flight Time to be the same as Air Time our pilots would be in contradiction to the CARs (as you and Jacqueline Booth have explained). One major concern we had was with respect to fatigue and Flight Time limits (when using flight time = air time method).

 

Also, please find attached another finding from the PVI. Although, we don't dispute the administrative findings against the Training Pilot for not completing the form in its entirety, we do have issue with the statement: "The flight Time was shown as 0.5 on the form however, the journey logbook only showed 1.3 hours of which 1.0 was logged as training." This statement is deceptive and not factual at all; we would like this statement removed (or corrective actions added to the Corrective Action Plan for this finding that address the true root cause). The Air Time column showed 1.3 hours for the Flight, while the "Flight Time" column in the Journey Log stated 1.8 hours, which accounts for the 1.3 hours of recurrent training and 0.5 hours for PCC. If we consider that recurrent training and a Pilot Competency check would involve multiple periods of being in contact with the earth's surface (with no intention of shutting down), then these time are completely reasonable.

 

As per J. Booth's interpretation and your further guidance, this training flight exceeds the minimum requirement as per the CARs and our Training program.

 

Regards,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

 

E-mail String from July 6/11 (read from bottom up):

 

"Dear Mr. Calaiezzi

 

BXXX did indeed ask me to contact Mr. FrXXXXX's office and ask the question regarding the JLB entries for flight time and air time again. Mr. FrXXXXX referred us to AXXX RXXXXX from his office. Mr. RXXXXXX response was that he was in agreement with Mr. FrXXXXX, so yes at BXXX's request this did occur but BXXX left it to me and I simply hadn't gotten back to you yet on BXXX's behalf as he had originally asked me too. Sorry for the delay BXXX.

 

Kindest Regards

 

JXXXX XXXXXX

 

Hi JXXXX,

Has anyone been in touch with Mr. FXXXXX's office since BXXX visited our hangar on June 9. I ask because when BXXX left he seemed to agree with me that there was confusion with respect to how to log time in personal logs and flight duty times. Specifically when dealing with short flights and operations with a high frequency of landings. BXXX told us that Mr. FrXXXXX had already responded(prior to June 9), however he PROMISED that he would reword the question to Mr. FXXXXXX and ask for further clarification. Did this ever occur? I don't think it did since BXXX sent me an e-mail yesterday confirming he never followed up....despite the fact that XX assured me that they were committed to providing me with further clarification within 30 days... 30 days later we have been advised to contact Mr FXXXXXX ourselves...thanks for the assistance Chad

 

 

 

 

Hi Chad

 

We have been in contact with RXX FrXXXXX's office in Ottawa to ask about the issue of Air Time and Flight Time being logged as the same in skid equipped helicopters as per the instruction in 4.18(2) of your COM. Mr. FrXXXXX office has replied to us that these times should be entered as the same. I suggest to you that if your company wishes to further challenge this COM statement then you might discuss it with Mr. FrXXXXX as I believe our office has done all we can to date regarding this issue.

Please accept this response as the one BXX and BXXX promised you as both are presently not available.

 

Regards

 

JXXXX XXXXXX

Sudbury TCC"

[pilot5]

Well as soon as those rotors are turning its moving all over the place, vertical and horizontal . A 205 I once flew had so much vertical could have swore it was bouncing off the ground and therefore moving under power and leaving the ground if only for a millisecond and 1 1000 th of a milimeter and therefore " off the ground" for those folks that really want to nit-pick ! So if we really want to be scientifically accurate airtime and flight time ate the same thing! End of discussion!

[Freewheel]

Well as soon as those rotors are turning its moving all over the place, vertical and horizontal . A 205 I once flew had so much vertical could have swore it was bouncing off the ground and therefore moving under power and leaving the ground if only for a millisecond and 1 1000 th of a milimeter and therefore " off the ground" for those folks that really want to nit-pick ! So if we really want to be scientifically accurate airtime and flight time ate the same thing! End of discussion!

Actually if you want to nit pick, according to the Cheif of Standards (and Director of standards), each time your 205 bounced into the air, you would be logging air time. When you drop down and make contact with the earth's surface you would not be logging air time(even if it is for a millisecond), yet your flight time would continue to be logged through this time on the ground.

If you're aircraft had a cycle counter with a squatch switch on the landing gear it would log your air time as down each time you made contact with the earth's surface (as stated in the CARs definition.

It sounds to me like your logging unnecessary air time on your company's aircraft and grossly inflating their maintenance costs for no reason. Consult your maintenance manual and ask your Bell rep if they expect you to log this time on the ground towards air time. In Today's competative market, you are giving other companies an competative edge over yours (I hope you work for a company who charges a decent tarriff).

If you are being told to log this way by your TC inspector, then there is a serious issue. This is why we beleive this disparity in enforcement of the regulation has led to a situation whereby individuals and companies are being held to different standard under the law. This is a violation to the Canadian Charter of Rights....every individual has the right to equal representation and protection under the law.

[Petit-Lion]

I would stick to the fact that an aircraft « moves under its own power » as long as the rotors are actually spinning. Safety wise, it does.

[Freewheel]

Mr. Calaiezzi,

 

Has Mr. Speer responded to your concerns which you expressed in your email dated April 16, 2012?  Please advise.

 

Thank you

 

 

Jeff Bond

Issues Officer / Agent, Chargée des questions d’intérêt

Civil Aviation Secretariat / Secrétariat de l’aviation civile (AARCE)

[Freewheel]

Mr Bond,

                No Sir he has not. Although I really did not expect a response. Don’t get me wrong, as a taxpayer and stakeholder I would expect response, but I have been asking for answers for a year and half now and all I get is people talking in circles. They rarely offer helpful information and do everything they can to deflect responsibility. It seems they are making every possible effort to avoid accepting any responsibility in this mess. When they do respond, they rarely meet the timeline standards set out by the CAIRS. Nice Safety Management System…

I am actually surprised to receive this e-mail from yourself. Based on past experience and dealings with Accountable Managers about CAIRS issues, they rarely respond in a timely manner. For that matter, issues are rarely resolved and we feel that we do not receive the respect we deserve as stakeholders. I’m sorry sir, the assistance we have been offered throughout several levels of TC has been appalling. We feel it has come to a point where it becomes more than a level of service issue; but a significant safety issue. Generally when I ask a TC representative for guidance, I feel I deserve answers and official documentation to back up these answers, not an inspectors personal opinion. That is how we got here; had this finding not been made and had I not submitted a CAIRS our inspector would still be telling us to log time illegally.

                I am not sure if you are aware but I also sent Mr. Speer a follow up e-mail on April 17, 2012. With additional information attached , including a secondary finding that was made against our organization in a recent inspection and exerts from our COM. We feel this finding is completely inaccurate and in no way represents the true facts. It actually seems worded in a deceptive manner in a deliberate attempt to hide the true facts. I will forward you this e-mail momentarily.

We want these findings corrected by implementing Corrective Actions that actually address the true root cause. We also want the much larger issue of confusion throughout TC and the Industry rectified.

I hope you are able to provide us with a means of making progress with this issue.

 

Thank You,

 

Chad Calaiezzi

Operations Manager