Flight Time Vs. Air Time Personal Logbook

[Freewheel]

Good afternoon Mr. Calaiezzi,

 

I have been asked to handle your file.

 

To begin, I would like to apologize for your experience with the CAIRS process and the lack of a timely response. The CAIRS team strives to respond to submitters within the service standard timeline however in some circumstances this is not always possible.

 

Please let me assure that your file remains open. I would like to acknowledge that your concerns are valid and substantiated.  I am currently coordinating with various branches and the region to address the misconceptions experienced. With that said, it will take some time to complete a thorough review and establish a way forward to ensure consistent communication when interpreting regulations and therefore we cannot provide a timeline for response.

 

Should you have any questions or concerns, please feel free to contact me directly at melanie.nash@tc.gc.ca or by phone at 613-990-1784.

 

Melanie Nash

613.990.1784

melanie.nash@tc.gc.ca

[HeliRico]

Good afternoon Mr. Calaiezzi,

 

I have been asked to handle your file.

 

To begin, I would like to apologize for your experience with the CAIRS process and the lack of a timely response. The CAIRS team strives to respond to submitters within the service standard timeline however in some circumstances this is not always possible.

 

Please let me assure that your file remains open. I would like to acknowledge that your concerns are valid and substantiated.  I am currently coordinating with various branches and the region to address the misconceptions experienced. With that said, it will take some time to complete a thorough review and establish a way forward to ensure consistent communication when interpreting regulations and therefore we cannot provide a timeline for response.

 

Should you have any questions or concerns, please feel free to contact me directly at melanie.nash@tc.gc.ca or by phone at 613-990-1784.

 

Melanie Nash

613.990.1784

melanie.nash@tc.gc.ca

 

 

Wow...Melanie Rocks!!

[twinstar_ca]

Melanie just spoke political double-speak... :down:

[Freewheel]

Melanie just spoke political double-speak... :down:

You hit the nail on the head this time....the "political double-speak" throughout Melanie's organization is likely a big part of why these issues rarely get dealt with in a timely fashion...or ever at all...

 

When you point out that you are not fooled by their "double-speak", they just stop responding. If you continue to press, your issue gets handed over to someone new.

 

This, infortunately, reveals other larger internal issues than the "Flight Time/Air Time issue"

[Freewheel]

Good Morning Ms. Nash,

Thank you for informing me that the file is still open. Also, thank you for acknowledging that my concerns are “valid and substantiated”. I understand it will take some time to complete a thorough review and establish a way forward to ensure consistent communication when interpreting regulations, but I am not sure why you are unable to provide a timeline. In my mind this points to further organizational issues.

I realize that Transport Canada is a large organization, however I am sure you are aware, an effective SMS should be tailored to meet the size and scope of the organization and includes the requirement for “milestones” or “proposed completion dates” when actioning reports and creating Corrective Action Plans.

Forgive me if I am skeptical that you will correct this issue in a timely manner; as you are aware, TC has been aware of this problem for many years, yet you have failed (or chosen not) to correct the issue. GAPL 2005-02 acknowledges that TC was aware of this issue seven years ago… I will continue to contact you regularly for updates.

In the meantime, should we expect to see an amendment to the PVI report and findings that we received? We would like the true root cause to be included in this corrective action plan. You seem to be acknowledging that these findings were made as a result of confusion and organizational issues within Transport Canada. We would like the PVI report to reflect the facts. While you continue to delay dealing with the issue, our organization continues to be affected by these inaccurate findings. The current wording insinuates we cut corners on our training, and falsified training records. We view, this as a black mark on our record and the findings have a negative impact on our ability to score well on audits from some of our more high profile clients. In short TC is affecting our ability to do business; is this the role of government?

 

Regards,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

[412driver]

If it's "turning and burning "....your earning!

[Freewheel]

Hi Melanie,

It has been 20 days since I received your most recent e-mail with regards to CAIRS IB 8718. As I mentioned to you in my response, I will continue to request updates with regards to the progress you have made with regards to the issue and widespread misconceptions at Transport Canada (with regards to the interpretation of Flight Time for skid equipped helicopters).

 

1) Are you able to provide any update whatsoever?

 

You mentioned in your email that my concerns were valid and substantiated, yet stated you were not able to provide a timeline for response. I would expect that within a twenty day timeframe, you should have been able to create a short term corrective action with regards to this issue. I understand that coordinating a long term corrective action with the various branches and regions could take some time, however I see no reason why short term corrective actions are not being implemented. I would suggest that the removal (or amendment) of the inaccurate PVI findings should be included in this short term corrective action plan. I see no reason why correcting this error could not be completed today (since you have acknowledged that we experienced misconceptions from various levels of TC which led to these findings).

 

2) Are you able explain to me why you are not able to correct this error at this time?

 

Considering, the various cultural issues at TC, and systematic deficiencies that were identified in CAIRS system while actioning this report, I would suggest that such a gesture would reinforce TC’s message that they strive to promote a reporting culture throughout the industry. As it stands, you’re handling of this issue challenges TC’s National objectives of implementing SMS throughout our industry. Too most stakeholders who are following this issue, this is just another example of what they should expect when reporting issues to TC. Why would anyone wish to report such issues when they see the effort (and hoops that I have had to jump through) to receive an acknowledgement that their concerns are “valid and substantiated”. Despite, the rhetoric coming from Transport Canada about SMS implementation, and a “new proactive way of thinking”, most of us feel that nothing has changed at TC. This is likely why no organization has pushed for clarification on this issue in the past, had we not raised the issue and persevered as we did, this issue would have never been acknowledged by anyone at TC…for this reason we shall continue to push (and hope that one day other operators will follow our lead).

 

As you are likely aware, I have been posting all of our correspondence on Vertical Forum in an effort to raise awareness through our industry with regards to this issue. I will continue to do so as we move forward with all possible redress mechanisms to rectify this issue (including other forms of media). We are strong believers that the internet can be used to effect positive change like no other tool we have seen in the past. Unfortunately, this will only solidify the beliefs of many that TC is paying “lip service” to SMS and that they will likely never succeed in implementing it in our industry. I have had several TC inspectors tell me exactly that, which raises serious concerns about the organizational culture. This is unfortunate, as we view SMS as a very useful tool which could be an enhanced layer of safety in our industry (along with effective oversight). We have always done everything TC has asked of us (including implementing a fully functional SMS); it’s worth noting, we are one of the few operators (of our size and scope) who have actually received designation as “transitioning to SMS”. I can assure you that if employees reporting concerns at our organization received such resistance, reports would rarely be received and we would be missing out on many opportunities to improve our organization and level of safety. Correcting this PVI report, might also be seen as an effective message to those inspectors at TC who are disbelievers that TC is truly moving forward towards full SMS implementation (and making an effort to implement a reporting culture).

 

Link to Vertical Forum:

 

http://verticalmag.com/forums/can/index.php?/topic/19518-flight-time-vs-air-time-personal-logbook/

 

Thank You,

 

Chad Calaiezzi

Operations Manager

[Grasshopper]

Quoting 'Caldy'

 

"If you were toed in then yes this would be flight time in line with the definitions. The air craft is touching the surface so it is no longer air time. The helicopter has not come to rest. If you were to turn the engine off the aircraft would disastrously come to its own "rest."

 

Hold on a minute! If a F/W 'taildragger' doing circuits does a 'touch & go' without putting its tailwheel down, surely it continues doing 'air time' just as the R/W toed-in continues doing 'air time' because the aircraft is not being entirely supported by a landing surface in either case.

 

And 'Freewheel,' keep up the good fight!

[Freewheel]

Quoting 'Caldy'

 

"If you were toed in then yes this would be flight time in line with the definitions. The air craft is touching the surface so it is no longer air time. The helicopter has not come to rest. If you were to turn the engine off the aircraft would disastrously come to its own "rest."

 

Hold on a minute! If a F/W 'taildragger' doing circuits does a 'touch & go' without putting its tailwheel down, surely it continues doing 'air time' just as the R/W toed-in continues doing 'air time' because the aircraft is not being entirely supported by a landing surface in either case.

 

And 'Freewheel,' keep up the good fight!

 

I have no intention of giving up on this one. It's unfortunate that TC chooses not to accept responsibility and do the "right thing". Where I come from, if you acknowledge you have errored, you do what is needed to make it right with those who you have affected negatively. It's called "ethics". I understand this may take some time to create a long term corrective action to prevent reccurrence, but there is no reason for a law abiding operator to continue to be penalized for their defficiencies. By allowing the incorrect findings to remain on our inspection report, they are doing just this. We were also forced to implement corrective actions that did not address the Root Cause, and in turn, cost our organization a great deal of money. Again, this issue has revealed much larger issues at TC.

 

Despite the fact they chose not to give timelines, we have created our own. If we do not see these findings removed or amended in the near future, I will hand this issue over to my lawyer. I have no doubt he will be very effective, as we have used him more than one civil litigation suit with great success. At that point, we'll be looking for a lot more than just an amendment to the PVI report.

 

Considering they have admitted that we encountered misconceptions at TC that led to these findings, I'm quite sure he will be successful once again. By admitting this, they have also admitted that there may be breaches to Canadian Charter of Rights, which guarantees equal representation under the law of all canadian citizens.

 

While I'd prefer not to feed lawyers over such a basic issue; at this point we believe we are are being penalized for TC's inadequacies. Worth noting, our lawyer is one of the best trial lawyers in Canada; he loves the spot light and hates to settle...just ask LLOYDS of LONDON. I've also been discussing TC's failure to deal with this issue with various media outlets in hopes of bringing these institutional issues to the attention of the public. These internal issues are a safety issue that concern the paying customers who are passengers on our aircraft everyday.

[dimit]

Freewheel,

 

I know you've given this issue and your response to it a tremendous amount of thought, and have sought credible legal advise. I admire your focus and determination! My (totally uninformed) concern is that your use of media leads TC to take a more punitive approach. I hope not!!!

 

Best of luck,

 

DM