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OGEgirl

Flight Time Vs. Air Time Personal Logbook

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If anyone's interested, we received a letter August 9/12 from Associate Director of Operations denying our request for amendment to the PVI findings (that we dispute); it's attached. The author claims that "The PVI was conducted against your COM amendment No.9 dated June 1,2009. Article 4.18 stated that helicopter flight time is the same as air time. This is consistent with the interpretation provided by Arlo Speer.”

 

It seems we've come full circle and I am right back where I started (Mr. Speers previous e-mails are posted on this forum).

 

Am I missing something here? Does anyone understand how the statement "flight time is the same as air time" is in any way consistent with: "Within your scenario, “flight time” might continue 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 at this time and where there is no intent to shut down the helicopter, then the flight time should continue to be logged." The above clarification was offered by director of standards J. Booth and Mr. Speers stated in his e-mail that: " 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”.

 

I welcome any insight which might offer an explanation that might help me understand how these statements are consistent. I have requested clarification from the author of the letter, but i am not confident that I will receive a response.

PVI Review letter Ylemieux aug 9-12.pdf

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Our Reply to Aug 9/12 Letter:

 

Hi ,

I received the letter that you mailed August 9, 2012 today. I have reviewed it and notice that you have no intention of altering the findings. We do have issue with this; and we will continue to proceed with other redress mechanisms. Thank you taking the time reviewing the issue.

 

Unfortunately, your letter has done nothing but confuse us further. Can please answer a few questions in hopes of clarifying this issue.

 

Paragraph 2 of your letter states:

“The PVI was conducted against your COM amendment No.9 dated June 1,2009. Article 4.18 stated that helicopter flight time is the same as air time. This is consistent with the interpretation provided by Arlo Speer.”

 

I hope you can clarify this for us, because we do not believe that it is consistent with Mr. Speers Interpretation.

 

While Mr. Speer provided some guidance through exerts from the CAIRS report (and the official response) in an e-mail, he stated Ms. Booth is the “accountable manager” for the Civil Aviation Issues Reporting System (CAIRS) file number IB-8718. Ms. Booth’s September 20, 2011 response to CAIRS 8718 is the official response from the “accountable manager”.

 

Ms.Booth’s response stated in part: “…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. Within your scenario, “flight time” might continue 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 at this time and where there is no intent to shut down the helicopter, then the flight time should continue to be logged. (Mr. Speer also pasted the first portion of this statement in his e-mail to me).

 

1)Considering Ms. Booths statement in bold (above), can you please explain to me how a statement that claims “Flight Time is the same as Air Time” is consistent with the interpretation provided by Mr. Speer (and Ms.Booth)?

 

I really don’t see how. I will acknowledge that it is indeed possible for some flights to have Flight Time equal Air Time (i.e. flights with no landings until shut down), but this is not the case for most flights. Many training flights have several landings in between whereby the pilot remains at control of the aircraft with intent of shutting down (so do most commercial helicopter flights). This tells me that the statement in our COM was in no way consistent with Mr. Speer’s interpretation. I cannot understand how both interpretations can be considered consistent; it’s either one or the other.

 

2) Are you now telling me that it is Transport Canada’s current position (interpretation) that Flight Time is indeed the same as Air Time for skid equipped helicopters?

 

I would also like to clarify to you that your statement at the end of paragraph 3 is false. You state that “An internal review you conducted confirmed that your company in general adhered to 4.1.8 (ie 49 records on 16 pilots have air time equalling flight time); however the review uncovered 5 flights that had flight time different than air time. Accordingly the finding stands as written and will not be altered.”

 

This statement is completely false. The corrective action plan that we submitted to the finding stated: “Fifty four Recurrent flight training records and PCC records were reviewed for an additional 16 pilots. In most cases, Flight Time was used on the forms and matched the “Flight Time” column in the Journey Logbook. In all cases the “flight time” on Recurrent training forms was a minimum of 1.0 hours; in all but 5 cases the air time was also a minimum of 1.0 hours.” I think this statement is pretty clear, but I can assure you sir, that in most of these 54 cases, flight Time did not equal Air Time in the Journey Log. Most flights at Expedition show a difference between Flight Time and Air Time in the JLB. The fact that these flights were usually over 1.0 hours air time, is simply testament to the fact that we generally do a great deal more than the minimum requirement. The fact that you seem to be misrepresenting the facts concerns me. I have to wonder if you responded without reviewing the facts in entirety, or you are making a conscious effort to minimize what happened here.

 

3) Where did you get the information that in most cases our training flights records had “air time equalling flight time”?

 

Can you please respond to my questions as soon as possible, because it seems we are more confused than ever and we would like to ensure we are moving forward using the appropriate interpretation of the regulation. Currently my COM has a similar statement to Ms. Booth’s in it that states “if the intent is to not terminate the flight at this time and where there is no intent to shut down the helicopter, then the flight time should continue to be logged.” I will submit an amendment to the COM if you are advising that this does not represent TC’s current position/interpretation. Also I will advise my pilots to commence using Air Time when calculating “Flight Time Limits as per the CARs”. See attached Company Operations Notice that we were prepared to release to our pilots last year (prior to receiving Ms. Booth’s clarification). While, as a pilot, I disagree that air time should be logged, as a member of Expedition Management, I can certainly see benefits of using the interpretation that “Flight Time and air time are the same”. This will certainly mean that pilots will reach flight limits (as per CARs) very infrequently and we will likely be able to lay off several pilots (reducing payroll, training costs etc.), as well as save on crew change costs. These are likely the reasons that some operators argue that “Flight Time is the same as Air Time; unfortunately it seems to be profit driven with little regard for pilot fatigue and aviation safety.

 

As always, all we are asking for is a clear response so we can move forward in full compliance with the CARs. We would also like to see some accountability. With regards to the findings not being altered, I hope you reconsider as it seems you may not be fully informed of all the facts. Regardless of whether we were right or wrong, on how to log Flight Time, we will always maintain that the true root cause of these findings was that there was (and still is) industry wide confusion that is a result of issues within TC’s organization. These root causes should be included in the PVI report. Not only is it the only way to truly prevent recurrence, it would also go a long way towards fostering a “healthy working relationship between government and industry” and “stimulating healthy discussions” as you so eloquently stated in your closing comments.

 

 

Yours Truly,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

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Hi Yves,

I have one more question that should have been included with the questions in my original e-mail to you (Aug 13). It is with regards to your statement that “…Article 4.18 stated that helicopter flight time is the same as air time. This is consistent with the interpretation provided by Arlo Speer.

 

4) Are you implying that when a helicopter that has several landings between shut down and take-off (in which the intent is to not terminate the flight at this time and where there is no intent to shut down the helicopter) that “Air Time” should continue to be logged as well as flight time (as was explained by director of standards)?

 

If so, I would suggest that very few operators are operating in this fashion. If there are operators that are being told to operate this way (by TC), while others are not then we have a charter of rights issue, don’t we? As you are aware, we were not allowed to amend our COM to remove the statement, while others had already removed it. We were told by our POI that if we wish to further challenge the COM statement that we should file a CAIRS (which we did).

 

Many machines are equipped with TC approved cycle counters that calculate Air Time as time spent in the air only. To my knowledge none of the manufacturers require that air time be calculated while on the ground with engines running/blades turning. If a commercial operator were to adopt this practice they would see a grossly inflated maintenance/operating costs .

 

I apologize if I seem like I am trying to be difficult, but I am really trying to understand how flight time can be the same as air time (if in many cases Flight Time should continue to be logged while on the ground with engine running). While you state this interpretation is consistent with the interpretation provided by Arlo, I can’t see how (unless we start logging air time in cases whereby we are running on the ground). Somehow I don’t think that is the intent of the regulation, but I could be wrong.

 

 

 

Thank You,

 

Chad Calaiezzi

Operations Manager

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I don't think there is such a thing as 100 hr (air time) commercial corse? I know when I did mine 16 years ago it was 100.00 hrs and it was defiantly not skids up skids down, there was lots of time on he ground between autos or whatever exercise just briefing. I would hazard a guess that I actually only did 85-90 hrs.

Should be lots of instructors on here that can fill us in on how it is being done now a days??

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Coast Helicopter College on Vancouver Island was in '06 when I went through.

Does anyone know of a Flight Training Unit that offers a course for a commercial licenc where the pilot receives 100 hrs Air Time?

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Does anyone know of a Flight Training Unit that offers a course for a commercial licenc where the pilot receives 100 hrs Air Time?

 

When I had gone to Great Slaves school in Villeneuve I remember the instructor stopping the clock whenever we landed. I figure that's close enough to air time.

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Coast Helicopter College on Vancouver Island was in '06 when I went through.

 

Thanks Coastal. Good Info.

 

I checked Coastal Heli College's website, and sure enough under FAQ's it states: Why should I train at CHC?....In addition CHC charges for air time only, resulting in approximately 10 more hrs of actual flight time, compared to most other training facilities.

 

While they only bill air time, they acknowledge there is a difference between flight time and air time. They go further yet, and state that this not the industry standard at most training facilities (where "flight time" is used); by their estimates flight time and air time differ by approximately 10 percent on training flights. I would suggest that even these estimates are conservative.

 

So why would there be a different standard for pilots completing commercial recurrent training after receiving their licences (or any other commercial flights for that matter)? Some jobs I have been on would have a difference of 50% between air time and flight time (if we apply the same standard or use Jacqueline Booth's interpretation that was offerd in the Official CAIRS response).

 

I am curious Coastal, how do you log time in your personal logs and when calculating flight times towards CARs Flight limits? Do you use air time (skids up/skids dn) or Flight Time (from the moment you lift off until the moment you touch down for the purpose of shutting down)?

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Does anyone know of a Flight Training Unit that offers a course for a commercial licenc where the pilot receives 100 hrs Air Time?

 

Premier Helicopters out of Pitt Meadows (when they were operating) did 100h of Airtime. Clock started just before lifting the collective.

 

I wonder if TC has to void licenses if they keep going the way they're going as lots of commercial pilots will not have 'valid' licenses?

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