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Flight Time Vs. Air Time Personal Logbook

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After several e-mail requests about the status of CAIRS IB8718 (over the past few months), I received this today:

 

"Dear Mr. Calaiezzi,

Please find attached the response for CAIRS IB-8718 sent to you from Transport Canada Acting Regional Director Yves Lemieux on August 9th, 2012. This response officially closed the file.

 

We have noted that you have sent additional information via email to Mr. Lemieux and CC'ed the CAIRS division as well as other Transport Canada subject matter experts. Doing so does not re-activate the CAIRS.

 

At this junction the best course of action would be to follow-up directly with Mr. Lemieux on this issue.

 

Regards,

 

 

Jean-François

Program Information Officer - Agent d'information de programme Transport Canada Civil Aviation Communication Centre/ Centre de communication de l'Aviation Civile de Transports Canada Telephone - Téléphone 1-800-305-2059 Facsimile - Télécopieur 613-949-4204 TTY / ATS (613) 990-4500 [email protected]

www.tc.gc.ca Government of Canada - Gouvernement du Canada"

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Dear Jean Francois,

 

Thank you for advising me that the CAIRS is indeed closed. I was not certain whether Mr. Lemieux's response was inded a formal response to the CAIRS. I have never been formally advised by anyone that the CAIRS was formally closed.

 

As you suggest, I will (once again) follow up with Mr. Lemieux and my POI in the near future; as you note in your reply, I have done this once already and Mr. Lemieux refuses to reply. What does a stakeholder do then? Should I file another CAIRS when my POI and Mr. Lemieux don't respond? Do they not have a requirement to respond? If not, where is the accountability in your system?

 

To say that both interpretations are consistent, without further clarification (and refusing to answer my questions), does nothing to resolve the issue for me and further demonstrates that there still is confusion about this issue at TC and industry wide.

 

The 4 questions I posed to Mr. Lemieux are the kind of questions my pilots are asking. They, like myself, wish to simply be compliant; TC's responses have done nothing to help us understand how.

 

Mr. Lemieux's response has only further confused us. We do not see how it is at all possible that both interpretations are consistent (for most flights - which have multiple landings beteewn start and shut down)

 

Answering my questions formally might help me understand Mr. Lemieux's point of view. After all, I think we share the same goal: ensuring that operators and pilots are compliant with the CARs and operate safely. If he is so convinced that the statement currently in my approved COM and the statement that used to be in my COM are consistent, then why not answer the questions?

 

Mr. Lemieux also refused to amend the findings in our PVI based on his belief that our company generally adhered to the statement in our COM, stating that 49 records on 16 pilots had air time equalling flight time... I have demonstrated to you that this statement is false... I guess that's no big deal to you...to me it should raise a bit of a red flag.

 

I find it odd that after almost 2 years of dealing with this issue through the formal CAIRS process, that I am now once again being advised to deal with the region (and ultimately my POI in the Sudbury office) who does not respond to my questions with regards to this issue. He is also the person who made the findings based on what we believe to be a misinterpretation of the CARs Definition. That is why I filed the CAIRS in the first place: to receive a 3rd party interpretation from a higher level at TC.

 

It seems like reporting this through the CAIRS was mostly an ineffective and pointless process:

The director of standards offered an interpretation that was similar to our own, and in my opinion in conflict with my POI's...yet we are right back where we started being told the same thing from the region.

 

Regards,

Chad Calaiezzi

 

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Sent January 3, 2013:

 

Hi Yves,

 

I was advised over the Christmas holidays, that CAIRS IB-8718 had been closed and that your August 9, 2012 letter officially closed the report in the system. I was also advised by the Program Information Officer that At this junction the best course of action would be to follow-up directly with Mr. Lemieux on this issue.

 

As you are aware, I have already followed up directly with you by e-mail on August 13 and August 15, 2012. I asked you to further clarify your belief that the interpretation we received from the Director of Standards and the statement that helicopter Flight time is the same as Air time are consistent. I asked you 4 questions yet I have not received a response. I was hoping that you would respond to these questions and clarify your point of view to me. As it stands, your letter has only confused me. As I told you, I dont see how it is possible that these two interpretations are consistent.

 

I have also, ccd Jacqueline, since she is the person who offered the interpretation with respect to this issue (part of her interpretation was copied and pasted into my COM and later approved). It is her interpretation that we are currently using and you claim is consistent with Helicopter flight Time is the same as air time. I do not see how, but with your lack of response, I was hoping maybe she would take the time to explain it to me.

 

I have been asked by the Accountable Executive at our organization to create a Company Operations Notice explaining the proper way to calculate Air Time and Flight Time (and I dont want to misinform pilots about the correct methods to be used). The reason for this Company Operations Notice is two-fold:

 

1) We want to ensure that our pilots (and operations) are compliant with the regulations. (Many of my pilots are also asking for further clarification because they dont understand how the 2 are consistent).

 

2) We want to ensure that our pilots are not unnecessarily inflating our maintenance and operating costs due to the fact they are not logging Air Time correctly.

 

I have created an example using a 1.2 hour flight between Moosonee Airport (CYMO) and the Lagoon heliport on Moose Factory Island. The distance between the 2 locations is 1.6 Nautical Miles and Flight legs are generally 3 to 4 minutes in duration. Pilots conduct multiple landings and take-offs between start and shutdown. They also remain at the controls with engines running while passengers and/or cargo is loaded into the aircraft. The end result is that they are often on the ground for as long as they are in the air.

 

Below is an example of what we believe a pilots trip log should look like when conducting operations between CYMO and the Lagoon.

 

Start Engine @758

 

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

 

Shut Down @ 912

 

 

Air Time = 4+3+3+3+4+3+3+3+3+5 = 34 minutes = 0.6 hours

 

Note: Pilots Should use the TC approved air time/cycle counter (AKV, Jenkins) on the aircraft if installed. This system should also calculate air time in the same fashion as above.

 

Method 1(Flight Time = Air Time):

 

Flight Time = Air Time, therefore Flight Time = 0.6 hours

 

Method 2 (Flight time is logged as per the interpretation offered by the Director of Standards)

 

Flight Time = 800 to 909 = 69 minutes, therefore Flight Time = 1.2 hours

 

When conducting operations such as shuttling passengers and cargo between Moosonee and Moose Factory island, it is not unusual for Flight Time to be 100% more than Air Time using Method 2. We feel that simply stating the two are consistent without further explanation as to how, is not an acceptable answer. We are asking for a simple explanation so we can advise our pilots (who would also like to know). Method 2 is currently the way our pilots are being advised to calculate flight time (based on our approved COM and the interpretation offered by the director of standards Jacqueline Booth).

 

 

 

1) Can you advise which method is the correct method for calculating the Flight Time for the above example (Method 1 or Method 2)?

 

2) When discussing mathematical calculations such as these, if the results to method 2 may be as much as 100% more than the results using Method 1, how is it possible to state that both methods are consistent?

 

3) Are you suggesting that our pilots should also be logging Air Time through these periods on the ground?

 

 

 

Please find attached a draft Company Operations Notice that I will be releasing to all Expedition Pilots once it is fully reviewed. Please feel free to comment on the validity of the Operations Notice; I would also welcome any input you may wish to offer.

 

As you can see, I am not simply trying to be difficult here; I am trying to deal with real life issues that affect our operations on a daily basis. While Moosonee may be a peculiar situation, this type of work is not uncommon in our day to day operations.

 

A pilot who uses method 2 to calculate his flight limits as per CARs 700.15, could reach his 150 hour/30 day limit, while another pilot using Method 1, flying the same hours would only have logged 75 hours

 

4)How is this consistent?

 

Yours Truly,

 

Chad Calaiezzi

Operations Manager

Expedition Helicopters Inc.

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Received January 4, 2013:

 

Good morning Mr. Calaiezzi,

 

I appreciate your patiance and determination to resolve this long standing issue. I apologize for the confusion my letter dated August 9, 2012 appears to have created. It was not intentional.

 

Note that this response is preliminary as I haven’t had the opportunity to discuss the details of your email below with my staff at the Sudbury TCC.

 

However, at this point, I can assure you that the amendment to your COM based on the information provided by Ms. Booth and approved by your POI is valid. There may be a requirement to specify in the COM how “air time” is to be calculated and recorded in the JLB (manualy or using the “air” time provided by the cycle counter) without the Moosonee scenario details.

 

I can also assure you that the general concept that “air time is the same as flight time” for skids equiped helicopter is out.

 

I will contact you next week for additionl information I need to address the PVI “finding”.

 

Have a good weekend.

 

Yves Lemieux

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Since they cancelled General Aviation Policy Letter 2005-02 dated 2005-09-07, how can Mr. Lemieux state "I can also assure you that the general concept that “air time is the same as flight time” for skids equiped helicopter is out."?

 

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comes into contact with the surface at the next point of landing

Since they cancelled General Aviation Policy Letter 2005-02 dated 2005-09-07, how can Mr. Lemieux state "I can also assure you that the general concept that “air time is the same as flight time” for skids equiped helicopter is out."?

Nowhere in the CARs did it ever say that "Flight Time and Air Time are the same for skid equipped helicopters....", this was a misinterpretatin of the CARs definition for Flight Time and Air Time by many at TC. This statement was placed in the TC COM template that was issued to many operators (and approved by TC as accurate).

 

Just because they cancelled the Policy Letter does not mean we revert back to the old "improper" interpretation.

 

If you look at the definition for flight time and air time:

 

Air Time ends when the aicraft "makes contact with the earth's surface at the next point of landing".

 

Flight Time ends when the aircraft "comes to rest at the end of the flight".

 

The bigger issue here is the confusion that has been demonstrated by TC with regards to this interpretation. In my mind organizational issues within TC has led to the industry wide confusion that clearly exists. Mr. Lemieux himself seems to have completely changed his view on Flight Time and Air Time since his August 9/12 response; yet they claim there is no confusion at TC???

 

Headquarters and the region also advised us that Flight Time and Air Time are the same...Until now,they refuse to acknowldege this as a legitamite issue that stems from within their organization.

 

The fact they closed the CAIRS prematurely demonstrates the true culture that exists at TC.

 

I am still pushing for formal clarification to the industry as a whole. I would like to see another Policy Letter issued and all COM's amended to remove this statement. I wouldn't be surprised once again attempt to minimize this as an isolated incident and sweep it under the carpet

 

 

 

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Sent January 6, 2012:

 

Good Morning Jean-Farncois,

In light of the e-mail received below from Yves Lemieux, it seems you have closed CAIRS IB8718 prematurely. I would suggest that it should be re-activated to include all information and corrective actions that are to be implemented. Also since the report was closed prematurely, it seems your system has failed. Another CAIRS investigation should occur as to why.

As Mr. Lemieux pointed out, this issue is a longstanding one. If you wish to truly correct it, shouldn't a full root cause analysis be conducted and corrective actions be implemented against the root cause?

In light of the fact that TSB believes TC's failure to implement SMS in our sector is a significant safety concern, these type of failed reports might be a good place to start. I suspect much of the difficulties TC has faced implementing SMS stem from cultural issues within your own organization. TC needs to lead by example (to foster a reporting culture), just as any accountable executive does.

This is an industry wide concern and the industry should be advised of the current interpretation of flight time that TC is using. There are still numerous companies with TC approved COM's being used that contain the statement "Flight and Air Time are the same for skid equipped helicopters".

Aside from the obvious safety concerns, this disparity throughout the Canadian industry also has charter of rights implications and it is likely that TC has been interfering with fair competition within our industry.

From a stakeholder who is simply trying to report known "longstanding issues", I have to say this process has been extremely frustrating. If TC is truly serious about implementing SMS, and fostering a "reporting culture" industry wide, cases like these should be used as case studies to determine where your system failed.

While Mr. Lemieux appreciates my patience and determination, I can assure you, while I remain determined, my patience ran out a long time ago. I will await his call next week.


Chad

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The bigger issue here is the confusion that has been demonstrated by TC with regards to this interpretation. In my mind organizational issues within TC has led to the industry wide confusion that clearly exists. Mr. Lemieux himself seems to have completely changed his view on Flight Time and Air Time since his August 9/12 response; yet they claim there is no confusion at TC???

 

Headquarters and the region also advised us that Flight Time and Air Time are the same...Until now,they refuse to acknowldege this as a legitamite issue that stems from within their organization.

 

The fact they closed the CAIRS prematurely demonstrates the true culture that exists at TC.

 

 

 

 

 

I think you hit the nail on the head with the attitude and culture that exists at TC. Seems like if it causes them more work they don't want to deal with the issues. Its mind numbing and extremely frustrating trying to deal with transport or even get in contact with a person who actually knows what they are talking about. Chad I have been following this thread and can't believe the responses that you have been getting from transport this should have been dealt with months ago and I still don't understand how TC has not seen the confusion, but looks like persistence will pay off. It's just ridiculous on how much effort you have had to put in to convince these people there is a problem.......

 

I filled a CAIRS a few months ago after I called 3 different TC offices to figure out how to process a rating I had applied for in less than 90 Days, and after I had already waited about 2 months. I not realising that it now takes almost exactly 90days to process a rating in BC almost cost me about $10,000 while working out of the country delaying a foreign license I needed to apply for. Being overseas and calling all the different offices across Canada it only took 2-3 days to actually talk to someone. I eventually talked to multiple offices and some officers were helpful, but they would not expedite the process of my licence. But multiple licensing officers encouraged me to file a complaint and forward it to them or file a CAIRs. Multiple employees also mentioned that due to budgetary cut backs things were taking a lot longer to process. Seemed like a work to rule situation to me. In the CAIRs I filled I recommended an expedited service to people who need there licence processed quickly like many other countries already have. More people need to file CAIRS in any situation that affects them there lively hood, or business. The standards need to increase and be more transparent with in TC. Here is part of the CAIRS I received in response to my complaint. Went no where but hopefully more people complain and eventually they do implament a expedited service for those in need.

 

"Like all federal departments, Transport Canada is facing budget restraints. Our priorities are unchanged: maintaining the aviation safety regulatory framework and oversight of the aviation system. In developing changes to spending, we tried to ensure that safety activities are not compromised and that the impact on Canadians would be as minimal as possible.

 

To address the budget restraints, the department implemented some administrative changes that may impact service delivery. That said, the service delivery standard of the processing the license rating is 90 business days. This service standard has not been affected by reduction of the budget. Transport Canada has considered your suggestion for an expedited processing program and is not pursuing it at this time, as this would involve legislative changes that takes time to process.

 

I would like to take this opportunity to thank you for sharing your views, as all comments we receive are appreciated.

Should you require any further information or if you have any other questions, please feel free to contact us via e-mail at [email protected].

 

Sincerely,"

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