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Flight Time Vs. Air Time Personal Logbook


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Thanks Freewheel/Chad for running with this, it's very important to us as an industry whether we are owners or employees.

 

____________, work to rule, you probably nailed it! I could regale you with a horror story i experienced with TC and the lack of communication between departments and how i almost had to surrender my license due to what amounted to nothing short of a TC employee doing a sloppy job or not giving a "dam".

 

A big thank you to the lady at TC in Edmonton who transferred my file out of Vancouver and sorted everything out in a few MINUTES, (i left a message and she called right back!) there are some good ones left! Like in any organization, there are good employees and bad ones, too bad some of the bad ones hold our livelihoods in their hands and the lengths you have to go to get service or justice...

 

W.

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Good afternoon Mr. Calaiezzi.

With regards to the email below and your desire to provide your pilots with correct information as soon as possible, without going into the details of the various scenarios or observations you have included, the following answers are provided to the 3 questions you included:

 

  1. Method 2 is consistent with the interpretation of “Flight Time” for flights where a number of landings are carried out between the first take-off and the last landing at the end of the flight, and the engine is shutdown. “Air Time” is either recorded automatically by a cycle counter or calculated by the pilot by recording the time spend on the ground.
  2. Both methods are not the same and obviously not consistent. Method 1 is valid only for a flight where there is one take-off and there is no landing between this take-off and the single landing at the end of the flight, and the engine is shut down.
  3. Pilots can’t log air time while the helicopter is resting on the ground.

 

With regards to questions related to my August 9, 2012 letter, I believe these would be addressed more efficiently over the phone.

 

May I call your office next Wednesday afternoon (Jan 16) to clarify and hopefully put to rest the “operational” aspect of this long running saga.

If Wednesday afternoon is acceptable to you, at what time should I call?

 

Yves Lemieux

Associate Director Operations-East

Transport Canada Civil Aviation

Ontario Region

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Good afternoon Mr. Calaiezzi.

With regards to the email below and your desire to provide your pilots with correct information as soon as possible, without going into the details of the various scenarios or observations you have included, the following answers are provided to the 3 questions you included:

 

  1. Method 2 is consistent with the interpretation of “Flight Time” for flights where a number of landings are carried out between the first take-off and the last landing at the end of the flight, and the engine is shutdown. “Air Time” is either recorded automatically by a cycle counter or calculated by the pilot by recording the time spend on the ground.
  2. Both methods are not the same and obviously not consistent. Method 1 is valid only for a flight where there is one take-off and there is no landing between this take-off and the single landing at the end of the flight, and the engine is shut down.
  3. Pilots can’t log air time while the helicopter is resting on the ground.

 

With regards to questions related to my August 9, 2012 letter, I believe these would be addressed more efficiently over the phone.

 

May I call your office next Wednesday afternoon (Jan 16) to clarify and hopefully put to rest the “operational” aspect of this long running saga.

If Wednesday afternoon is acceptable to you, at what time should I call?

 

Yves Lemieux

Associate Director Operations-East

Transport Canada Civil Aviation

Ontario Region

 

 

Pilots can’t log air time while the helicopter is resting on the ground.

 

Pilots never log air time, as we all know it...There is no column in my log for air time, neither flight time.

 

In fact there a reference to the AIMTP14371/air4.1 and at some point it saids flight time should be recorded in all pilot logbooks.

 

I'm not shure what to thing of this last comment.

Chad can you light me up here ?? What is he sayin ?

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Hi Yves,

I will be in the office all of next week, except for a short period Monday and Tuesday afternoon (as I have an ECG booked for Monday and Medical on Tuesday); you can call me any time. I don’t see an issue with Wednesday afternoon; I can’t say for sure what would be a good time…that depends on what comes up. Feel free to give me a call and ask the receptionist to transfer you to me anytime next week. If or some reason, I am not available, please leave a message and I will return your call at my earliest convenience.

 

I appreciate your belief that these issues may be more efficiently handled over the phone and look forward to talking to you. I should tell you however, that I will want any official conversations/clarifications conducted formally in writing so I can be sure that I have your response documented (if these issues arise again in the future). I hope you understand, we feel that if we have any fault in the findings, it is that we did not push for formal written clarification in years passed when we discussed this issue with numerous Transport Canada Inspectors. For this reason, I will likely follow up with an e-mail that will include a summary of our conversation, as well as any questions I may have. I would appreciate if you would respond acknowledging my summary and answering my questions (in writing). In an effort to reduce the likelihood of another misunderstanding like this, we have decided that moving forward, all communications with TC about regulatory matters shall be conducted in writing.

 

Here are a couple of questions that I have at this time:

 

  1. Do you acknowledge that TC and industry wide confusion exists around the interpretation of Flight Time as per the CARs definition?
  2. Will the findings be removed from the PVI Report?

Considering these are all flights with multiple landings and by your own admission “Method 2 is consistent with the interpretation that “Flight Time” for flights where a number of landings are carried out between the first take-off and the last landing at the end of the flight”. This is exactly the method used by the training pilot; therefore Air Time should not be the same. The Inspector made the finding based on the fact that they should be the same. All flights had flight time over 1.0 hours Flight Time (as required by our COM for Recurrent Training) and the forms matched the Flight Time Column in the Journey Log.

3. If Not, will the findings be amended in any way? To include the true root cause, that industry wide and TC wide confusion exists about this issue. Transport Canada played a significant role in this confusion (in our opinion) and the root cause lies within TC’s organization.

 

4. How will TC rectify this confusion within TC and throughout the industry? (Policy letter to industry stakeholders, other TC Guidance material etc.)

 

5. Is the CAIRS being re-activated to ensure that a root cause analysis is conducted to determine the root cause of this confusion and corrective actions implemented against the root cause (to prevent recurrence)? Considering your August 9 letter was the official closing letter, and you have since provided me with further correspondence that contradicts the closing letter, it should be reactivated.

 

6. What is TC doing prevent future recurrence of incidents of this nature?

 

7. What is TC doing to prevent disparity in enforcement from region to region? Can you confidently tell me that an operator who asks for clarification about Flight Time definition in Calgary, Alberta will receive the same “co-ordinated” response as I would asking the Sudbury Office the same question?

 

While I agree one hundred percent with you that this has been a “long running saga”, I have to say we don’t believe we played any part in this being dragged on for so long. I have merely asked for a simple clarification and for two years I have received a variety of differing responses from multiple individuals at TC (including yourself in your past two letters) about flight time. It’s unfortunate that TC was not able to recognize this as a legitimate issue the first time I contacted my POI, as you are aware this was far from the case. Ultimately I was able to get him to ask Headquarters for clarification who also informed us that Flight Time and Air Time are the same (in all situations).This alone demonstrates the confusion I am discussing.

While I, like you, would like to put an end to this long standing issue, if we are not able to confidently answer these questions, then I fear we are destined to repeat the same errors in our industry. I will continue to seek further rectification (and answers to my questions) using other redress mechanisms and I can assure you the saga will continue. I hope you can appreciate that I have a responsibility not to close a report in my SMS until I feel adequate corrective actions have been implemented to prevent recurrence.

 

 

Have a good weekend and I look forward to your call next week,

 

Chad Calaiezzi

Operations Manager

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Good for you Freewheel/Chad that you are pressing TC for an answer and haven't given up. I was going to caution you against conducting business with TC over the phone (not having anything in writing) but you were way ahead of me! Keep up the good work and know that you have some fans out there who are cheering for you.


I would like to say it's unbelievable that it has taken so long to get to this point, but the truth is it's not that surprising.


I do wonder if the "findings" or what ever the result of all this will be called will be "transferable" to other TC regions? If it is resolved, will it become "policy"?

 

When it does come to an end and there is a resolution, will there be a "plain English" (and French) version available for the unwashed masses?


W.

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Chad next time you talk to TC you should ask them what is the differnce between flight schools charging flight time and logging flight time as personal experience, then writing a .2 (minimum) less in the journey log. meanwhile over the past XX-years transport has been approving CPL lisences to this standard. Is there a difference between reccurent training through operators and flight schools for logging of flight time?

 

Here is an old magazine article on the Flight Time topic. I am still amazed with all the information in front of TC they won't admit to any confusion.

http://www.bluetoad.com/publication/index.php?i=59508&m=&l=&p=7&pre=&ver=swf

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While I appreciate the the words of support, that was not my intention when posting on this forum. The simple truth, is that I recognized this was likely the best place to reach a broad spectrum of pilots from accross the country; my intention was to determine how widespread the confusion about this issue really was. I have always recognized this was an issue in our industry, but until we received findings as a result of this confusion, I (like the rest of you) did not have the time or patience to deal with the issue.

 

I appreciate, all the imput I have recived from posters on this site. Thanks everyone. Espescially, those who don't see eye to eye with me on my interpretation (as you have likely proved my point more than anyone).

 

OGEgirl also deserves credit, as she is the one who first recognized that GAPL 2005-02 had been cancelled and expressed that she was confused on how she should log flight time. While I have no idea who she is, she made my point better than I could have imagined.The fact of the matter is, when i received word that TC had cancelled GAPL 2005-02 in 2011, I was sure someone would bring this up in the forum (so i waited). I have to admit, I chuckled a little when I saw her post; it was perfect (along with most of the posts that followed).

 

After my telephone conversation with Mr. Lemieux this week, he asked that I forward him some evidence that this confusion existed. Here is my response:

 

Hi Yves,

Here is the link to vertical forums main page for General Helicopter Operations - Canada:

http://forums.verticalmag.com/index.php?showforum=28

I have sent you the link to the main page which lists all the forums (along with stats for number of views and replies/comments). The forum that discusses the issue we are discussing is called: "Flight Time vs. Air Time Personal logbook".

If you click on this link you’ll see 18 pages of comments from pilots across the country (about how they interpret the definition of Flight Time). As discussed, I have no idea who the pilot is who started this forum, but it was started a few weeks after GAPL2005-02 was officially cancelled.

I will follow up with another e-mail with other industry sources attached (that also demonstrate this confusion).

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