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OGEgirl

Flight Time Vs. Air Time Personal Logbook

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E-mail sent Jan 17/13:

Hi Yves,

I've attached some additional documents from industry sources that demonstrate the confusion about logging time in our industry. I will send you additional evidence in the next few days.

 

http://www.helicoptersmagazine.com/content/view/2296/38/

 

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

 

http://www.helicoptersmagazine.com/index.php?option=com_content&task=view&id=3522&Itemid=145

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Received Jan 17/13:

 

Thank you for all the additional information. There is obviously enough information to support the need for correct actions.

 

Yves

 

 

Received Today:

 

Good afternoon

Please accept my apologies for not responding to your comments regarding my letter dated August 9, 2012. There is some validity to your comments and they also serve as an indication that clarifications is warranted.

 

First issue - I agree with you that the reference to the content of your COM at the time of the PVI is NOT consistent with the interpretation provided by Arlo Speer (and Ms. Booth). The statement "This is consistent with the interpretation provided by Arlo Speer" related to a draft paragraph detailing the current Article 4.18 of your COM. That paragraph was deleted in the final version of the letter. This slippage was the result of questionable proofreading on my part.

 

Second Issue - During my review of the CAP for finding FO-08-01, I assumed that your pilots were following company procedures as defined in COM 4.18 in force at the time of the PVI with regards to the recording of flight time and air time. A review of the PVI report and a number of emails between yourself and TC staff at the Sudbury TCC did not offer any hint that Expedition pilots were not logging the flight and air times as the same. Your insistence that the ..flight time and air time are the same should be removed from your COM because of all the problems it created within your company and the industry across Canada reinforced my belief that you were in fact logging the times as the same. I viewed the 5 "non-compliant" records your review of some 55 training records uncovered as "exceptions" to the general practice. Hence my conclusion that the vast majority of your pilots complied with 4.18.

In summary, with regards to the 4 questions you posed in relation to my August 9, 2012 letter, the following is provided for the record:

  • 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)?

Answer

: I believe the information in the First Issue paragraph above explains the error.

 

  • 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?

Answer

: No. The times will be the same only when, following take-off, the helicopter proceeds to its destination and carries out its first landing at the end of the flight.

 

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

Answer

: I believe the details provided in Second Issue paragraph explains how I reached this conclusion.

 

  • 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)?

Answer

: I fully agree with the clarification provided by the Director of Standards in her email of September 20, 2011. Your COM Article 4.18 currently reflects this interpretation.

 

Lastly, I will validate PVI Finding FO-08-01. The records you provided me last week will assist me get to the bottom of this issue. The findings refers to "air time" as recorded in the JLB. Article 8.6.8 of the COM in force at the time of the PVI refers to a minimum requirement of "1.0 hour flight time" for recurrent training. I will clarify with our Sudbury staff.

 

I trust that the above clarification for the record and the discussion we had last Thursday have addressed some of the concerns. However, there remains a significant amount of work to "clean up" the issue of flight vs air times recording/logging for helicopter operations across Canada and within TC.

 

Sincerely

Yves Lemieux

Associate Director Operations – East

Transport Canada Civil Aviation

Ontario Region

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Good afternoon Mr. Todd and Chad Calaiezzi,

 

I appreciate very much the discussion we had January 17th, 2013. I believe this initiative has set us on the road for a solution to a nationwide issue within the helicopter world regarding the logging of Flight Time versus Air Time.

 

We agreed that the definitions in the CARs for Air Time and Flight Time are accurate and workable.

 

In accordance with the interpretation provided by the Director of Standards, we agreed that for flights where a helicopter carries out a number of landings and take-offs during the conduct of operations, the air time “recording/logging” stops while the helicopter is resting on the ground. However, the flight time “recording/logging” shall continue with the pilot at the control while the helicopter is resting on the ground. Air and Flight times recording/logging stop with the last landing and shutdown “at the end of the flight”. In such cases, air time will obviously be shorter than flight time.

 

We agreed that the statement “Flight time and Air time are the same for skid equipped helicopter, accordingly the recorded time shall be the same.” included in the generic COM provided by TC to helicopter operators in the late 90s is responsible for the confusion and inconsistencies among helicopter pilots and operators and Transport Canada Inspectors. We agreed that this statement must be removed from every helicopter operators’ COM.

 

As a result of our discussion, I committed to lead an initiative to clear for the industry and TC inspectors the confusion that currently exist with regards to the logging of air time and flight time for helicopters. I will consult with Directors in the other Regions and HQ to determine how this can best be accomplished.

 

Yves Lemieux

Associate Director Operations-East

Transport Canada Civil Aviation

Ontario Region

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Good work

Thanks.

 

Now I just need to get them to "address" the findings (that were made as a result of the confusion Mr. Lemieux is discussing) against our organization. Despite commiting to this over the phone and in e-mails, Mr. Lemieux makes no mention of this in his e-mails. I replied to the e-mail above immediately, yet he has not responded yet. In the meantime our organization is penalized for TC's internal issues.

 

I am scheduled to have an audit with a large international mining client (with a large scope of work) in the weeks to come. We regularly are required to provide our Inspection/Audit findings to prospective clients in the bidding/approval process. If TC does not remove the findings and I am provided evidence (through the this audit report or from any customer) that these findings result in lost revenue to our company, we will have no choice but go after TC for the lost revenue and punitive damages. I have already discussed this option with our legal advisors and they are interested in Civil Litigation if this occurrs. It's really too bad if we've reached a point that a law abiding operator is required to sue TC to rectify an incorrect finding like this.

 

Also, this dealing with this issue has identified much larger issues at TC such as their complete disconnect with our industry and unwillingness to work with stakeholders when issues are identified. The published "service window" for a regulatory interpretation is "immediately by phone or e-mail" through headquarters. It took me 2 years to get the proper co-ordinated response that should have been offered in January 2011. Baby steps I guess.

 

Jacqueline booth is also the Co-chair of the working group for Flight Duty Time limits, yet she is using inaccurate baseline information about Commercial Helicopter flights (and how pilots log) to draw conclusions and introduce sweeping changes to the regs. If she doesn't understand what most commercial heli op's entail, how can she come to conclusions about the effect these changes will have.

 

I received the above e-mail on January 24/13 and responded 3 hours later. I am still waiting for a response.

 

e-mail sent Jan 24/13

 

Good evening Mr. Lemieux,

Thank you for the prompt response. I am glad we agree that there is confusion and that corrective actions are warranted. I also appreciate the opportunity to have a candid discussion with you the other day.

I apologize if some of my e-mails came across as rude and condescending, but I have to say that I was trying to be candid and as direct as possible. I have nothing but respect for each of the individuals I dealt with on this issue; as I stated, I believe this to be a larger organizational issue and wide scale corrective actions are required. In all reality, this finding and CAIRS should be considered positive; it has identified opportunity to correct a longstanding issue. My POI likely deserves pat on the back for identifying the issue through his finding; I believe it is unfortunate that when I (the stakeholder) came forward with a larger issue identified through root cause analysis, no one wanted to believe it could be true.

I hope you understand that after 2 years of not being listened to, I was getting a little frustrated. The multitude of people that I had to deal with did not help matters. It seemed I was constantly forced to re-explain my points to someone new on a regular basis. Quite frankly, some of the responses seemed like there was resistance to what I was saying (so I was being brushed off until I went away). I simply feel I was getting the runaround in many cases.

With all due respect, it was you who stated in your August 9 letter open “ the future of aviation in Canada demands a healthy working relationship between Government and Industry. It requires regular, open transparent communication.†I can tell you, that this yet another example where we completely agree; unfortunately I have to say I don’t feel that is what occurred in this instance.

I hope this is not an example of what we should come to expect moving forward into the future. Many others in our industry feel that this is not an exception, but the norm when dealing with TC. The president of the HAC, discusses these very concerns in the Helicopters magazine article "Emerging from the Fog"

If this truly is the norm, then it is unfortunate. As I mentioned to you on the phone, Operations Managers and Chief Pilots at all organizations are your direct liaison to the pilots and the industry. Without open, transparent communications with these individuals, there will be a disconnect (between TC and our industry)from the reality of what goes on(as was the case in this instance).I would suggest safety levels will decline as a direct relationship to TC’s "full retreat from industry contact" as Fred Jones puts it.

What I fear the most, is that TC'ss involvement in the creation of future regulations will create increased risk and reduced efficiency(due to the disconnect with the Commercial Helicopter industry). An example of this would be Jacqueline Booths statement in her official CAIRS response: "The CARs does not state that "flight time shall be the same as air time", however the majority of flights conducted by commercial helicopter operators are logged as the same time. While I thank Jacqueline for her clarification, this demonstrates a lack of understanding of what Commercial Helicopter operations are really like. Ms. Booth is the Flight Crew Fatigue Management Working Group Co-Chair and Co-author of the TC report that proposes sweeping changes to the CARs with regards to Flight Time Limits and Duty Time limits, yet she does not understand what most commercial helicopter flights entail; this concerns me. It is not surprising that the majority of helicopter pilots and the HAC are so strongly opposed to her proposed amendments; they are not in tune with the reality of our industry. While I am not opposed to changes, I believe what is proposed will cripple the industry, create increased risk. I also believe that TC is greatly underestimating the effect it will have on the Canadian economy due to the vital role the Commercial VFR helicopters play in the development of our Natural Resources sector (particularly as we expand our search for resources into the far north).

We are not all like most scheduled fixed wing operators! I would suggest to you that the idea that "Flight Time = Air Time for skid equipped helicopters" was dreamed up by someone who insisted on comparing a helicopter flight to a fixed wing flight ; they likely had no understanding of what most commercial helicopter flights in Canada were like and not consider the reality that helicopters generally don't fly direct from one airport to the next (with no stops in between). This is likely your root cause....lets not make the same mistakes moving forward.

I am also wondering about how you plan on "addressing"or "evalidating" the two findings on the PVI Report that were made as a result of this confusion? I am still unclear as to what you meant by this in your e-mails. Will there be changes to the PVI Report? If so, what changes will be made?

Regards,

 

Chad Calaiezzi

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Received this by e-mail yesterday:

 

Please respond to me via email with the answers to the questions below. These questions are being asked throughout the region of all our operators.

 

For the records, I need to know the logging practices for each helicopter operator in Ontario. Please canvass your operators for the following information:

  • Does their COM contains the statement/rule that “Flight Time is the same as Air Time” or some statement to that effect?
  • Do they or have they in the past adhered literally to the rule?
  • When do they start/stop logging “Flight Time”?
  • When do they start/stop logging “Air Time”?

Is the time from Rotor Start to Rotor Stop used for some reason e.g. customer invoicing

 

Thanks for your cooperation.

 

 

 

Jamie Bionda

Civil Aviation Safety Inspector - Flight Operations

Inspecteur de la sécurité de l'Aviation civile - opérations aériennes

Civil Aviation | Aviation civile

Transport Canada | Transports Canada

3101 Skyline Drive, Garson, Ontario P3L 1V4 | 3101 Skyline Drive, Garson (Ontario) P3L 1V4

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Does this mean that Freewheel is going to start collecting a Transport Canada salary? Sounds like they want him to do their job or did i miss something?

 

W.

 

Well with all the cut backs we are all going to have to chip in for TC :lol:

 

Any new news on the subject been a while.

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