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OGEgirl

Flight Time Vs. Air Time Personal Logbook

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There seems to be no clear answer from anyone. Most people I work with seem to go with flight time, most don't use the Hobbs.

 

Also TC doesn't even require signatures in logbooks anymore....

 

How many of you have your logbook signed every so often? Or even at all? I know TC is 100% ok with digital logbooks with no stamps or signed entries. What's stopping anyone from using blades turning to blades stopping?

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Here we go again :lol:

 

"Blades turning to blades stopped" use to be what TC wanted as flight time in the personal log books. Now TC is not even sure what they are talking about. This is the same definition as in many countries and ICAO. At least its not as bad as the FAA allowing 2 pilots to log PIC time while flying. Might as well log what you legally can on the international job market your only shorting yourself unless you have all the requirements already. I guess the below policy letter never expired because there was no admendment to CARs? Although it was cancelled in 2011 if I remember correct. I believe there are still no "differences" which are required to be listed between TC and ICAO, So anyone care to Clarify what the Definition in CARs means now?

 

 

Some have had findings against there companies for logging the definition below "Rotors turning to rotors stopped" as flight time for companies recurrent training, yet flight schools get away with it every day billing and logging "rotors turning to rotors stopped" for new 100hr pilots while putting airtime in the journey log. You would think a 100hr pilot with limited experience should have 100hrs of airtime. So why would the experienced pilot get penalized and companies get findings. There still is a lot of confusion and legalities which can show Transport Canada being somewhat liable with all this confusion. So why isn't there a standard and why are some being penalized while others are not?

 

General Aviation Policy Letter (GAPL) No. 2005-02

Reference
Canadian Aviation Regulations Part I - General Provisions, Sub-part 1 Interpretation

Background
CAR 101.01(1) defines "flight time" as meaning "the time from the moment an aircraft first moves under its own power for the purpose of taking off until the moment it comes to rest at the end of the flight".

For aeroplanes, the meaning is clear and for helicopters that can taxi on the ground, "flight time" is interpreted as it is for aeroplanes. For helicopters on skids, it has been interpreted to mean, "skids off to skids on". In this case, "flight time" and airtime would be the same.

Annex 1, Chapter 1, of the Convention on International Civil Aviation sets out separate "flight time" definitions for aeroplanes and helicopters. For helicopters, "flight time" is "The total time from the moment a helicopter's rotor blades start turning until the moment the helicopter finally comes to rest at the end of the flight, and the rotor blades are stopped." In Canada, some have applied the ICAO definition of the helicopter "flight time" for helicopters on skids.

Action
In order to clarify the interpretation of the definition of "flight time" with respect to helicopters as it applies to flight crew licensing, "flight time" shall be as it is set out in Annex 1: "The total time from the moment a helicopter's rotor blades start turning until the moment the helicopter finally comes to rest at the end of the flight, and the rotor blades are stopped."

In order to align formally with the Convention, a Notice of Proposed Amendment proposing a separate definition for helicopter "flight time" will be presented to the Part I Technical Committee.

Effective Date
September 1, 2005


Expiry Date
This Policy Letter will expire with the appropriate amendment to the CARs.

Manzur Huq
Director
General Aviation

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From the back and forth between Freewheel and TC, it would seem that the "consensus" at TC is that flight time is to be calculated from the moment the aircraft first takes off after startup until it last touches down before shutdown. So, on a flight with only one leg, air time and flight time will be equal. If there are multiple landings (and possibly waits) in between, then flight time will be greater than air time.

 

However, I have yet to hear or see anything that even remotely sounds or looks official from TC on the matter.

 

As far as logbooks go, I was told by an ex TC inspector not very long ago that your logbook is like an insurance policy. No one wants to see it until the sh!t hits the fan. Same with the flight time declaration you make on your medical (hours flown last 30, 90, 180, 365 days). They'll only dredge that up post-accident...

 

TC doesn't have the resources to audit pilot logbooks. Imagine if you've worked for ten operators and flown ten different machines at each place. Machines get sold abroad or are destroyed over time. The only way you could do it is force pilots to keep copies of all the aircraft logbooks they've ever flown. Good luck with that...

 

Personally, I have all of my flight ticket books in a box somewhere. I can therefore corroborate every entry in my logbook, with the exception of some maintenance test flights, training flights and ppc rides...

 

Here's what CARS says about personal logs:

 

 

Personal Logs

401.08

(1) Every applicant for, and every holder of, a flight crew permit, licence or rating shall maintain a personal log in accordance with subsection (2) and with the personnel licensing standards for the documentation of

(a) experience acquired in respect of the issuance of the flight crew permit, licence or rating; and
(amended 2001/03/01; previous version)

(B) recency.

(2) A personal log that is maintained for the purposes referred to in paragraphs (1)(a) and (B) shall contain the holder's name and the following information in respect of each flight:

(a) the date of the flight;

(B) the type of aircraft and its registration mark;

© the flight crew position in which the holder acted;

(d) the flight conditions with respect to day, night, VFR and IFR;

(e) in the case of a flight in a aeroplane or helicopter, the place of departure and the place of arrival;

(f) in the case of a flight in an aeroplane, all of the intermediate take-offs and landings;

(g) the flight time;

(h) in the case of a flight in a glider, the method of launch used for the flight; and

(i) in the case of a flight in a balloon, the method of inflation used for the flight.

(3) No person shall make an entry in a personal log unless the person

(a) is the holder of the log; or

(B) has been authorized to make the entry by the holder of the log.

 

In clear, you are only required by CARs to log flights pertaining to flight training for the purpose of getting a licence or rating, and flights pertaining to recency requirements.

 

I know a lot of high time pilots who only log their annual training and ppc rides each year...

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Here we go again :lol:

 

"Blades turning to blades stopped" use to be what TC wanted as flight time in the personal log books. Now TC is not even sure what they are talking about. This is the same definition as in many countries and ICAO. At least its not as bad as the FAA allowing 2 pilots to log PIC time while flying. Might as well log what you legally can on the international job market your only shorting yourself unless you have all the requirements already. I guess the below policy letter never expired because there was no admendment to CARs? Although it was cancelled in 2011 if I remember correct. I believe there are still no "differences" which are required to be listed between TC and ICAO, So anyone care to Clarify what the Definition in CARs means now?

 

 

Some have had findings against there companies for logging the definition below "Rotors turning to rotors stopped" as flight time for companies recurrent training, yet flight schools get away with it every day billing and logging "rotors turning to rotors stopped" for new 100hr pilots while putting airtime in the journey log. You would think a 100hr pilot with limited experience should have 100hrs of airtime. So why would the experienced pilot get penalized and companies get findings. There still is a lot of confusion and legalities which can show Transport Canada being somewhat liable with all this confusion. So why isn't there a standard and why are some being penalized while others are not?

 

General Aviation Policy Letter (GAPL) No. 2005-02

 

Reference

Canadian Aviation Regulations Part I - General Provisions, Sub-part 1 Interpretation

 

Background

CAR 101.01(1) defines "flight time" as meaning "the time from the moment an aircraft first moves under its own power for the purpose of taking off until the moment it comes to rest at the end of the flight".

 

For aeroplanes, the meaning is clear and for helicopters that can taxi on the ground, "flight time" is interpreted as it is for aeroplanes. For helicopters on skids, it has been interpreted to mean, "skids off to skids on". In this case, "flight time" and airtime would be the same.

 

Annex 1, Chapter 1, of the Convention on International Civil Aviation sets out separate "flight time" definitions for aeroplanes and helicopters. For helicopters, "flight time" is "The total time from the moment a helicopter's rotor blades start turning until the moment the helicopter finally comes to rest at the end of the flight, and the rotor blades are stopped." In Canada, some have applied the ICAO definition of the helicopter "flight time" for helicopters on skids.

 

Action

In order to clarify the interpretation of the definition of "flight time" with respect to helicopters as it applies to flight crew licensing, "flight time" shall be as it is set out in Annex 1: "The total time from the moment a helicopter's rotor blades start turning until the moment the helicopter finally comes to rest at the end of the flight, and the rotor blades are stopped."

 

In order to align formally with the Convention, a Notice of Proposed Amendment proposing a separate definition for helicopter "flight time" will be presented to the Part I Technical Committee.

 

Effective Date

September 1, 2005

 

Expiry Date

This Policy Letter will expire with the appropriate amendment to the CARs.

 

Manzur Huq

Director

General Aviation

 

I remember when I did my ab initio the instructor explaining to me why flight time was different on helicopters and airplanes. He said that an airplane can be taxied under power by someone other than a pilot (ie mechanic) as long as they have company approval, because even if you mess up and push the throttles forward on a plane, it won't take off immediately and you can retard the throttles with little or no consequences. In a helicopter, from the moment the blades are under power, even at ground idle, inadvertent movement of the controls can lead to the aircraft leaving the ground or rolling over, therefore there must always be a licenced pilot at the controls. Hence the justification for flight time from blades turning to blades stopping.

 

In hindsight, seems like a pretty good excuse to rip me off... <_<

 

At one operator where I worked, and where we were told to log start to shutdown, we actually received a memo at one time explaining to us how to justify the fact that flight time could be greater than air time. We were to explain that not all helicopter parts were timed, and that a lot were "on condition" parts that would wear even if the aircraft was on the ground and bla bla bla... Worked with some customers, but others often got credited time, and we knew because the operator would reduce our flight pay accordingly...

 

I think the only thing we can do as pilots is to go as per company policy and let them worry about it. More and more operators and customers rely on whatever the satellite tracker says, so make sure you corroborate what it says with what you wrote in your notebook to make sure they jive. I've seen the trackers miss the first or last part of a flight. Better to catch those right off the bat than to spend time justifying yourself on the phone with your Ops Manager after the fact...

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I remember an old chief pilot telling me once "I don't give a sh!t what a pilot has in their logbook. I ask 'em what year they got their licence, then multiply how many years thay've had it by 500 and I'm pretty close 9 times out of 10"... :lol:

 

The way things have been going the last few years, I think if he was still in the business, he'd have to lower that number a bit...

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Received February 6, 2013:

Good morning Mr. Calaiezzi,

 

In your email dated January 21, 2013 6:45 PM, you quoted an excerpt from an email from J. Bionda March 28, 2011:

 

“With regards to your concerns regarding the air time/flight time findings, Rick and I spoke to Todd during the PVI about how /what you are recording in your aircraft journey logs, Todd responded that yes you record the air time/flight time in the air time column as suggested in your COM and that the flight time column was used for billing purposes (start up to shut down). In keeping with that air time and flight time are the same thing until otherwise approved, anything less than 1.0 hours does not meet the requirements of your present COM.”

 

Given the above stated practice, the Air Time/Flight Time recorded in the three JLB records referenced in the finding form did not meet the training requirements specified in your COM. Your own review of other training records identified five other training records where the Air Time/Flight Time recorded in the JLB did not meet the company’s minimum recurrent training requirements.

 

Furthermore, according to the statement above regarding your company’s practices for recording times in the JLB, the recorded time in the column titled Flight Time or Ops Time does not meet the CAR definition for “Flight Time” and therefore, could not be claimed as the flight time for the purpose of recurrent training

 

Please note that in my estimation, the “Flight Time and Flight Time are the same ……” issue that was in your COM at the time of the PVI has no bearing on the validity of the finding. In other words, neither recorded Flight Time nor Air Time recorded in the Air Time column was 1.0 hours.

 

Therefore, please allow me to reaffirmed TC’s position that the subject finding was and remains valid.

 

Sincerely,

 

Yves Lemieux

Associate Director Operations – East

Transport Canada Civil Aviation

Ontario

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Exerts from e-mail responses to Mr. Lemieux's Feb 6/13 e-mail:

 

"This not the way to promote open and transparent discussions with industry or a reporting culture. I should advise you that moving forward all conversations with TC will be recorded (whether over the phone or in person). What evidence do you have that Todd even said that. Did you get it in writing? I was not present when jamie spoke to todd, so i cant say for sure what was said. I also replied to this statement when Jamie sent it and I will resend you my reply when I get to the office. This was 2 years ago.

 

Every recurrent training form at our company had the value from the flight/ops time column in the JLB ; of these a very small portion were below 1.0 hrs air time: all were above an hour flight time..."

 

"Also, even if we didn't meet the standard how can you deny that the root cause was confusion industry wide created by TC. This you have already acknowledged. If Todd did indeed state that then i say he was likely confused like everyone else in the industry. Keep in mind gapl 2005-02 was still valid since TC forgot to cancel it; this document advised us to use ICAO definition for flight time"

 

"I guess this also means that my inspector did not see issue with us logging flight time as air time in our logs and calculating flight time limits. Or did he believe we log flight time 3 different ways?"

 

"Hi Yves,

 

I apologize for several e-mails this morning, I was not in the office, but felt your e-mail deserved a prompt response; I responded on my phone.

 

Since you are examining exerts from an e-mail string I believe we should look at the entire e-mail. I have cut and paste the entire e-mail and my response below. I have always found my POI’s closing statement to mean that he actually believed Flight Time = Air Time as written in the CARs: “If you believe there is an incorrect definition in the CAR's perhaps you would be wise to submit a CAIRS. I don't see the fact that the regulations as they are, not being to your satisfaction as a valid excuse to operate otherwise.” What do you think? Sure sounds like he believes the CARs state flight Time shall = Air Time as per the CARs. That is why he made the finding.

 

As stated, I can’t speak for Todd, but I will confirm with him what was actually said. I believe he has already denied saying this. But I will confirm.

 

Regardless, let’s look at the big picture here. You have a chief pilot being asked a questions by an inspector, when in all reality the inspector doesn’t know the correct answer to the question himself. The Chief Pilot is expected to provide an accurate response within seconds as to how he does it (based on what he believes the regulations state and how this inspector chooses to interpret it, today. Do I need to remind you that Transport Canada themselves took 2 years to provide me with a clear co-ordinated response as to what the regulation says? You yourself “flip flopped” on the issue just recently. In august you advised the statement “Flight Time is the same as air time” as consistent with the interpretation that the Director of standards offered. Months later you recanted and stated that this “obviously” wasn’t the case for many flights. I would also like to point out to you the wide range of responses from TC that I have received is further evidence that TC is responsible for further “muddying the waters” with respect to the correct interpretation. To be honest, I believe your e-mail admitting this confusion and TC’s role, is the first time TC has actually committed to offer an interpretation (other than GAPL2005-02 that is).

 

Doesn’t this all mean that TC only recently just figured out how it should be done and plan on advising the industry? I am sorry sir, but this finding should be against your organization, not ours. You’re email acknowledges that the root cause is a statement introduced to COM’s by TC themselves; doesn’t it?

 

Combine this with the fact we have had numerous Principal Operation Inspectors in the past 13 years who have offered a wide range of convoluted beliefs on how they interpret how flight time should be logged. How is it that you expect any Chief Pilot to answer this question with certainty? Especially if the POI, TTL and Director of Operations can’t. Even the Director of standards made comments that were not accurate. Also keep in mind, that it is his in the CP’s best interest to answer as the POI would like to hear, so he won’t receive a finding and he can get back to conducting his daily duties.

 

As you are aware, I have an audit to prepare for, so I will cut this short. I have to say as a stakeholder I am dismayed at your response. Especially, when I consider the audience of High Ranking TC officials that have been cc’d on these e-mails. I am very surprised that at least one of you don’t see the findings (and this resistance) for what it really is. I am also surprised at the complete lack of accountability that this demonstrates at TC. Despite all the rhetoric and SMS slogans in the news and on your websites, it seems the culture is not where it needs to be to advance the implementation of SMS."



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