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Flight Time Vs. Air Time Personal Logbook


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"Sure, use air-time for A/F time, but if the client is paying for it I will be logging it." Really...   So what your saying is a good few hundred hours of your 20k is actually with the skids on

Can't find the amendment to CARs for definition of helicopter flight time so do we revert back to logging air time?       General Aviation Policy Letter (GAPL) No. 2005-02   Reference Canadian

Twiddling your thumbs too : )

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Thank you for your email. I trust that your summer has gone well and that your fall season continues to be a safe one.

 

There is no doubt in my mind that the question of airtime vs flighttime in a long haul flight regime is quite simple. However, once the flight times for a particular operation start approaching 6 minutes or less, the use of the one tenth measure, begins to become questionable and care should be taken. There is no doubt in my mind, Expedition Helicopters and the entire industry need clarity or guidance as necessary.

 

I am passing your questions along to Aaron McCrorie, so that he and his staff can answer your questions more formerly. No doubt these are questions that others have asked in the past, and it is imperative that the answers given are consistent and help to eliminate any confusion.

 

Respectfully

 

 

Michael R. Stephenson

Transport Canada/Transports Canada

Regional Director General / Directeur général régional Ontario Region/Région de l'Ontar

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APL 2005-02 was published after a comprehensive presentation that I made to TC on the subject.

 

Essentially "flight time" vs "air time" has nothing to do with what anyone thinks is best. It is a question of properly interpretting the law, as written.

 

First simple rule of interpretation in that regard is "the legislator does not speak for naught". In this case there is no getting around the fact that if the regulation speaks of "air time" and "flight time" it's because they are two distinct regulatory concepts. Ergo, they can not be systematically the same ... Defining the same thing twice would be a legislative waste of time and I say again, the rules of regulatory interpretation says that can't be!

 

Second simple rule of interpretation, if "flight time" and "air time" can't be the same, one must figure out how they are authoritatively different. In the absence of clear distinction in the CARS we can refer to the quite clear and ICAO definitions, especially in as much as Canada's agreement to abide by ICAO standards makes them officially as well as generally authoritative: "flight time" = rotors turning to rotors stopped; "air time" = skids up to skids down.

 

(This really burns the people responsible for flight training, especally ab initio flight training because the 100 hr minimum "flight time" is less han the ICAO Standard of 150 hrs. And hey are right to be upset! Canada should not be cherry picking ICAO Standards!)

 

Unfortunately, that being so, does not prevent anyone from TC o the industry from saying it ain't so ... And thus the argument goes for 38 pages on this forum and will continue to do go until someone goes to Court over the issue and a judge makes it official or until APL 2005-02 is re-issued.

 

BTW, the answer to the Indoctrination Exam question is non of the above, because without the time for beginning of rotors turning and the time for rotors stopped, you can not calculate the legally binding "flight time".

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“flight time”

 

“flight time” means 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; (temps de vol)

While the rotors are turning on startup, some would say that the "aircraft" as a whole has not moved yet for the "purpose of taking off" and therefore the flight time does not start until the "aircraft" takes off. The rotors have moved but the aircraft has not. The same on landing at the end of the flight. The "aircraft" comes to rest once it has landed.

I believe that fixed wing only count flight time when the aircraft is taxiing not when the engines start.

Just my "interpretation"

 

 

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Email response from TSB regional Manager Bill Yearwood. Bill is also an 11000 hour commercial helicopter pilot who spent time as a TC inspector and contributed to the creation of the CARs.

 

Hi,

Q1 is tricky. If you consider it 10 flights its 0.1 per flight. So A1 is i. Flight time 1.0, Air time. As one flight it’s 1.1 and 1.1

A2 is easy a. Flight time 0.4 Air time 0.4

In every case for a skid type helicopter flight time and air time are equal.

Cheers;

Bill

C.Wm. Yearwood

 

Manager, Regional Operations / Aviation Investigations- Pacific

Transportation Safety Board of Canada

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Reply to Mr. Yearwood:

 

Hi Bill,

 

Thanks for the feedback. nice to hear from you.

With all due respect I will need to disagree with you. I'll follow up with my reasoning and additional info next week.

Just a quick FYI...many Transport Canada approved air time calculators that are installed on aircraft would calculate Q1 as 0.6 air time. Jenkins system with squat switch on skid gear comes to mind.

 

Also according to director of Standards Jacqueline Booth and associate regional director: on flights with more than one landing flight time may be a higher value than air time. Under the interpretation they offered I beleive the answer to q1 is 1.2/0.6..

 

Flight time under ICAO would be from rotors turning to rotors stopped.

 

So far the majority of respondents (mostly pilots) have responded that Q1 is 1.3/ 0.6 which is in accordance with ICAO in my opinion.

 

You are the first person to provide this answer.

 

Also TC published GAPL 2005-02 in 2005 advising that the Flight Time = Air Time interpretation was incorrect.

 

The policy letter advised pilots to use the ICAO definition for flight time for helicopters. It also stated that the policy letter would remain in affect until the CARs were amended.

 

In 2011 TC Cancelled the policy letter with no explanation

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Reply from Mr. Yearwood,

 

Regardless ‎of what the regulations say it is important to log/report the time and cycles the way the components life was calculated. Next is how can operators get more revenue. Using rotors turning to rotors stopped sounds good, but as a customer I only pay from skids up to down. If I had to pay for rotors turning I would insist on a rotor brake and its maximum use. That would increase wear and tear. So around and around we go.

I still fly regularly and the approved log books have no provision for ‎2 different times. No takeoff or landing time record, but room for cycles (hook, start, landings, etc.).

If the rules change, the TBOs need to change. ‎Use needs to match design.

I acknowledge I'm out of touch with the fine points of regulation changes. I wrote all of the original CARs.and used the intent of the rule to guide me.

‎Cheers for now,

Bill

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