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OGEgirl

Flight Time Vs. Air Time Personal Logbook

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This confusion poses a risk in particular to forest fire operations in Alberta. Alberta will not pay for time on the ground (non airtime). So a pilot doing crew moves all day long can easily have 8 hrs of air time but 9 hours of flight time (time at the controls while loading and unloading). The norm would be to put 8 hours in the logbook as that is all that we get paid for. So a pilot after 18 days of logging 8 hours of airtime (adds up to 144 hrs) but actually has 162 hours of flight time if you count the time at the controls.

He is well over the max CARS regulation of 150 hrs if he uses the increase in "Flight Duty Time".

 

I'm sure this will come out in a court of law if there is an accident. This may come back to bite Transport Canada as they are well aware of the confusion and have done nothing to correct the problem. They may be the ones that are sued!

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This confusion poses a risk in particular to forest fire operations in Alberta. Alberta will not pay for time on the ground (non airtime). So a pilot doing crew moves all day long can easily have 8 hrs of air time but 9 hours of flight time (time at the controls while loading and unloading). The norm would be to put 8 hours in the logbook as that is all that we get paid for. So a pilot after 18 days of logging 8 hours of airtime (adds up to 144 hrs) but actually has 162 hours of flight time if you count the time at the controls.

He is well over the max CARS regulation of 150 hrs if he uses the increase in "Flight Duty Time".

 

I'm sure this will come out in a court of law if there is an accident. This may come back to bite Transport Canada as they are well aware of the confusion and have done nothing to correct the problem. They may be the ones that are sued!

Or from another perspective: if you have been doing it as per ICAO and GAPL 2005-02 (or by the interpretation offered by the Director of Standards) and TSB, TC officials and/or insurance adjusters use the Flight Time = Air Time interpretation when examining your personal logbook and training records they could claim you misrepresented your experience and/or did not receive the minimum training requirements under the CARs. This could lead to the pilot and operator being sued and denial of insurance coverage.

TC and TSB inspectors are often called to testify as expert witnesses.

 

The reason we have asked for clarification is that is exactly what happened during a TC inspection which led to findings. pilots received the required training in flight time hours however a couple had a 0.1 less than required if Flight Time = Air Time.

This time around, the gentleman from HQ who claimed Flight Time = Air time is leading our next PVI; we simply want to be sure he still isn't using the same interpretationbbut no one can answer.

 

Shouldn't those who audit flight time/air time records, licensing requirements, training requirements as per CARs (and act as expert witnesses in court)!be able to answer this question as a basic requirement of the job description?

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FYI

 

Interpretation 1: The same interpretation that was introduced into a COM template in late 90s by TC and distributed Nationwide for years,; also same interpretation offered by Robert Freeman and Alex Roberts of Headquarters, in 2011, the answers to the questions would be:

 

A1. B) Flight Time = 0.6/ Air Time = 0.6

A2.a) Flight Time=0.4/Air Time = 0.4

 

(This is the same method used by our POI when examining training records on our 2011 PVI resulting in bogus findings)

 

Interpretation 2: offered by Director of Standards Jacqueline Booth, 2011, the answers to the questions would be:

 

A1. c) Flight Time =1.2/ Air Time=0.6

A2. a) Flight Time=0.4/Air Time = 0.4

 

Interpretation 3: offered in 2005 in TC Policy letter GAPL 2005-02. GAPL 2005-02 was cancelled in August 2011 with no explanation given. Also in accordance with ICAO definition for Flight Time for helicopters, the answers to the questions would be:

 

A1. a) Flight Time = 1.3/ Air Time = 0.6

A2. B) Flight Time = 0.6/ Air Time = 0.4

 

(Currently there is no “difference” listed with ICAO with regards to logging Flight Time for helicopters. Alex Roberts and J. Booth advised in August 2011: “Errors in processing occurred when GAPL 2005-2 was cancelled in 2009. The document was not properly removed from the web and not included in the cancelled GAPL list. These errors lead to the circulation of erroneous information about the Policy Letter validity. The links below illustrate the corrections. GAPL 2005-2 is no longer valid, our apologies for the confusion”)

 

Those are some pretty significant Differences.

 

Yours Truly,

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Good morning,

I am doing ok here – I hope you are also.

Regarding your question yesterday on flight and air time please review the following.

Airbus Helicopters is concerned with limitations expressed in Flight Hours (FH), Calendar time & Cycles.
The definition of FH is given in both the Chapter 4 Airworthiness Limitations Section (ALS) and Chapter 5 Master Servicing Manual (MSM) – both are available through TIPI and as part of the standard documentation for each model of aircraft operated.

This definition of flight hours (not to be confused with Flight TIME) corresponds to Air Time as defined in CARs Section 101.01:

Airbus Helicopters does not take into account running time (i.e. flight time by ICAO definition) for purposes of tracking limitations.

So in answer to your two questions:

A1: answer a. Flight Time = 1.3 / Air Time = 0.6
A2: answer B) Flight Time = 0.6 / Air Time = 0.4 (Note: rotors stopped at 0831)

If you have any further questions regarding Airbus Helicopters requirements for tracking time please let us know.
Best regards,
Rod

Rod TUPALA
Technical Support (Ontario)
Airbus Helicopters Canada Limited

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Excerpt from Letter Received from Joseph Szwalek (Regional Director, Transport Canada, Civil Aviation)Nov 9/15

Subject: Flight Time vs. Air Time and Cabin Safety


As per my commitment to provide you an official interpretation of air time vs. flight time as applicable to skid equipped helicopters, please note the following.

As per CAR 101.01, air time commences when the aircraft lifts from the surface and continues to the point of landing. Flight time occurs when the aircraft first moves under its own power for the purpose of take off and continues until it comes to rest at the end of the flight. For commercial operations, air operators must record both air time and flight time in the Aircraft Journey Log. As you know, skid-equipped helicopters don't normally ' ground taxi', and all movement/manoeuvring is done while in flight because landing and coming to rest at the end of the flight are the same action. Manoeuvring at an aerodrome at low speed and low altitude is referred to as "air taxi", but in any event, the aircraft is still flying (taxi time on the ground is non-existent).

In some circumstances, a helicopter pilot may be required to touchdown on a surface that will not fully support the helicopter's weight, or may exceed pitch or roll limits (i.e. deep snow, swamp, rough/uneven terrain). Landings on these surfaces are generally done to allow crew members to embark/disembark or to unload relevant equipment (i.e. firefighting equipment). In these cases, the pilot is maintaining position by use of engine power (rotor maintained at flight rpm and positive flight control placement including collective and pedal inputs), thus the helicopter is essentially still flying while in contact with the ground. Since, as previously mentioned, the definition of 'flight time' is the time from the moment an aircraft takes off until the moment it comes to rest at the end of the flight, Transport Canada's conclusion is that holding a helicopter in a position where the pilot must rely on the aircraft controls and engine power to maintain position and control doesn't meet the definition of coming to rest at the end of the flight. The time spent in these types of operations (holding the aircraft in place by using the controls) qualifies and will count as flight time. Accordingly the operator is justified in claiming this as flight time in the Journey Log Book. Since flight time equals air time, this also addresses the requirement to log component time for the technical records as air time.

In summary, given that the CARs definitions of flight time and air time are the same in the context of skid-equipped helicopter operations, Transport Canada' s official interpretation is that flight time equals air time for purposes of Journey Log entries.

You may consider this interpretation Transport Canada' s final position on the matter. Please note that this interpretation has been disseminated within Transport Canada nationally and has been added to the National Aviation Safety Information System (NASIMS). I trust that this will resolve your previous requests for information on this subject. I encourage you to work with the Helicopter Association of Canada (HAC) if you have concerns about the applicability of this interpretation on your operations.

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So if a helicopter has one hour of air time and the pilot has been at the controls for an hour and a half during numerous stops while his customer got out (and did meter readings for example) What does the pilot put down for his flight time for his Flight Duty times? As far as fatigue goes he is still in control of the aircraft.

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