Freewheel Posted September 20, 2016 Report Share Posted September 20, 2016 The following email survey was distributed to Minister of Transport, Marc Garneau on June 3/16. September 7/16 the Directors General office replied on his behalf. I'll post 4 page reply shortly. Good Afternoon Honourable Minister, How are you? I hope all is well. The reason for this e-mail is to respectfully request your assistance. I can assure you, it will only take a few minutes of your time. Expedition Helicopters Inc. Safety Management System/ Integrated Management System has identified what we perceive to be a Hazard to our operations and Aviation Safety. The HAZARD identified is: Transport Canada and Industry wide confusion surrounding the regulatory requirements for calculating and logging Flight Time and Air Time in skid equipped helicopters (in compliance with the CARs). It is evident that this exists within Transport Canada: we have received differing interpretations from Headquarters, Regional Authorities and the Standards branch. High Ranking Regional Officials have also acknowledged the confusion exists. It seems there are at least 3, separate, yet distinct ways that the definition of Flight Time is being interpreted by Transport Canada and calculated throughout the helicopter industry. Some of these interpretations differ significantly from the ICAO definition of Flight Time for Helicopters. As a member state, I dont believe Canada has ever filed this regulatory difference with ICAO. Part of our Corrective Action is to implement additional training for our pilots. Under the CARs, this training requires that we validate the pilots competence through comprehensive examination. To ensure our training is sufficient and that pilots are knowledgeable on calculating both Air Time and Flight Time, the following question will be added to the Indoctrination Exam (which pilots complete annually). We are reaching out to industry stakeholders, pilots, aviation consultants, TC officials Nationwide (and other interested parties), asking them to respond to the following 2 questions. I kindly, and respectfully, request that you review the 2 simple multiple choice questions below and reply to this e-mail responding what you believe to be the correct answers. I'd welcome any responses, regardless of what your point of view is. Feel free to elaborate on the reasoning for your answers if you feel the need. This is a proactive data gathering exercise. I have already distributed the questions to all of our pilots and most have responded. Before we add them to our Indoctrination Exam, we want to be sure we are training our pilots on compliance requirements correctly and that we clearly understand what are the correct answers to these questions. In the absence of clarity from the regulator, we intend on using the responses to determine what we believe to be the compliant method (and train as such). Q1. A pilot flies a Bell 206 Jet Ranger between CYMO (Moosonee Airport) and the Lagoon Heliport (Moose Factory Island) and makes the following entries in his pilot flight log. Time up is the moment his skids leave the earths surface and Time down is the moment his skids make contact with the earths surface at the next landing. Engine Start Time/Blades turning: 754 Time Up Time Dn Air Time Starts Comments 800 804 4 min 1 CYMO Lagoon 809 812 3 min 0 Lagoon CYMO 816 819 3 min 0 CYMO Lagoon 822 825 3 min 0 Lagoon CYMO 829 833 4 min 0 CYMO Lagoon 838 841 3 min 0 Lagoon CYMO 844 847 3 min 0 CYMO Lagoon 850 853 3 min 0 Lagoon CYMO 855 858 3 min 0 CYMO Lagoon 904 909 5 min 0 Lagoon CYMO Engine Shutdown @ 912; Rotors Stopped @ 914 A1. For the above entries: The pilots calculated Flight Time and Air Time respectively, should be: a. Flight Time = 1.3 / Air Time = 0.6 b. Flight Time = 0.6 / Air Time = 0.6 c. Flight Time = 1.2/ Air Time = 0.6 d. Flight Time = 1.3 / Air Time = 1.3 e. Flight Time = 1.3/ Air Time 1.0 f. Flight Time = 1.2 / Air Time = 1.2 g. Flight Time = 1.2/ Air Time 1.0 h. Flight Time = 0.7/ Air Time = 0.6 i. Other: Flight Time = / Air Time = Q2. A pilot flies a Bell 206 Jet Ranger from CYCN to CYTS with no landings enroute. He makes 1 landing at his destination and shuts down the helicopter. He makes the following entries in his pilot flight log. Time up is the moment his skids leave the earths surface and Time down is the moment his skids make contact with the earths surface at the next landing. Engine Start Time/Blades turning: 754 Time Up Time Dn Air Time Starts Comments 800 824 24 min 1 CYCN CYTS Engine Shut Down @ 830; Rotors stopped @ 931 A2. For the above entries: The pilots calculated Flight Time and Air Time respectively, should be: a) Flight Time = 0.4 / Air Time = 0.4 Flight Time = 0.6/Air Time = 0.4 c) Flight Time = 0.5 / Air Time = 0.4 d) Flight Time = 0.4 / Air Time = 0.3 e) Other: Flight Time = Air Time = I thank you in advance for taking part in this exercise to promote regulatory compliance and look forward to your replies. If you have any questions, dont hesitate to contact me. Quote Link to comment Share on other sites More sharing options...
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