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Flight Time Vs. Air Time Personal Logbook

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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

B) 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.

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Text copied from 4 page letter ( 1 page cover letter and 3 page interpretation) from Directors General Of Civil Aviation, Aaron McCrorie. At the request of the minster, Mr. McCrorie replied to a June 3/16 e-mail addressed to the minister (posted above).

 

Does anyone else see an answer to either Multiple choice question? I thought it was pretty clear that was the sole purpose of the June 3 e-mail.

"Thank you for your correspondence of June 3, 2016, in which you seek Transport Canada (TC)’s guidance to ensure that your pilots training is compliant with regulatory requirements for calculating and logging “Flight Time” and “Air Time” in skid equipped helicopters.

 

The Minister has asked me to reply on his behalf. Please accept my apology for the delay in replying.

 

Transport Canada Commercial Flight Standards is responsible for the national interpretation of Flight Time and Air Time as these definitions apply to skid-equipped helicopters. With regard to your concerns about multiple interpretations, the TC regional offices have been made aware that one interpretation for all regulations and standards is necessary to ensure consistent application of the Canadian Aviation Regulations (CARs) across the country and to prevent confusion amongst operators and other affected parties.

 

The interpretation for Flight Time and Air Time for skid-equipped helicopters was supplied to you previously through the Transport Canada Regional Office responsible for your operations. This interpretation has been reviewed as the result of your recent inquiry but has not changed. A copy of the interpretation has been attached to this letter for your convenience.

 

The International Civil Aviation Organization (ICAO) definition of Flight Time is intended to apply to commercial, international operators only for the purpose of flight and duty time regulations. Adopting this definition would not address other regulatory concerns and would introduce inconsistencies in the regulatory requirements.

 

Transport Canada has not filed a difference with regard to this definition. The TC ICAO liaison has been so notified.

 

I trust that the above has addressed your concerns.
Thank you again for writing.

 

Sincerely,

 

Aaron McCrorie
Director General, Aviation Safety Regulatory Framework - Civil Aviation

 

Canadian Aviation Regulations Interpretation of Air time and
Flight time For skid-equipped helicopters

 

CAR 101.01 – Interpretation

 

"air time" - means, with respect to keeping technical records, the time from the moment an aircraft leaves the surface until it comes into contact with the surface at the next point of landing;

 

"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;

 

CAR 605.94 Journey Log Requirements

 

(1) The particulars set out in column I of an item in Schedule I to this Division shall be recorded in the journey log at the time set out in column II of the item and by the person responsible for making entries set out in column III of that item.

 

(4) Unless recorded in the operational flight plan or operational flight data sheet, the pilot-in-command of an aircraft engaged in a commercial air service and operating in international flight shall record in the journey log the following particulars in respect of each flight:
(a) the names of all of the crew members and their duty assignments;
( B) the places and times of departure and arrival;
© the flight time;
(d) the nature of the flight, such as private, aerial work, scheduled or non-scheduled; and
(e) any incidents or observations relating to the flight.

 

Schedule I - Journey Log Requirements

 

Item - Particulars to be entered

 

4. Air time of each flight or series of flights and cumulative total air time and, where applicable, number of operating cycles or landings since date of manufacture.
Analysis:

 

1. For commercial international operations, air operators must record both air time and flight time in the Aircraft Journey Log.

 

2. Skid-equipped helicopters do not ground taxi. Manoeuvring at an aerodrome at low speed and low altitude is referred to as “air taxi” or “hover taxi” depending on the aircraft altitude. In any event, all movement by a skid-equipped helicopter involves flight.

 

3. Air time commences when the helicopter 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 takeoff and continues until it comes to rest at the end of the flight. In a skid-equipped helicopter, takeoff and manoeuvring for takeoff are the same action. Landing and coming to rest at the end of a flight are also the same action. Taxi-time on the ground is non-existent.

 

Conclusion: As the CARs flight time definition does not apply to skid-equipped helicopter operations, the TC interpretation is that flight time equals air time for purposes of Journey Log entry requirements. Billing procedures, contractual considerations or data derived or developed for other purposes from the helicopter journey log entries is beyond the scope of this interpretation and is at the discretion of the operator.

 

 

Note/Exception: There are some helicopter operations where the pilot is forced to land on a surface that will not fully support the helicopter’s weight, or may exceed pitch or roll limits, such as deep snow, swamps or rough, uneven terrain. Landings on these surfaces is generally done to permit crew members to disembark/embark or to unload equipment being used for the task at hand, such as firefighting crews and equipment, mountain operations, and external load hook up. In these cases, the pilot maintains aircraft position on a marginal surface by use of engine power (rotor at flight rpm and positive flight control placement including collective and pedal inputs). In summary, the helicopter is essentially still flying while in contact with the ground.

 

The definition of flight time is “the time from the moment an aircraft first moves under its own power for the purpose of taking off takes off until the moment it comes to rest at the end of the flight”. The TC interpretation is that holding a helicopter in a position where the pilot must maintain position by means of the aircraft controls and engine power does not meet the definition of “comes to rest at the end of the flight”.

 

The time spent in these operations or other, similar operations counts as flight time. Accordingly, the operator is justified in entering this as flight time in the Journey Log Book. As flight time equals air time, then this allowance also addresses the necessity to log component time for the technical records as air time.

 

This guidance matches the intent of the ICAO Note 1 concerning the development of additional guidance attached to its definition of flight time as discussed below.

 

As well, the requirement to include flight time for rotors running between sectors in Note 1 is captured in the current CARs - one entry required for multiple short flights where the same pilot conducts the flights.

 

ICAO Definition

 

The ICAO definition for Flight Time – Helicopters contained in Annex 6, Part III, reads as follows:
Flight Time - Helicopters. 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 a flight and the rotor blades are stopped.

 

Note 1. The State may provide guidance in those cases where the definition of flight time does not describe or permit normal practices. Examples are: crew change without stopping the rotors; and rotors running engine wash procedure following a flight. In any case, the time when rotors are running between sectors of a flight is included within the calculation of flight time.

 

Note 2. This definition is intended only for the purpose of flight and duty time regulations.

 

TC Comments:

 

 The ICAO definition only applies to international commercial helicopter operations – not private operations.

 

 The ICAO definition (see Note 2) is intended only for flight and duty time calculations. Other requirements are not addressed.

 

 Note 1 authorizes the State to provide guidance and interpretation for other considerations concerning normal practices. TC has included a Note/Exception to the interpretation of flight time for skid-equipped helicopters.

 

 

 TC has not incorporated the ICAO definition into our CARS as this would result in inconsistencies in logging flight time between aeroplanes and helicopters. The CARS definitions do not include a requirement for recording starting and shut down times that the ICAO definition would introduce.

 

 The current definitions were developed and introduced into the CARS in 1996 and skid-equipped helicopters were duly considered at the time. The long-standing interpretation of flight time equals air time was not perceived as problematic or hazardous".

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Lol. Wild idea. Get an STC and throw some wheels on the A/C. Like the Schweitzer 300 and many others. Didnt say anywhere they had to work. Our great govt at work.

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And they STILL did not answer the question...

 

"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;

 

What about intermediate landings without shutting down??? You don't end the flight with setting out a crew in the bush, it ends when you shut down...

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E-mail reply to Minister of Transport Marc Garneau; Transport Canada Director General Civil Aviation was cc'd.

 

Good Morning Marc,

 

I received a response from the Directors General office on September 7, 2016; The letter states that the response is on your behalf and is in response to my correspondence of June 3, 2016. I thank you for this; its apparent that he took significant time to respond in detail. He also states that the interpretation has been reviewed as the result of your recent inquiry but has not changed. Again I thank you for allocating the resources to review the interpretation. Myself and the Accountable Executive responded to him on the very same day. Our correspondence to Aaron is below for your review.

 

Unfortunately, my June 3/16 e-mail clearly advised that its purpose was to gather data as part of a survey being distributed to stakeholders industry wide; it contained 2 basic multiple choice questions and requested that recipients respond to the questions. In responding on your behalf, Aaron did not respond to either question. I have attached the June 3 e-mail that I am discussing. I have also attached the e-mail I received from Aaron on September 7/16 and an e-mail reporting this industry wide danger to TC aviation Occupational Health and Safety

 

I appreciate the resources that Transport Canada has allotted to this issue, however, the request for recipients to respond to the multiple choice questions was quite clear. Aarons response is therefore incomplete. He also eludes to the fact that I have received most of this information previously.

 

I have pasted the 2 multiple choice questions below (Q1. And Q2.); I politely request that you (or Aaron) respond to these basic questions. Since the June 3 e-mail was distributed to you; we have also asked Aaron and his colleagues to answer a few other very basic questions. At this time we have yet to receive a response to any of these basic questions on regulatory compliance. I find this a little perplexing. I have also pasted these 5 questions below (Q3. Q7.) as well. In the interest of compliance I also request a response to these questions. They should really only require a minute or two of someones time.

 

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

B) 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 =

 

Q3. Applicable Definitions

 

"in operation" is described in paragraph 128(5)( of Part II of the Canada Labour Code. An aircraft is "in operation" from the time it first moves under its own power for the purpose of taking off in Canada, until it comes to rest at a destination in Canada.

 

"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)

 

Based solely on the above 2 definitions (as written), is the following statement true or false for a domestic flight in a skid helicopter?

 

Time "in operation" = Flight Time

 

A3.TRUE/FALSE ?

 

Q4. Can you please confirm that your interpretation of Flight Time = Air Time also applies to every other instance in the CARs where the term Flight Time is used? A4. YES or NO

 

Q5. Is it Transport Canadas position that your interpretation of Flight Time = Air Time also applies to CARs 401 licencing requirements and CASS 421 Personnel licensing standards? A4. YES or NO

 

Q6. Under your interpretation: a pilot should be logging Air Time as defined by the CARs in his Flight Time records under CARs 700.15; A6. YES or NO

 

Q7. Does Transport Canada plan on implementing other Corrective Actions and/or using available tools (like Guidance Material distributed to industry and/or enforcement) to rectify this well-known problem and confusion? A7. YES or NO

 

 

I thank you in advance for your co-operation,

Yours Truly,

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The same survey that was sent to Minister Garneau 0n June 3/16 was sent to long time helicopter pilot and TC inspector Richard Pearce. Mr. Pearce conducted my commercial pilot flight test in 1996 and attended our facility for a TC inspection in 2013. He retired in 2014.

 

Mr. Pearce had no problem responding to the multiple choice questions Q1 and Q2. He responded 5 days later on June 8. Q2 actually had a typo at the time ( rotors stopped at 931 and it should have been 831). Not only did he respond but he was kind enough to provide some quality assurance and advise of the error.

 

Here's Mr. Pearce's response:

 

I stopped my backhoe for a minute to figure this one.

I assume in Q2 it's 8:31 not 9:31.

Without giving this the sort of time and thought that a TC Inspector would, but being just a simple and happy farmer, I conclude Q 1 answer a.

Q 2 answer b.

 

My customer would, of course, be charged Flight Time.

However, I've a feeling that TC may scheme otherwise, as few there have ever made a payroll!

btw my big tractor engine quit on me when plowing the other day, so I simply swigged a coffee and climbed down to have a look. That's absence of stress!

All the best,

Richard

 

Sounds like Mr. Pearce has been applying the ICAO interpretation for most of his career, and therefore Flight Time does not equal Air Time in his opinion.

 

Regardless if he's right or wrong, it clearly demonstrates the confusion that has existed from within Transport Canada. This is the Root Cause of industry confusion IMHO (and sny findings which are the result).

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That raises an interesting point....... Don't you record "time up" and "time down"? So is sitting on the ground waiting for pax to deplane "air time" by the definition? No, it's not, IMO, but it could be construed as "flight time" strictly for billing purposes, I suppose? If you count "sitting" time as "air time", by definition, then you're adding needless component times, are you not?

And they STILL did not answer the question...

"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;

What about intermediate landings without shutting down??? You don't end the flight with setting out a crew in the bush, it ends when you shut down...

 

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No, it's not, IMO, but it could be construed as "flight time" strictly for billing purposes, I suppose?

 

 

Strictly for billing purposes???? Show me the CARs that relate to billing.

 

How you bill is not Transport Canada's business.

 

Flight time has one definition in CARs 101. No other definitions for flight time are found subsequently in CARs so it only has only 1 meaning and must be interpreted the same way in every instance that it is referred to in the CARs (and your COM).. Personal log, flight time limits, licensing, training etc. etc. Etc.

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Can't argue with you on the meaning of "flight Time" as defined in CAR's.  My comment on billing (flight time) was strictly that, from the time the helicopter lifts off with the customer until it finishes the flight, no matter how many landings and takeoffs it has, for example a soil sampling flight.  Nothing to do with the CAR's definition.  CAR's also, as you've previously indicated, has a definition of "air time" which basically says the aircraft has toi be in the air to log "air time."   Does your company bill the client strictly for "air time", as defined in CAR's, or for the time the total job takes, "flight time" as I mentioned above?

Maybe the CTA could provide some guidance on billing flight or air time? Kidding.....

 

Freewheel, on 29 Sept 2016 - 04:10 AM, said:

Strictly for billing purposes???? Show me the CARs that relate to billing.

How you bill is not Transport Canada's business.

Flight time has one definition in CARs 101. No other definitions for flight time are found subsequently in CARs so it only has only 1 meaning and must be interpreted the same way in every instance that it is referred to in the CARs (and your COM).. Personal log, flight time limits, licensing, training etc. etc. Etc.

 

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As a general rule: we bill as you mentioned above. But that's not always the case. Have you figured a way to get all provincial forestry agencies to allow you to bill that way? Many expect your flight report to match radio logs...which is air time only.

 

Industry wide there is also a pile of "Flat rate work". Many of those flights involve dozens (even hundreds in some cases) of landings between starts. How about aerial spray? Passenger shuttling? Rides? As you said "SOIL SAMPLING".

 

We always pay the pilot as you "mention above" after all he is working and responsible for the aircraft which is "in operation" according to TC AOHS and Canada labour code. Funny how the definitions of in operation and flight time are exactly the same don't you think? Yet the Givernment of Canada chooses to interpret them differently. Huh...

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