Flight Time Vs. Air Time Personal Logbook

[Cambox]

I'm just raising various interesting points to stimulate the conversation around this topic, although after 52 pages, I'm not sure we need anymore stimulation?

Regardless, my own opinion is that a helicopter is flying the minutes the blades are up to speed, just bang that cyclic full deflection to the side sometime while sitting on the ground if you don't believe me! LOL


 

Freewheel, on 29 Sept 2016 - 11:32 AM, said:

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...

 

[Freewheel]

Why not give the 7 questions a go? Pretty basic stuff really,

 

BTW MAKE THAT 53 pages and almost 67,000 views...i'm pretty sure we've revisited all of this discussion multiple times. Unfortunately we're beating the dead horse that is Transport Canada...that's the real story here.

 

Might as well come to your own concensus and have the compliance discussion if they ever have the gonads to charge someone.

[Freewheel]

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

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,

Letter replying to received Oct 3, 2016:

 

As you are aware, Transport Canadas priorities are to promote and develop a safe, secure and efficient transportation system, and aviation safety is of the utmost importance to the Department.

 

Transport Canada is aware of your position, which you have raised on several occasions and we believe we have addressed all of your concerns.

 

Please note any future correspondence on this issue will be reviewed to determine if new issues, under the purview of our mandate, have been raised. However, should no new area of concern be identified, no response will be issued.

 

I trust that the foregoing clarifies our position.

 

Yours truly,

 

Aaron McCrorie

Director General

Aviation Safety Regulatory Framework - Civil Aviation

[twinstar_ca]

wow....

[twinstar_ca]

[Freewheel]

wow....

What's wrong? Care to elaborate? Do you feel he hasn't "addressed all of our concerns"?

 

He clearly has no interest in continuing the discussion with me, but maybe he'll respond to your concerns (if you still have concerns, of course).

 

Here's his email address: TC.DGCivilAviation-DgAviationcivile.TC@tc.gc.ca

 

My suggestion keep it simple. I suggest true or false or yes or no questions. Feel free to use mine or any variation .

 

FYI: There's actually 2 Directors General that replaced Martin Eley: Aaron and Dennis Guindon. I guess they figured they were't heavy enough at the top....either that or Martin had really big shoes...

[Freewheel]

Oh...and he claimed his initial reply was to an email sent to the minister of transport. He stated he was replying on behalf of the minister...so might as well cc the Astronautl:

 

marc.garneau@parl.gc.ca

[Freewheel]

Letter replying to received Oct 3, 2016:

 

As you are aware, Transport Canadas priorities are to promote and develop a safe, secure and efficient transportation system, and aviation safety is of the utmost importance to the Department.

 

Transport Canada is aware of your position, which you have raised on several occasions and we believe we have addressed all of your concerns.

 

Please note any future correspondence on this issue will be reviewed to determine if new issues, under the purview of our mandate, have been raised. However, should no new area of concern be identified, no response will be issued.

 

I trust that the foregoing clarifies our position.

 

Yours truly,

 

Aaron McCrorie

Director General

Aviation Safety Regulatory Framework - Civil Aviation

Mr. McCrorie,

 

Since you refuse to respond to basic questions and/or discuss your interpretation as it pertains to any CARs requirements other than CAR 605.94 Journey Log Requirements, perhaps you can answer the following question:

 

Can you explain why we have never received a finding for Journey Logbook entries which have differing Flight Time and Air Time totals entered?

 

You stated: 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.

 

Our Journey Log entries are rarely ever the same for Flight Time and Air time. Our Journey logbooks have had a column for both flight time and Air Time for as long as I can remember. In that time we have had dozens of TC inspectors audit and inspect these entries during audits, inspections and PVIs. At our most recent PVI Alex Roberts, George East, Robert Laporte and James Dusalt all reviewed dozens of Journey log book entries, yet made no findings with regards to a practice which you claim is non-compliant.

 

We specifically brought up our Flight Time and Air Time Logging practices and drew there attention to the Journey Logbook entries (and the difference between Flight Time and Air Time entries). Furthermore, they made specific duty day findings with regards to several pilots training records (which were cross referenced with JLB entries), however they refused to make a finding against the fact we rarely enter Flight Time and Air Time as the same in Journey Log.

 

I have attached some scanned copies of our Journey logbooks. The first specifically shows the Flight training entries for pilot XxX XXX identified by the inspectors in Finding 703-02. Your inspectors specifically reviewed these entries and cross referenced against Flight Training records and Flight Time/Duty Time records (along with 13 other pilots records and JLB entries). The second attachment is a random page from the JLB for our Bell 206 Jetranger GJSZ. Im sure youll agree that according to your interpretations and recent correspondence this should be a non-compliance (& finding), yet the inspectors looked right at it and chose not to make a finding.

 

I understand that our most recent PVI was conducted in accordance with Transport Canada Surveillance Procedure in Staff Instruction SUR-001 Issue No. 5. Section 11 of this document states: TCCA must act on all non-compliances of which they become aware of. As such it is at this stage that TC begins the step of TCCA Follow-up action in the conceptual model of surveillance.

 

I apologize if Im raising an issue which is not new to you. It has previously been brought to the attention of several TC employees, however there is no way for me to know if you have received or reviewed this informatio. As directed in your recent letter: If no response is issued from you Ill take it to mean that no new area of concern has been identified and you are already aware that your inspectors are ignoring Transport Canadas own internal procedures and staff instructions (as mandated by the Minister).

 

Again, Ill raise my concern of ethics. The mandate that Transport Canada must act on all non-compliances of which they become aware is quite clear. When multiple inspectors simply chose to ignore that requirement then I will politely suggest that you likely have an integrity problem.

[Maury]

Freewheel - may I suggest you drop this and get a life.

[Freewheel]

Maury- thanks for the suggestion. I'll take it into consideration.

 

But I should tell you: I'm quite happy with my life. How about yourself?

 

In the meantime: if you don't like my posts, don't read them. It's that simple.