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Flight Time Vs. Air Time Personal Logbook

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85,000 got to be a record! So judging on that definition I'd say 95% of Canadian pilots came out of flight school with less than the 100 hour requirement unless they went over the 100 hour minimum for one reason or another. On top of that which would really piss people off  is every time you timed out on your 150 on a good job and got crewed out you could of stayed longer flew more and made more money cause the journey log book and your CPR should match according to the "definition" but who actually charges the customer what gets put in the JL I don't know any that do. Then if they really want to get sticky the whole system is foolish anyway cause every machine has the hobbs wired different so its all at the "discretion of pilot" what gets put in the log book so any lawyer could have a field day with that. How many AC have you flown that the book and the hobbs match? I know of 1. All comes back to the whole helicopter industry being a s@#$ show (but i love it) from what we get payed compared to our responsibility right down to the complete inconsistency across the TC regions from one end of Canada to the other all comes down to who you ask and you won't get the same answer twice. The fact that this thread is still on going just proves this and that there is no straight answer. Freewheel I have no idea who you are or what company you own or work for but seems from this thread and the other one about the carry on baggage TC in your area likes to give you home work. My hat is off to you for putting in the time trying to figure out the "right way" if it even exists. In the end if you get in legal trouble its going to come down to who got the better lawyer.   

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I'm no lawyer, but if any pilot ever gets into legal trouble I would suggest there's a pretty good case for a Defence of “Officially Induced Error" and/or "Due Diligence". Look the defences up if you're not familiar.


I wouldn't argue I was logging flight time in compliance; just that the root cause of my errors  (if it was found I was doing it incorrectly) was confusion created by erroneous guidance from the regulator; they know the confusion exists and choose to nothing to correct it. As you stated, this forum alone proves there is an issue industry wide. Then there is the numerous conflicting interpretations from high ranking officials in various branches of TC and a dozens of responses to an industry survey.  I'd be glad to share them with you if you ever find you need to defend your actions; many are posted in this forum. How about the general aviation policy letter (2005-02) that TC published and circulated from 2005 to 2011 (pasted in the first post)? There’s also a recent Supreme Court of BC ruling that contradicts HQs interpretation.

Given that TC is fully aware of this issue and choose not to do anything about it, I'd suggest they could end up with significant liability if it came up in civil litigation.

While we wait for it come up in a tribunal or court case, you can tell your clients you bill them for the time the aircraft is "in operation" as defined under the Canada Labour Code.

From Transport Canada Aviation Occupational Health and Safety:

"Confirmation has been received from ESDC-Labour that for Aviation Occupational Health and Safety purposes, a helicopter would be considered to be in-operation the entire time its engines are running and blades are turning, for the purposes of taking off"

"in operation" is defined 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.

Wait a minute, that's sounds pretty familiar doesn't it? Where have I heard that terminology before...oh that's right:

"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)

2 branches of Transport Canada providing interpretations to definitions that use the very same words and sentences, in separate legislation, in contradiction to each other. Huh, imagine that...I don't think that approach passes the sniff test….but again, I’m no lawyer.

The entire interpretation from Employment and Social Development Development Canada (ESDC) Labour Program and TC Aviation Occupational Health and Safety is on Page 46 of this forum. Right after they provided this interpretation, they cancelled CBAACNo. 0202R (which was in circulation for years) and offered an entirely different interpretation of “in-operation”. While they cancelled the guidance material, they provided no advisory or guidance to stakeholders about this new direction/interpretation. Common practice at TC it appears; they did the same thing with GAPL 2005-02. That doesn’t work at my organization, your organization, or TCs organization.


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Received from TC Enforcement Officer in Ontario Region Oct 27/17. 

"I did read over your survey and while I knew there were differing views I wasn’t aware of how big an issue this was in the helicopter field, I myself have not come across this as an enforcement issue. I came from the fixed wing part and it was a little more cut and dried. I don’t know what else I can offer, though it would definitely be an interesting challenge in a tribunal setting"

While he wouldn't provide specific answers to the 7 questions below, a response like this might be more revealing than actual answers.

If the person who  is responsible for investigating violations to the CARs (and issuing enforcement charges) doesn't know the answers, how can anyone expect a pilot to? 

Meanwhile Students with no aviation background whatsoever are being educated (by TC approved FTUs and accredited colleges) on CARs requirements contrary to TC HQ's  interpretation of the law. It's the first CARs requirement the school that gets you your licence teaches you as they take your money.

Despite his fixed wing background he regularly investigates helicopter companies for alleged violations. 

The  7 questions he was asked in the survey are below. 

Q1. A pilot  flies a Bell 206 Jet Ranger on Skids between CYMO  and the Lagoon Heliport and  makes the following entries in his pilot flight log.

Time up is the moment his skids leave the earth’s surface and Time down is the moment his skids make contact with the earth’s 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 on skids from CYCN to CYTS with no landings on route. 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 earth’s surface and Time down is the moment his skids make contact with the earth’s 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 @ 831

 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         


 Q4. Can you please confirm that you believe that your interpretation of Flight Time also applies to every other instance in the CARs where the term “Flight Time” is used?  

 A4. YES or NO

 Q5. Is it your position that the interpretation offered by Transport Canada (Flight Time = Air Time in skid helicopter) also applies to CARs 401 licencing requirements and CASS 421 Personnel licensing standards?   

 A5. 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

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On 2017-11-14 at 0:32 PM, Bif said:

Freewheel, I don't know how you find the energy to go on with this, but kudos. I'd love to see a cut & dry answer from TC but I won't hold my breath.

I would advise against holding your breath.

The purpose of the Safety Survey is to help us determine what the best approach is at our organization, not to get yet another "interpretation" from the standards branch. We've already received several As stated abouve this Official Induced error has made it so pilots and operators can pretty much come up with their own interpretation and implement.

Recently a TC Enforcement Officer from Atlantic Region cc'd the standards branch and regional authorities in his response and the Director of Standrads Robert Sincennes replied with a less than convincing commitment:

"I BELIEVE THAT MAYBE HQ needs to review these and prepare the response.

Herschell... please coordinate internally for answers

Robert Sincennes, P.Eng.
Director, Standards Branch
Directeur, Normes‎
Tel: 613-991-2738   cell: 613-859-2796   facsimile / télécopieur : 613-952-3298‎
Internet: robert.sincennes@tc.gc.ca
Transport Canada | Transports Canada
330 Sparks St‎
Ottawa (Ontario) K1A 0N5
Government of Canada | Gouvernement du Canada"

As far as my energy level( it really takes very little energy to distribute a 2 year old survey by email. About the same energy that it takes to complete the survey. Why not take part and help us devise our own interpretation.

The other point is that by simply providing an interpretation Standards branch will not fix this problem. They need to ensure that is distributed to all industry, regional authorities and inspectors and enforced in accordance with the interpretation. As we've seen, despite the numerous interpretations they've offered since 2005 they have failed in this respect. Responses to the survey and recent court rulings demonstrate this failure quite well.

GAPL 2005-02 was an interpretation that was distributed to stakeholders for 6 years then we received a finding from an inspector who was still enforcing Flight Time = Air Time. When the letter was brought to their attention, Standards branch cancelled it.

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No  problem if you don't want to participate in the survey.

How about a pool? These forums could use a little levity...

1) Will HQ respond further (as indicated by Director of Standards...maybe)?

2) How long will it take?

3) Will they provide actual answers to the questions in the survey?

The participant with the best answers wins the pot...I'll throw in 10 bucks.


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  • 2 weeks later...

I believe I made a comment about this years ago and as a contracting officer with PWGSC and responsible for trying to clarify how aviation charters should be billed to all department of the Federal Government, I had a clause inserted in all Contracts and Standing Offers issued to companies on how to bill:

Fixed Wing: rate per mile from A to B and return, including allowable charges as agreed. 

Rotary Wing: Hourly Rate from takeoff to final landing. i.e. depending on the requirement and type of work where the engine was not shut-down, it would be considered a continuous flight. The same would apply to fixed wing doing surveys.

This would apply to both types of aircraft, charges should only apply when the aircraft is in flight mode, ceases when the aircraft lands. This IS referred  to as "AIR TIME".

The entry of "AIR TIME" is the TRUE COST to the operator and is reflected in the overall maintenance life of the aircraft. "Flight Time" should be  removed from the Journey Log Book as it serves no purpose other than to HAVE THE DISHONEST OPERATORS USE IT FOR BILLING.


All the Auditors have to do is cross check the invoice for any given flight and the entry in the 

journey log and the tech log, you will be surprised

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Why not answer the 7 questions from the Survey BM? 

I’m not sure it’s fair to say everyone who disagrees with you is dishonest...one thing i’ve Learned there are many people who log a certain way because they have been taught that way...

in many cases it’s the school who trains them that First teaches them,....and it’s also the way they bill them.

In others, it’s the way TC told them to log...

some log flight time in a variety of ways depending on which document or regulation we are referring to. Some operator respondents stated flat out that TC has forced them to log flight time differently for differing records such as Flight/Duty Time records.

Journey Log Requiremebts are just one of many CARs requiremebts where “Flight Time” is referenced..Flight Tine is CARs 101 definition and is not redefined in any subsequent CARs; therefore it must be interpreted and logged consistently throughout all CARs.

you would not beleive the variety of responses to the survey...and herein lies the problem. Not who’s right or wrong, but that no one is clear on the actual expectations from the regulator. 

One thing the data does show,: the majority of pilots and operators who responded  bekeuve  flight Tine is logged as per ICAO. Definition. Rotors turning to rotors stopped for purpose of flight. This is Contrary to your interpretation and the recent interpretations from TC HQ. So how is it TC doesn’t notice? 

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