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Flight Time Vs. Air Time Personal Logbook

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HAC Communique July 12/18

Air Time Versus Flight Time Issue Unlikely to be Resolved – At Least Until the Fall

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You may recall from a previous issue of the Newsletter, that Transport Canada is revisiting the definitions of Flight Time and Air Time that were recently imposed on the industry. The current definitions have been delivered to Justice, for their interpretation, and there has been some recent dialogue with HAC. Your association has tried to help inform the Department about some of the problems that have arisen with the current definitions. The current definitions were not really drafted with the rotary-wing community in mind. Your association is concerned that the department will torture the interpretation of the current definitions, by applying Guidance Material, rather than fix the problem by revisiting the definitions themselves. You can’t fix a bad definition by applying your own definition that defies the meaning of the words in the regulation. HAC believes that would be “regulation through Guidance Material,” which circumvents the regulatory process altogether.

 

I like the insinuations that there has been New definitions for Flight Time and Air Time imposed on industry recently. The CARs definitions have not changed in 22 years, since the CARs were first introduced in 1996. There have been no new interpretations.offered recently either.

TCs 2005 Policy Letter acknowledged that many were interpreting Flight Time = Air Time interpretation prior to 2005 and advised to use ICAO definition.

The idea that the definition for flight time was not ideal for Helicopters is nothing new, either. Clearly, that is the case, or TC wouldn’t be continuously be interpreting it differently. This forum wouldn’t have 69 pages and almost 102,000 views either.

It was clear back then that the definition was not perfect for Helicopters. That is why TC s 2005 policy letter also committed to amend the CARs to include a specific flight time definition for Helicopters (which stated it would expire when the CARs were amended).

Talk about coming full circle (13 years later). What’s really odd, as I understand it, the HAC was instrumental in the creation of the 2005 policy letter. I guess they don’t recall that.

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Transport Canada Aviation Safety Letter 4Issue 4/2011

https://www.tc.gc.ca/eng/civilaviation/publications/tp185-4-2011-regulations-6173.htm#false

The purpose of this article is to focus on subsection 7.3(1) of the Aeronautics Act and specifically paragraphs 7.3(1)(a) and M7.3(1)(c) which, are very serious offences related to "False Representation" and "False Entries."

 

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13 hours ago, Freewheel said:

Transport Canada Aviation Safety Letter 4Issue 4/2011

https://www.tc.gc.ca/eng/civilaviation/publications/tp185-4-2011-regulations-6173.htm#false

The purpose of this article is to focus on subsection 7.3(1) of the Aeronautics Act and specifically paragraphs 7.3(1)(a) and M7.3(1)(c) which, are very serious offences related to "False Representation" and "False Entries."

 

Thanks for this observation, "False Entries."

AIR TIME in an aircraft log book is what is used to calculate the life expectancy of the aircraft and every component attached to it, to maintain it's airworthiness for flight.

If it should happen that the operator would play with the entry, i.e 2.5 hrs. "Flight Time" and invoiced said time, BUT entered 2.0 hrs in the "Air Time",  column.

The operator just made a false entry in a log book.

It also decreases the airframe and component costs and increases the profit margin.

If you think this doesn't happen, think again.

Normally the hours invoiced, equal the hours in the AirTime log book or tech log.

There is one TC inspector who says he never checks the invoices in relation to the log book entries, maybe he should.    

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I’m sure there are some who fudge numbers. You always have a few in society who are willing to push the limits in the “Grey areas” of the regulations.

Take this Transportation Appeal Tribunal Case found in ASL4/2008  for instance;

https://www.tc.gc.ca/eng/civilaviation/publications/tp185-4-08-regulations-4051.htm

But wait a second, the operator was charged with “Making inaccurate entries regarding cumulative air time and recording excessive differences between air time and flight time”.

Say what now.?! I thought any difference between Flight Time and Air time would be violation (and therefore excessive).

IMHO The vast majority of discrepancies are likely a direct result of the confusion created by TC in the current environment;. officially induced error.. Since they aren’t enforcing these regulations these days, those few devious operators are able to benefit. I guess they don’t see this as such a serious offence after all.

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On 9/19/2018 at 10:08 PM, Blackmac said:

There is one TC inspector who says he never checks the invoices in relation to the log book entries, maybe he should.    

Just one?

In the past 19 years ive been through about a dozen audits and inspections. There have likely been 30 different TC inspectors in attendance throughout these visits. I can’t recall one of them ever looking at an invoice....

No surprise though. TCs mandate has nothing to do with how we bill. The CTA checks that.

Clearly, the vast majority of inspectors don’t verify student pilot personal logs against the Air time in the Journey logbooks either (to ensure they’ve actually received the minimum licensing requirements in CARs part IV). This IS within their  mandate.

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The idea of checking the invoices for the hours charged for the flight, entries in the "airtime tech log" should be the same, or somebody is playing games. This basically a cross check.

It has nothing to do with the billing process. 

CASE No. 1-Record Keeping: Accuracy Is a Must

A company appealed a review decision that the TATC had rendered against it. The challenged decision dealt with numerous contraventions of the Canadian Aviation Regulations(CARs). The contraventions concerned the performance and recording of maintenance or elementary work[CARs 571.02(1) and 571.03], compliance with airworthiness directives[605.84(1)], requirements regarding journey logs and technical records[605.93(1) and 605.94(1)], and maintenance control systems[706.02]. The TATC appeal panel concluded that the review decision was reasonable.

8 hours ago, Freewheel said:

Just one?

In the past 19 years I've been through about a dozen audits and inspections. There have likely been 30 different TC inspectors in attendance throughout these visits. I can’t recall one of them ever looking at an invoice....

No surprise though. TCs mandate has nothing to do with how we bill. The CTA checks that.

Clearly, the vast majority of inspectors don’t verify student pilot personal logs against the Air time in the Journey logbooks either (to ensure they’ve actually received the minimum licensing requirements in CARs part IV). This IS within their  mandate.

I guess the Government wasted taxpayers money when they paid for the following courses on my behalf.

Transport Canada Auditors Course. Edmonton

ISO 9000 (KPMG) Ottawa

Three (3) different Safety Courses at the California Safety Institute, New Mexico

 Safety Management Course, Transport Canada.      PLUS OVER 50yrs IN THE INDUSTRY.

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Nov 29/18 email

“...Please note that earlier this year Transport Canada decided to develop an Advisory Circular (AC) to ensure consistent application and understanding of the matter...I can now report that the AC is nearing completion.  It our plan to share the AC with all industry associations by January 2019 for review prior to its official publication with a requested response date...Once the AC has been reviewed by recipients and that we have considered the feedback, I believe this will be the best opportunity for a discussion with TC.  

 Thank you

 Robert Sincennes, P.Eng.

Director, Standards Branch

Directeur, Normes

Tel: 613-991-2738   cell: 613-859-2796   facsimile / télécopieur : 613-952-3298

Internet: [email protected]
Transport Canada | Transports Canada
330 Sparks St
Ottawa (Ontario) K1A 0N5

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