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OGEgirl

Flight Time Vs. Air Time Personal Logbook

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So here is what I take from the "definitions". TC issued the letter to clarify the definition of helicopter flight time in line with the ICAO version of flight time. They have now cancelled there clarification letter and have made no admendment to CARS. So back to the unclarified version of CARS. However TC has submitted there differences to the ICAO version of personal licensing with no differences to annex 1 chapter 1 which contains the definitions of helicopter flight time.

 

So if you ask your chief pilots, TC officials, or fellow pilots I bet you will get different answers which will depend on the individuals interpretation. However I go by there are no diferences to chapter 1 of ICAO and why ripp off your own hours when competeing for jobs interenationally when most are loging "rotors turning to rotors stopped".

 

 

Transport Canada:

Annex 1, Chapter 1, of the Convention on International Civil Aviation sets out separate "flight time" definitions for aeroplanes and helicopters. For helicopters, "flight time" is "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 the flight, and the rotor blades are stopped." In Canada, some have applied the ICAO definition of the helicopter "flight time" for helicopters on skids.

 

Action

In order to clarify the interpretation of the definition of "flight time" with respect to helicopters as it applies to flight crew licensing, "flight time" shall be as it is set out in Annex 1: "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 the flight, and the rotor blades are stopped."

 

In order to align formally with the Convention, a Notice of Proposed Amendment proposing a separate definition for helicopter "flight time" will be presented to the Part I Technical Committee.

 

ICAO ANNEX 1 — PERSONNEL LICENSING

 

 

The attached Supplement supersedes all previous Supplements to Annex 1, and includes differences notified by

Contracting States up to 1 June 2000 with respect to all amendments up to and including Amendment 162.

 

SUPPLEMENT TO ANNEX 1 (EIGHTH EDITION) CANADA 1 (Differences)

1/6/00

CHAPTER 2

2.5.1.5.1 Canada does not require the use of a multi-crew aircraft for the demonstration of skill for the issue

of an airline transport pilot licence.

2.6.1.5.1 Holders of instrument ratings do not require a Class 1 Medical Assessment.

2.10.1.5 Holders of instrument ratings do not require a Class 1 Medical Assessment.

CHAPTER 3

3.3.1.3 Canada gives aircraft maintenance engineers a credit of 50 hours toward the experience requirement

for the flight engineer licence.

 

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I have see this pop up several times now and I just want to throw in my two cents regarding it.

 

Some of you comment that running the machine on the ground causes wear and tear, which i won't argue, but in my line of work, i know it is fractional compared to working forces.

 

As for costs, when you break down everything (and yeah, it varies greatly by overhaul costs per component and specific machine), it costs very little per hour in the big picture to be running your machine on the ground. I didn't go and crunch any numbers, but its very clear that spread over a 3000hr overhaul and extremely minimal wear attributed to idleing on the ground, you might be a few pennies an hour if you really exaggerate it.

Fat math on your logged hours is usually more than sufficient to overcome any extra cost that may be incured. "yep jethro, that flight lasted exactly 26 minutes....lets make than an even 0.5"

 

So there is zero reason to use that as an excuse to bill the several minutes of sitting idle during start/shut down of the aircraft.

 

Now if you're on a sampling job and waiting 10-15 minutes before the next hop, work it into your contract and enjoy the extra revenue at full rates.

 

that is all...continue...

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"moves under its own power."

 

Well, when the rotors start spinning, the helicopter "moves". You're better not to be too close from, say, the tail rotor. Should be the same for airplane propellers, IMO.

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As mentioned in one of my previous posts, we have submitted a Civil Aviation Incident Report (CAIRS) to Transport Canada in order to receive clarification with regards to the Flight Time/Air Time definitions. For those of you who are unfamiliar with the CAIRS system, it is basically Transport Canada's Safety Management Reporting System for stakeholders like ourselves.

This CAIRs report was originally submitted on April 27, 2011, but ironically it discussed several of the very same discussions that others have since posted on this forum.

 

We Recently received a response with regards to this issue from Director of Standards Jacqueline Booth. We have decided to share this response on this forum in hopes of clarifying the issue slightly for those of you who are concerned. We have requested that TC provide formal clarification to the industry and throughout TC to eliminate this confusion, however this remains to be seen.

 

Here is the CAIRS Response:

The recent concerns expressed in your submission of August 2, 2011 were entered into the Civil Aviation Issues Reporting System (CAIRS) and were assigned file number IB-8718. As a result of my review of the above referenced file I would like to provide you with the following information:

 

Please see the attached Appendix A which includes the meanings from subsection 101.01 (1), Section 602.02, Section 700.15, and Section 700.16 of the Canadian Aviation Regulations (CARs).

Concern #1

 

“…Our concerns were with regards to Transport Canada’s interpretation that “Flight and Air Time are the same for skid equipped aircraft”. This statement is nowhere to be found in the CARS, yet TC has placed a statement of this nature in our generic COM. We attempt to amend the COM, but are denied, despite the fact it meets the CARs. From what I understand, POI does not have the right to deny approval of a COM that meets the CARS. I challenge any person at TC to show me where it states that Flight time shall be the same as Air Time in the CARs…”

 

The meaning of the phrases “air time” and “flight time” for Canadian operations are found within Subsection 101.01 (1) of the CARs which are applicable to all parts of the aviation regulations...

 

The CARs does not state that “flight time shall be the same as air time”, however the majority of flights conducted by commercial helicopter operators are logged as the same time.

Concern #2

 

“…as is clearly stated in GAPL 2005-2 (see CAIRS submission); this policy letter is no longer listed in the current GAPL list, however it is not listed in the cancelled GAPL’s either. It is still listed on Transport Canada’s website and as far as I am aware the aviation community was never informed that the Policy Letter was no longer in effect. The Policy letter states its validity will expire when the appropriate amendment to the CARS has occurred…”

 

GAPL 2005-2 is no longer valid. When GAPL 2005-02 was cancelled in 2009 the document was not properly removed from the website and not included in the cancelled GAPL list. These errors lead to confusion surrounding the Policy Letter... This error has now been corrected. The links below illustrate the corrections.

 

GAPL 2005-02

http://www.tc.gc.ca/eng/civilaviation/standards/general-policyletters-cancelled-gapl-2005-02-3953.htm

 

(Menu page)

http://www.tc.gc.ca/eng/civilaviation/standards/general-policyletters-cancelled-menu-2256.htm

 

The meaning of “flight time” within Subsection 101.01 (1) of the CARs remains intact but may be subject to a future review.

 

Concern #3

 

“…I also understand, that member states of ICAO must file differences in regulations with ICAO. To my knowledge no “difference” with respect the CARs and ICAO standards with regards to this issue have been filed…”

 

As you pointed out the ICAO definition of “flight time” is not identical to the meaning of “flight time” within Subsection 101.01 (1) of the CARs. Many of the ICAO member states have individual phrases within their Regulations that are not identical to the ICAO Standards and Recommended Practices (SARPS). This occurs for many reasons. Unless a member state adopts the SARPS verbatim these subtle inconsistencies between the regulatory phrasing will continue to exist.

 

Differences are generally filed when the individual Member States regulations are not included, are missing, or not in compliance with the international aviation regulations. Where the definitions are not identical but are similar to those contained in the ICAO Annexes, a filing of a difference is not required. In many cases Canada has included definitions in the CARs that are not included, or are not exactly the same as the ICAO definitions. One example where similar definitions cover the same meaning or intent is the ICAO definition for “Flight duty period” and the CAR definition for “flight duty time”. These two definitions have the same meaning but are calculated differently.

 

Concern #4

 

“…One of our biggest concerns, is how this is to be interpreted by pilots with respect to logging Flight time with respect to Flight Duty Time regulations and monitoring pilot fatigue. If TC’s interpretation is accurate, we understand this to mean that the pilot is only required to log the time in which his skids are not in contact with the Earth’s surface in his flight duty time records. We have asked several TC inspectors and Supervisors a simple question, yet receive no clear response.

Here is a recent scenario that was presented to several inspectors and supervisors yet we have not received clarification: A pilot makes 50 take-off and landings(on creek beds) over a period of 10 hours with engines running and blades turning at 100% ; the pilot is in contact with the earth’s surface (creek bed) for 4 .0 hours with engine at full throttle and wings/blades moving)while his customers take sediment samples. Is he only required to log 6 hours flight time in his flight duty times....????...”

 

The appropriate “air time”, “flight time” and “flight duty time” for Canadian operations should be logged in accordance with CAR 101 definitions.

 

The reality is that helicopter flights do not end when the helicopter touches a surface, but rather “…the moment it comes to rest at the end of the flight….” as per the meaning within Subsection 101.01 (1) of the CARs. Within your scenario, “flight time” might continue while the helicopter is in contact with the surface but still under control by the pilot in command. If the intent is to not terminate the flight at this time and where there is no intent to shut down the helicopter, then the flight time should continue to be logged.

 

There may be some confusion between the terms flight duty time and flight time limitations. Your reference to the flight duty time is probably more in line with the flight time limitations found in CAR 700.15 which specifies the total flight time limits for all flights during a given number of days.

 

Flight Time Limitations under CAR 700.15 requirements are to calculate the total flight time limits for consecutive periods of time for a day, 7 days, 30 days, 90 days and 365 days. Under CAR 700.16 Flight Duty Time Limitations and Rest Periods are used to calculate the flight duty time limits for a 24 hour period.

 

 

The maximum “flight duty time” allowed under the appropriate portions of Subpart 700 of the CARs is the minimum safety standard. Complying with Subpart 700 does not exempt an air operator from other Regulations such as Section 602.02 of the CARs that states in part:

 

“…No operator of an aircraft shall require any person to act as a flight crew member and no person shall act as a flight crew member, if either the person or the operator has any reason to believe, having regard to the circumstances of the particular flight to be undertaken, that the person… is suffering or is likely to suffer from fatigue; or… is otherwise unfit to perform properly the person's duties as a flight crew member…”

 

Within your scenario it would be prudent of an air operator to relieve a flight crew member of his flight duties “…when he is suffering or is likely to suffer from fatigue…” irrespective of his “flight duty time” limits.

 

Concern #5

 

“…Most recently, our POI responded that if I wished further clarification I should contact Rob Freeman because his office had done all they could. When Mr. Freeman was contacted, he informed me that Transport Canada protocol does not allow him to deal directly with me and I would have to deal with my POI???...?

 

Transport Canada (TC) assigns a Regional Inspector to each air operator as a Principal Operations Inspector (POI) to liaise on operation matters. This set up is meant to ensure TC offers an appropriate point of contact that is most familiar with the individual air operator’s needs. If the POI encounters situations and/or issues that they are unable to resolve, consultation with TC Regional Management or TC Headquarters may occur. Due to the structure of Transport Canada advice offered by TC Headquarters is considered functional guidance, and is rarely offered directly to the air operator but rather to the POI, thereby avoiding confusion and preserving the relationship between the POI and air operator.

 

If an air operator wishes to discuss a situations and/or issues with a TC representative other than their POI they should consult TC Regional Management.

 

Concern #6

 

“…As an operator, we are currently confused with this situation (as are most pilots in the industry); we are trying to determine the proper way that a pilot should log his flight time with respect to Flight Duty Times and Personal Logs. These issues are linked directly to pilot fatigue and pilot experience and feel that the current situation is a threat to aviation safety…”

 

 

As discussed above and to reiterate:

 

• GAPL 2005-2 is no longer valid.

 

• The meaning of “flight time” within Subsection 101.01 (1) of the CARs remains intact but may be subject to a review in the future.

 

• The appropriate “air time”, flight time, and “flight duty time” for Canadian operations should be logged as per the meaning (s) within Subsection 101.01 (1) of the CARs.

 

• “…No operator of an aircraft shall require any person to act as a flight crew member and no person shall act as a flight crew member, if … the person… is suffering or is likely to suffer from fatigue; or… is otherwise unfit to perform properly the person's duties as a flight crew member…”

 

 

I would like to take this opportunity to thank you for sharing your views as any comments we receive are appreciated.

 

Should you have any further questions, please feel free to contact me via e-mail at:

 

[email protected]

 

Sincerely,

 

Jacqueline Booth

A/Director

Standards Branch

Civil Aviation

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Here is my reply to Jacqueline with additional questions (I was advised she forwarded on my e-mail on to the appropriate division and she would have a response within a couple of weeks - a date which has passed with no reponse)

 

Hi Jacqueline,

First off, I’d like to apologize for using the term Flight Duty Times so loosely. I can assure you that I have a good understanding of the CARs as it relates to Flight Time Limits as well as Duty Time limits; there is no confusion between Flight Time limits and Duty Time limits at Expedition. At our organization we monitor both of these limits using one system and we generally refer to the as Flight/Duty Times (ie. When asking pilots for updates etc.). As you suggest, my concern was how the interpretation that we’ve been hearing from our TC inspectors (Flight Time = Air Time) related to the Flight Time Limits found in CAR 700.15.

Also, we are aware that GAPL 2005-02 has been cancelled and that an error occurred in 2009 which “lead to confusion surrounding the Policy Letter... This error has now been corrected”. Although this is simply an administrative error, I would suggest that this error lead to some of the confusion within the industry and Transport Canada; I would hope additional corrective actions have been in place to prevent future recurrence (other than simply correcting the error). In the spirit of SMS would it not be prudent to provide stakeholders (who come forward with such concerns) the corrective actions that have been implemented?

Your interpretation of the CARs definitions for Flight Time and Air Time ( and whether they should be logged as the same) is of particular interest to me. I have been discussing this issue with several POI’s since we received our AOC and approved COM over 10 years ago. The COM was a generic template that most operators received from TC, and the statement below was in the COM when we received it.

 

COM 4.18 (2) states “Flight Time and Air Time are the same for skid equipped helicopter, accordingly the recorded times shall be identical”.

 

You stated: “The reality is that helicopter flights do not end when the helicopter touches a surface, but rather “…the moment it comes to rest at the end of the flight….” as per the meaning within Subsection 101.01 (1) of the CARs. Within your scenario, “flight time” might continue while the helicopter is in contact with the surface but still under control by the pilot in command. If the intent is to not terminate the flight at this time and where there is no intent to shut down the helicopter, then the flight time should continue to be logged.” This statement tells me that the statement in COM 4.18 is not valid as per the CARs. This statement is found in most COM’s across the country and should be removed; it has led to improper interpretation of the CARs by TC inspectors and throughout the industry. We have always interpreted the definitions as you do, and have discussed removing this statement with various POI’s over the years. In all instances they were adamant that flight time and air time are the same. I can tell you that several operators do advise their pilots to use air time in their flight duty times based on this statement in their COM. I’ve been told this by many pilots from other organizations; some of these pilots now work for our organization.

 

Something that does concern me is your statement that “The CARs does not state that “flight time shall be the same as air time”, however the majority of flights conducted by commercial helicopter operators are logged as the same time.” I do not agree with this statement, I suspect if you examined the commercial helicopter industry more closely, you would find that this is not the case; In all actuality most flights do have a significant difference between Flight Time in Air Time. The commercial helicopter industry in Canada is mainly a support provider for the Natural Resource sector in Canada and most of our work entails delivery of goods and personnel to remote, unprepared landing areas. In most cases pilots have no intention of shutting down the aircraft at each landing and remain in control of the aircraft. Most flights entail several take-off and landings before the aircraft comes to rest at the end of the flight. The intent is to not terminate the flight at most of these landings and there is no intent to shut down the helicopter.

 

Although, the statement in 4.18 remained in our COM, our pilots have always logged Flight Time and Air Time (with respect to pilot logs and flight time limits) as you suggest. As stated, earlier we believe this statement is in conflict with the actual definitions in the CARS, and figured if this was ever questioned we use COM 1.1 (2) as our defence. COM 1.1(2) states “In the event of conflict (between COM and CARs), the laws of the body having legislative authority where the aircraft is being operated shall take precedence”. It is our belief this statement should be removed from all COM’s across the country and TC should clarify to the industry (as you have done for us) how they expect pilots to log air time and flight time. This statement leaves room for questions to be raised about a pilots experience level in civil litigation after an accident occurs. It is also used by some operators to ask their pilots to use Air Time when calculating their flight times.

 

I would also like you to clarify whether your interpretation should also hold true for flight training flights and records. I would like to present you one more hypothetical scenario:

 

• The chief pilot conducts a recurrent training flight with a line pilot (with 1000 hours on type). The aircraft lifts off for the first time at 1100 and throughout the flight, 15 landings (and take-offs) take place for the purpose of training circuits, sloped landings, confined areas, emergency procedures, rejected take-offs etc.

• The pilots have no intention of shutting down the aircraft or terminating the flight on any of the first 14 landings. The aircraft touches down (for the purpose of shutting down after completing all the require manoeuvres) on the pad at the hangar at 1220. (the intent is to not terminate the flight during the first 14 landings and there is no intent to shut down the helicopter until 1220)

• After the flight the pilots calculate that throughout the training flight the aircraft was in contact with the earth’s surface for 24 minutes (throughout the 14 landings mentioned above).

• The Company’s Transport Canada Approved Company Operations Manual states:

o 8.6.6 Initial Flight Training Single engine Type: (2) For pilots with more than 100 hours on type…, the minimum initial flight training will be 1 hour air time

o 8.6.7 Recurrent Flight Training Single Engine Type: (2) Recurrent flight training shall be a minimum of 1 hour flight time on each type of helicopter the pilot is assigned to fly.

 

 

1) The Flight Time for this Training Flight is 1.3 hours (1 hour 20 minutes) . Do you agree?

2) The Air Time for this Training Flight is 0.9 hours (56 minutes). Do you agree?

3) Has the operator met the minimum recurrent flight training standard (for that type of helicopter) as set out in the COM for the flight training scenario mentioned above?

 

 

Thank You,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

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Chad, thanks for pursuing this and keeping us posted. It'd be great to see some official clarification from TC!

 

DM

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Don't thank me DM, I'm just doing my job. Our pilots want clarification. We have TC inspectors giving out PVI findings that contradict what Director of Standards is telling us about the interpretation of Flight Time. This only compounds the confusion.

If you have concerns about this issue I suggest you ask your op's manager/Cheif pilot to push TC for clarification as well. TC has tried to impress upon us that we are the only people in our industry that are concerned about this issue.

Until they have clarified this issue to the industry, we feel that TC chooses to leave pilots and operators to be hung out to dry by a high priced lawyer in civil litigation. If the director of Standards can't respond to my questions about the proper way to log your hours (as they pertain to experience, flight time limits and training), how do think you'll do on the stand? This issue affects all of us no matter where or who you work for...

 

We operate under an SMS and are considered a "Transition Enterprise". The root cause analysis that we conducted when actioning this finding led us here and we are not able to close the finding until we beleive corrective actions have been implemented that address the true Root Cause; for this we need clarification from Transport and as ussual they are not able to respond in a timely manner.

We are not asking for an amendment to the CARs here, simply a clarification of the existing reg's, yet they are not able to provide one (or don't want to). Unfortunately this does nothing to promote a reporting culture amongst stakeholders and it appears that they do not wish to acknowledge that the root cause of this finding could stem from within their own organization. Lately, all the talk about SMS, has been about funding cuts and cancellation of oversight activities. The biggest issue we see, is a culture issue at TC. Attitudes need to change and they need to respond to operators concerns. It's apparent that even their own SMS (CAIRs) is not functional.

 

By the way we do feel that SMS has merit and have implemented what we bielive to be functional system that adds benefit to our organization. We also beleive that SMS will work if itis used as an added safety layer with traditional oversight and GOOD COMMUNICATION between stakeholders and TC.

 

Here is the last e-mail I sent Jacqueline two weeks ago (still no response):

 

Hi Jacqueline,

Can you advise me which "appropriate Division" of TC you forwarded my e-mail to?

In an October 19th e-mail I asked you to provide me with a time frame for a response and CAIRS Co-coordinator Melanie Nash advised me (in an Oct 20 e-mail):

" I would like to inform you that Jacqueline Booth is the accountable manager for this file. The CAIRS system provides for 20 working days for the accountable manager to provide a response.

I will continue to track the response to your email."

On October 21, 2011, you advised me that you had forwarded my e-mail to the "appropriate Division" for review and you would have an answer for me within a couple of weeks.

Since my e-mail sent September 26, 2011, 31 I have waited 31 working days and since your October 21/11 e-mail "a couple of weeks" have gone by, yet still no response.

 

At the risk of sounding like a broken record, once again, here is what we would like to see happen:

 

1) the PVI finding removed if invalid or;

 

2) If we are advised, that it is indeed valid (with a reasonable explanation), we should be permitted to resubmit the PVI CAP stating that the root cause was "confusion throughout the industry and TC". This confusion was created by Transport Canada; therefore the Corrective Actions should be carried out by Transport Canada.

---Based solely on the fact that the director of standards and headquarters are not able to give us a clear answer (within a reasonable time), I think I've proven that even TC does not have a good grasp or understanding of the regulation and how it should be applied.

---It is likely that inspectors have been applying their own varied interpretations to operators across the country, which has in turn compounded the confusion.

---I also have written responses from various divisions of TC (and TC employees) giving conflicting information

-- I am aware of several commercial operators that have approved COM's that conflict with the regulations with respect to this interpretation.

 

3) I would like to see formal clarification to the aviation / helicopter industry for the following reasons:

 

- this confusion is industry wide and has serious implications to aviation safety (pilots /operators are using air time when calculating Flight time limits; confusion with regards to a pilots experience and training standards)

 

-Pilots and Commercial Operators are at risk of litigation and denial of insurance coverage in the event of an accident as long as this type of confusion exists. Until this issue is cleared up, Training records, Pilot experience and Flight Time records (with respect to fatigue) will be questioned by lawyers.

 

-The standards need to be applied equally to all operators to ensure a fair competitive industry whereby the standards are applied consistently among operators. Operators using Air Time to monitor limits will have a competitive edge at a reduced level of safety (higher risk due to increased likelihood of fatigue).

 

4)I would like to see the statement in COM that states "Flight Time and Air Time are the same" removed from all COM's across the country (including ours) if it is not accurate (as the director of standards clearly states in her first e-mail response). We agree with the interpretation of flight time as stated in the Director's September 20/11 e-mail, which is in conflict with this interpretation, the statement in the COM and our Recent PVI finding.

 

We are in discussions with our legal counsel with regards to using other avenues to rectify this issue. If at any point we encounter litigation issues due to this confusion, we shall most certainly do everything we can to ensure that Transport Canada (and each individual TC employee/division) who gave us incorrect guidance and/or in most cases, refused to offer guidance will be named in such lawsuit. I think the general public (and most certainly a jury) would find this complete lack of response from the governing authority for aviation in Canada to be an eye-opener.

 

Regards,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

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