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OGEgirl

Flight Time Vs. Air Time Personal Logbook

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13 hours ago, Bif said:

Well, it's progress

I have yet to see any evidence that TC is able to have a coherent discussion on the subject, let alone progress....

We shall see...

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 We received a copy of the Draft Advisory Circular, AC 700-052 – Recording of Flight Time for Skid-Equipped Helicopters.  This draft has been sent out to the Associations as well for a comment period before it is finalized and released.

In its current state the Advisory Circular does not state that Flight Time is the same as Air Time for skid equipped aircraft.

in a nutshell, It states Flight Time is from the first take-off to the last landing. Time spent on the ground during subsequent intermediate landings without shutting down shall continue to be logged as Flight Time.

Excerpts:

“Flight time ends when the skid-equipped helicopter contacts the supporting surface and shutdown actions are initiated by the pilot such as when the collective is fully reduced to the minimum position and moving the throttle(s) from the flight to idle position. The term “comes to rest” has been purposely selected in the definition, rather than “landing”, because “comes to rest” is interpreted to mean the chosen place for shutdown, or where no further flight is intended. In most cases, the shutdown sequence particular to the type will commence at this juncture; any or all intermediate stops where the pilot remains at the controls is to be included in the logging of flight time subsequent to the first take off”.

“Air time as defined in the CARs is quite clear in its intent.  It is simply the time in the air and is used primarily for technical component record keeping. However, there are exceptional operational circumstances that helicopter pilots must address. In some operations, helicopter pilots may have to hold their position involving partial ground contact by means of power and control inputs. Examples include toe-in operations, slope landings, hover exit with one skid in ground contact, or landing on surfaces that will not support the weight of the aircraft like deep powder snow, swamps or string bogs. In these cases, the pilot continues to literally fly the helicopter in position by manipulation of the controls and engine power lever(s) or throttle(s) set to the flight detent.  This time should be logged as air time rather than flight time and applies whenever the aircraft is in partial ground contact, but has not securely landed.  Anytime the helicopter position is maintained solely by aerodynamic forces and pilot control inputs cannot be construed as a landing. More simply stated, – if you can’t lower the collective to the minimum stop and reduce the engine(s) to idle, you have not landed”. 

Comments?

 

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Doesn't need to be overcomplicated as in typical Transport fashion!     Could be simplified by stating................... from takeoff until final landing for the purpose of shutdown.   

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On 1/15/2019 at 11:43 AM, Torque Split said:

Doesn't need to be overcomplicated as in typical Transport fashion!     Could be simplified by stating................... from takeoff until final landing for the purpose of shutdown.   

It’s 9 pages with Appendix A and B

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18 hours ago, Brian Jenner said:

Besides being extremely belaboured, it is inconsistent with the quite simple ICAO standard definition of “helicopter flight time”, to which Canada has not filed an exception.

I’m not sure that this method is “extremely belaboured”, but I agree it is inconsistent with ICAO.  

TC seems more concerned with inconsistencies between the method  Helicopters and aeroplanes use to log flight time. I don’t know about you, but I think the root cause of this whole mess was TCs failure to recognize there are very few consistencies between aeroplane and helicopter operations. The old “One size fits all” approach. Oh the irony...

Additional  excerpts from the AC.

Using the ICAO definition for flight time - helicopter which includes an allowance for rotors turning to rotors stopped introduces a significant discrepancy between aeroplanes and helicopters because aeroplanes do not record start up and shut down times as flight time.”

“TC determined the existing CARs definition of flight time was more appropriate to ensure regulatory compliance by flight students, pilots, and air operators with the intended personnel licensing requirements.  This would also ensure consistency by logging flight time in both aeroplanes and helicopters the method in accordance with the existing common standard. Subsequently, the GAPL was cancelled in 2009 and the Notice of Proposed Amendment (NPA) withdrawn. “ 

its also inconsistent with their own interpretation of aircraft “in operation” in the Canada Labour Code. Both definitions use the same terminology, so it’s likely the intent of the drafters was for Flight time to be consistent with the time an aircraft is “in operation”. I believe it is for aeroplanes....but apparently not for Helicopters. Yet another inconsistency between aeroplanes and Helicopters...TC AOHS and ESDC interpret a Helicopter as being in operation any time the rotors are turning for the purpose of taking off.

its also inconsistent with current case law (Wildcat v Ellis).

As I understand it, courts are bound by intent and case law, when  statutory law is ambiguous. Question is, does Guidance Material trump both?

On the flip side, it’s still a compllete 180 from Flight Time = Air time. The time spent on the ground during intermediate landings dwarfs the time spent starting and shutting down industry wide..

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After 70 pages of "Hogwash", why are airlines using miles that never change, between A & B  for log book enteries converted to air time, depending on the knots of the particular aircraft. Mileage Rate has been accepted for Fixed Wing aircraft since tariffs came into effect. 

The only rate that is in question is the hourly rate charged by both Fixed Wing and Rotary Wing aircraft. The only charges applicable is when said a/c takes-off and returns for it's final landing.

Manufacturers have stated that there is no STRESS on any a/c idling on the ground or taxing. 

Air Time (Stress Time) is the only time to be entered in the Technical Log.

As I have stated before operators have control of "Air Time" which becomes a cost factor in relation to the life of the a/c and the components attached.

When doing an Audit its easy to confirm the invoiced hours against the Tech Log entry are the same.

Flight Time is only applicable to aircrew and has nothing to do with overhaul or life of the aircraft or components.

When I was Audting on behalf of PWGSC (after completing a Transport Canada Audit Course) I visited just about every opertor in Canada doing business on a contracting basis with the Feds.

I also worked with Export Development Corporation and USAF Audit Team from Scott Airforce Base, auditing all Canadian Airlines doing business transporting American contractors or personnel.

One thing the USAF taught me was if they were not happy a company, they were put on notice and not used. In actual  fact one company was put on notice after they had been visited by Transport Audit from Moncton two days prior to our arrival. Needless to say they were slightly embarrased, when I informed them of our findings.   

The whole system of Transport Civil Aviation needs a complete overhaul and get some people in there that care about avaition and not writing a two page memo on something that can be said in a paragraph.

Use the "KISS" principal and enforce it  

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