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Flight Time Vs. Air Time Personal Logbook

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For those who are interested in compliance, attached is the Draft Advisiry Circular 700-052 - Recording of Flight Time for Skid-Equipped Helicopters 

The AC has been under development for more than a year.

E-mail received today:

Please note we extended the comment period at the request of industry associations and members.  We will soon initiate a full review of comments and proceed from there as expeditiously as we can.

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:robert.sincennes@tc.gc.ca
Transport Canada | Transports Canada
330 Sparks St
Ottawa (Ontario) K1A 0N5

Government of Canada | Gouvernement du C

RDIMS-#14731047-v3-AC_700-052_-_RDIMS-#14407279-V3-RDIMS-#14121971-V1-FL....pdf

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On 1/19/2019 at 7:55 AM, Freewheel said:

I’m not sure that this method is “extremely belaboured,

Freewheel, « belaboured » is 71 pages of « huh?????? %&$#@+!!!!!!!! » vs no further comment possible if Canada simply respects the ICAO definition of helicopter flight time « rotors turning to rotors stopped » as per our agreement to adhere to ICAO Standards.

The problem is, if TC admits to the ICAO definition of  «helicopter flight time»,  they will then have to deal with TC 100hr commercial helicopter license vs ICAO 150 hr commercial helicopter licence.

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3 hours ago, Brian Jenner said:

Freewheel, « belaboured » is 71 pages of « huh?????? %&$#@+!!!!!!!! » vs no further comment possible if Canada respects the ICAO definition of helicopter flight time « rotors turning to rotors stopped ».

The problem is, if TC admits to the ICAO definition of  «helicopter flight time»,  they will then have to deal with TC 100hr commercial helicopter license vs ICAO 150 hr commercial helicopter licence.

Oh there’s no doubt their handling of this issue since 2011 has been extremely belaboured. I just meant the process described in the AC is not al that belaboured.

I also understand that the ICAO licensing requirements are 150 hours vs. canada’s 100 hrs, and that we signed on to harmonize our requirements...but do you really believe that would happen? I’m not saying it shouldn’t, just wondering your thoughts on this....

Answer this: When you were President of the HAC and met with TC in 2005 to discuss this very issue, was that REALLY your intent...to have minimum commercial licensing requirements increased to 150 hours?

I don’t recall you ever stating that back then....

Was GAPL 2005-02 not  the result of those very discussions ? It was in play for 6 years after that...but I never heard anyone discussing this increase to licensing requirements...not from you...not from TC...NOT FROM ANYONE. It certainly wasn’t written in the Policy Letter.

With that being said most people at TC Standards, HQ AND/or Ontario region never acknowledged that document as legit. In fact, those that did, tried to stipulate that it ONLY applied to licensing through Flight Training Units. In fact, recently my POI tried to tell that might be the case with this new guidance material. Who knows...it still might end up that way, given this is a draft. That’s quite odd given what you’re saying now...don’t you think? 

We all know that the CARs as written doesn’t allow for flight time to be interpreted differently from one regulation to the next. Our licensing requirements are lower than ICAO, yet the only stakeholders who were to benefit from GAPL 2005-02 were those companies who provided training towards a licence. At the risk of sounding like a conspiracy theorist...it sounds unethical.

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Thankfully they are implementing the ICAO definition. That is the whole issue, FROM FIRST IN MOTION, to COMES TO A STOP AT END OF FLIGHT.

That. That is the only thing that means anything. And what most people argues has been correct. Except a few stalwarts within TC who just couldn't

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On 2/12/2019 at 3:53 PM, Brian Jenner said:

Freewheel, « belaboured » is 71 pages of « huh?????? %&$#@+!!!!!!!! » vs no further comment possible if Canada simply respects the ICAO definition of helicopter flight time « rotors turning to rotors stopped » as per our agreement to adhere to ICAO Standards.

The problem is, if TC admits to the ICAO definition of  «helicopter flight time»,  they will then have to deal with TC 100hr commercial helicopter license vs ICAO 150 hr commercial helicopter licence.

Here’s what your successor at the HAC had to say about the new Draft Advisory Circular. 

http://mediaedgedigital.com/supplierinsights/hac/flight-time-v-air-time

The communique was circulated yesterday. and asks for comments from members; apparently the deadline for comments was extended until today. That doesn’t give much time to comment but members are asked to submit comments to fred.jones@h-a-c.ca.

No mention of Canada’s reduced licensing requirements vs. ICAO licensing requirements.

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7 hours ago, Freewheel said:

Here’s what your successor at the HAC had to say about the new Draft Advisory Circular. 

http://mediaedgedigital.com/supplierinsights/hac/flight-time-v-air-time

The communique was circulated yesterday. and asks for comments from members; apparently the deadline for comments was extended until today. That doesn’t give much time to comment but members are asked to submit comments to fred.jones@h-a-c.ca.

No mention of Canada’s reduced licensing requirements vs. ICAO licensing requirements.

Frewheel I don't quite get what you are trying to say (read into what I have said)  but, although I am loath to add another line to the 71 pages, just to make sure that no one misunderstands my opinion I offer the following clarification: 

1) as President of HAC both Fred and I express(ed) Association opinion not personnal opinions (that is not to say they are different but rather if there is a difference, perceived or real, you can not hold me personnally to opinions expressed by me as HAC President);

2) in my personnal opinion (something I could not say as HAC President even thought it was obvious to me at the time) Canada has long proven that 100hrs (rotors turning to rotors stopped) is quite sufficient to train commercial helicopter pilots;

3) in my personnal opinion, what you are up against is an issue that has always come from within TC Flight Training Standards Branch and “in my personnal opinion” TC opinion has always been well intentionned but misguided, inspirred by the unfounded/factually disproven argument that Canada's minimum flight time for commercial helicopter licensing is already too low;

4) in my personnal opinion, the only support for the opinion of some/most Flight Standards inspectors opinion on this subject is the fact that Canadian flight trainning minimum flight time does not in fact respect the ICAO Standard.

 

 

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3 hours ago, Brian Jenner said:

Frewheel I don't quite get what you are trying to say (read into what I have said)  but, although I am loath to add another line to the 71 pages, just to make sure that no one misunderstands my opinion I offer the following clarification: 

1) as President of HAC both Fred and I express(ed) Association opinion not personnal opinions (that is not to say they are different but rather if there is a difference, perceived or real, you can not hold me personnally to opinions expressed by me as HAC President);

2) in my personnal opinion (something I could not say as HAC President even thought it was obvious to me at the time) Canada has long proven that 100hrs (rotors turning to rotors stopped) is quite sufficient to train commercial helicopter pilots;

3) in my personnal opinion, what you are up against is an issue that has always come from within TC Flight Training Standards Branch and “in my personnal opinion” TC opinion has always been well intentionned but misguided, inspirred by the unfounded/factually disproven argument that Canada's minimum flight time for commercial helicopter licensing is already too low;

4) in my personnal opinion, the only support for the opinion of some/most Flight Standards inspectors opinion on this subject is the fact that Canadian flight trainning minimum flight time does not in fact respect the ICAO Standard.

 

 

Thank you for clarifying Brian. I’m not trying to read anything into your statements. Despite the fact you loath responding, you continue to bring up the ICAO minimum requirements (multiple posts).. I was just wondering your personal opinion On the matter because of your posts.

1) no comment

2) agreed. then a  risk assessment should easily demonstrate an equivalent level of safety (in accordance with TCs own national objectives (and ICAOs)).

3) agreed. That’s why we directly challenged the the Chief of Standards and Director of Standards...the result is this AC.

4) Agreed.. but even the interpretation offered in this AC is a significant change from Flight time = Air time in that respect. Start and shut down for most operators and  FTUs is less significant than the time spent on the ground on intermediate landings. I think Fred’s estimate of 10% difference between flight time and air time is at the low end of the spectrum. Start and shut down might account for 10% (as stated in the TC AC). The multiple landings on many flights accounts for a larger percentage. This is really evident when you use something like an Aerodyne system which calculates air time with a squat switch on the skid gear. Given this fact we have increased the difference between ICAO and Canadian licensing requirements with this AC.

Have  a nice weekend Brian

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On 2/12/2019 at 9:59 AM, Freewheel said:

 

For those who are interested in compliance, attached is the Draft Advisiry Circular 700-052 - Recording of Flight Time for Skid-Equipped Helicopters 

The AC has been under development for more than a year.

E-mail received today:

Please note we extended the comment period at the request of industry associations and members.  We will soon initiate a full review of comments and proceed from there as expeditiously as we can.

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:robert.sincennes@tc.gc.ca
Transport Canada | Transports Canada
330 Sparks St
Ottawa (Ontario) K1A 0N5

Government of Canada | Gouvernement du C

RDIMS-#14731047-v3-AC_700-052_-_RDIMS-#14407279-V3-RDIMS-#14121971-V1-FL....pdf

That does it, for sure. Layman's take is if your primary attention has to be on the aircraft, it's flight time. If you're ground idling and able to update your instagram, it's not.

At a certain point it becomes superfluous, and generally you'll find more respect reporting air time, as that's the only time you're improving as a pilot. I personally have three columns in my excel logbook; air time, bill time, engine time. Billing time coincides with the TC definition of "Flight", it requires more than my peripheral attention as a pilot to prevent something untoward occurring. 

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