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Important - Tc Releases Draft Of New Flight Duty Time Regulations

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All valid points Brian, but if you look back at my other post, my argument all along has been that the helicopter portion of the aviation industry has been all but ignored during this process. I'm not going to get into a protracted argument about what version of the rules produces a safer environment, because theoretical situations and statistics can be shown to prove whatever result you want.

 

The industry won't magically have everyone working a 2 and 2. How will it reduce my pay? Simple. On a 2 and 2 vs. 3 and 3 from May 1st to Aug 31st I get an extra week of work on the 3 and 3 schedule. The lucky few? Under the proposed regs, the lucky few will work an even time schedule, the unlucky will continue to be so and take the mandatory minimum days off in camp and have to be double crewed.

 

Communication is key to any relationship, and right now we haven't been communicated with, rather, we are being dictated to.

 

Kevin McCormick

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All valid points Brian, but if you look back at my other post, my argument all along has been that the helicopter portion of the aviation industry has been all but ignored during this process. I'm not going to get into a protracted argument about what version of the rules produces a safer environment, because theoretical situations and statistics can be shown to prove whatever result you want.

The industry won't magically have everyone working a 2 and 2. How will it reduce my pay? Simple. On a 2 and 2 vs. 3 and 3 from May 1st to Aug 31st I get an extra week of work on the 3 and 3 schedule. The lucky few? Under the proposed regs, the lucky few will work an even time schedule, the unlucky will continue to be so and take the mandatory minimum days off in camp and have to be double crewed.

Communication is key to any relationship, and right now we haven't been communicated with, rather, we are being dictated to.

Kevin McCormick

Kevin, you are of course quite right, helicopter pilots were not represented on the FDT working ground. They won't be represented on the next one either. And operator associations chose to play for and continue to play for double or nothing. But you now have a chance to offer your input and it does have a chance of influencing the final product, provided it is clear, focussed and justified.

 

If in your comments on NPA 2014-019 you cry about the spilt milk, you will be ingnored; if you demand they start over again, you will be ignored; if you try to make all the arguments you would have made, had you been at the table for all those weeks of heated debate, you will be ignored; but if you propose, practical adjustments, to the most important shortcoming of the proposed new FDT regulations, you will be heard; if your proposal does not comme at significant cost to others, you may very well succeed in changing the rules.

 

That's why my comments were limited to the two things I perceive as essential to improving the proposal: no days off away from home; no increasing of flight time limits for helicopters, by substituting air time for the ICAO definition of flight time.

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The industry won't magically have everyone working a 2 and 2. How will it reduce my pay? Simple. On a 2 and 2 vs. 3 and 3 from May 1st to Aug 31st I get an extra week of work on the 3 and 3 schedule. The lucky few? Under the proposed regs, the lucky few will work an even time schedule, the unlucky will continue to be so and take the mandatory minimum days off in camp and have to be double crewed. /quote]

 

There will be nothing magical about the results. The present law requires you ge given 5 days off in 42 - you get 3X3. If the new law requires everyone get at least 5 days off, at home, in 20 days, it seems likely that you will get 2X2. All helicopter pilots win, with the exception of your week of lost time every summer. You can't make an omelette with out breaking eggs. Your loss seems pretty small to je, who gave up flying because in my day operators 'tried' to maintain 8X2.

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Brian perhaps you need to come up for air. Kevin's schedule may be fine for Kevin, but it is far from "normal". Perhaps check the operator's directory for the number of single ship operators in Canada. Your down the nose look at the industry is not appreciated.

 

How do you propose the numerous single ship people who make a living flying 300 hours a year to make it if they have to do the 2 x 2 schedule?

 

How in ell are they going to regulate the "no days off away from home"? My lanta, I have seen numerous pilots take days off away from home,,,,in Mexico one of our guys brought his family there for his time off at the beach. Get special approval from TC to take your days off away from home. What if you leave your home to go on days off,,,oh my...Rediculous. You said it yourself, if you want to make a change then it should be done "realistically".

 

My guess is that you are here now only to stir things up and get the various opinions in the open the similar fashion as the local newspaper getting the locals fighting to read the rag. Start reading and listening to what is written with an open mind, as this is an open forum and you will reap what you sow.

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Brian perhaps you need to come up for air. Kevin's schedule may be fine for Kevin, but it is far from "normal". Perhaps check the operator's directory for the number of single ship operators in Canada. Your down the nose look at the industry is not appreciated.

 

How do you propose the numerous single ship people who make a living flying 300 hours a year to make it if they have to do the 2 x 2 schedule?

 

How in ell are they going to regulate the "no days off away from home"? My lanta, I have seen numerous pilots take days off away from home,,,,in Mexico one of our guys brought his family there for his time off at the beach. Get special approval from TC to take your days off away from home. What if you leave your home to go on days off,,,oh my...Rediculous. You said it yourself, if you want to make a change then it should be done "realistically".

 

My guess is that you are here now only to stir things up and get the various opinions in the open the similar fashion as the local newspaper getting the locals fighting to read the rag. Start reading and listening to what is written with an open mind, as this is an open forum and you will reap what you sow.

 

My guess is you have your head turned back with your mouth open ready to receive the next "shove" - as in "TC shoving new regulations down our throats".
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Pretty petty shot at Paul there Brian, when all he did was offer a very valid reason as to why the new regs would harm many. Another indicator that Transport doesn't give a crap, no matter how many nice individuals work there. Paul and I are of different opinions as to what is acceptable, but I never disrespect him personally because of that.

 

This thread needs to stay on topic and not disintegrate into a slander-fest. Some of the opinions here are very valuable and could assist others in their potential submission to the great powers in Ottawa, so best to keep it factual and avoid the personal attacks.

 

Kevin McCormick

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Pretty petty shot at Paul there Brian, when all he did was offer a very valid reason as to why the new regs would harm many. Another indicator that Transport doesn't give a crap, no matter how many nice individuals work there. Paul and I are of different opinions as to what is acceptable, but I never disrespect him personally because of that.

This thread needs to stay on topic and not disintegrate into a slander-fest. Some of the opinions here are very valuable and could assist others in their potential submission to the great powers in Ottawa, so best to keep it factual and avoid the personal attacks.

Kevin McCormick

And you say that to me! I have never done anything but keep things factual and impersonnal, which can not be said of Paul's comments about me, which follow a long standing tradition of people who attack the messenger, when you don't have an inteligent response to the message.

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Then how about looking at our industry with what it is today. There is a glut of helicopters with almost all companies trying to stay alive. It is pretty easy to say the established companies with work are so much smarter as there was a huge requirement for helicopters before 2009, this is an undeniable fact. The excess work that was done at that time was not able to be done by the existing number of helicopters. Would it have been any better or safer to have the larger companies expand and increase their fleets? I doubt it. but here we are now and that is that. In the "old" days customers would have had to wait for the industry to ramp up to handle the extra load, but today with the money available, aircraft available and good crews, things happened fast. The safety standards were for the most part held up to standard that were in place. Not many perceived the fall in the WORLD economy caused by the the corruption of bankers and wallstreet. There are too many aircraft for the work at this time. Margins are slim with almost all customers. The forest service rate by Alberta is the highest I know of. I lost work to a company two years ago over price and now I hear that that company just lost the contract to yet someone cheaper yet. Yet you feel that the "35%ers" are grossly exaggerating the cost of the proposed regs. I really doubt that you know the margins of most companies and have zero faith in what you are putting down in posts as to having done any research on. So you say what you post is factual but yet I do not believe this, but this is not something that is bad as this is public forum. Your opinion here has no affect on any outcome of policy. But your opinion is just that. If you believe this is an outlet for your opinion you are not wrong. But this is a two way street and everyone is on an equal playing field. This forum is a place where a pilot can say crappy things about a company that abuses them as long as there is no slander, excellent. If you don't like my post, it does not bother me, many have not. But that does not stop me from providing my opinion for what it is worth. Pilots have long been misrepresented by some and some of those pilots are owners too. I love to see other's opinions such as Kevin's but I realize that his opinion is based upon his view. Each is fine. I have respect for the industry and complete distaste for those who do not appreciate how it got to this point and what it is today.

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Oh and thanks for the editing the post-post post about the shove.....not really how I got it the first time reading re re tc shoving the next reg down my throat.

 

We did the old "I think this is the way it should be" before here and it became rather complex. But you seem to think that is what we should be doing. So, I say stick with the rules as they are now with the exception of working 42 days straight and duty day length. Make it 3 in 30 with a max of 35 then take off 4. Duty day of 12 with 2 more hours for travelling/prep. All other regs unchanged. The proposed is too complicated and inference to similar rules to airlines is bogus. One does not need a bargeload of garbage labelled as science to sift thru to realize that the stress of determination of legality will be an unsafe stressor to the job.

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Oh and thanks for the editing the post-post post about the shove.....not really how I got it the first time reading re re tc shoving the next reg down my throat.

 

We did the old "I think this is the way it should be" before here and it became rather complex. But you seem to think that is what we should be doing. So, I say stick with the rules as they are now with the exception of working 42 days straight and duty day length. Make it 3 in 30 with a max of 35 then take off 4. Duty day of 12 with 2 more hours for travelling/prep. All other regs unchanged. The proposed is too complicated and inference to similar rules to airlines is bogus. One does not need a bargeload of garbage labelled as science to sift thru to realize that the stress of determination of legality will be an unsafe stressor to the job.

Sorry Paul, if my "shove" seemed vulgar - such misunderstandings are an unfortunate danger of posting - luckily Kevin's uncaracteristically caustic reaction gave the signal that I may have mis-communicated my Opinion as to your previous post.

 

As for your opinions as to how to correct the FDT proposal, I can only hope you send thenm to CARAC since in the absence of representation specific to one aircraft operations, your opinion is all they have or not. That being said I don't think there is much of a chance for that much massaging at this late stage of the consultative process.

 

On the hopeful side, taking the long vue, which will not impress your Banker in the short run, the new Part 8 regulations would gove regulatory authority and obligation to long stating good intentions on the part of TC toward adaptive regulation based on principles of SMS. It will remain to be seen and will come at some considerable cost in terms of effort on the part of industry and TC, but dealing with individual imperatives, realities and needs should be possible based on FRMS. I say again, it will not be easy and dertainly not fast but possible, in theory.

 

Now that may not be of any concellation to operators such as yourself but given my personnal pessimism with regard to the probability of turning the regulatory machine around, what else can you do but hope that together, you + TC + your association will make the best of an imperfect system.

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