Important - Tc Releases Draft Of New Flight Duty Time Regulations

[2007]

Change is coming......

 

So now the HAC is going to "strongly object?" - What are the new points being covered now that weren't addressed over the last two years? The owners club is obviously getting a little nervous

 

I wonder how helicopter pilots in Finland, Sweden, Norway, Iceland, Alaska, etc. manage to make any money working in their wilderness areas?
They are all operating with more restrictive FDT limitations than the "new" proposed rules for Canada.

Pretty sure these countries have all seen diamond drills.

 

Sleep in your camp if that turns your crank - but perhaps you may want to look at working 8 on, 8 off or something more pilot friendly.

 

You will have two years to educate your customers.

 

R0T0R - absolutely not!

[Freewheel]

".. So, if the new rules are to provide a level playing field "single day free from duty" will need to be ammended, to inlude something to the effect that the "single day free from duty" can't be given in a bush camp or a 5 star hotel of the operator's choosing i.e "single day free from duty" means a time free from all duties and free from any practical requirement to be away from home base ...."

Since you brought up "Home Base", I'm hoping you will indulge me with a conversation about the new proposed Definition for "Home Base": means the location nominated by the operator to the crew member from where the crew member normally starts and ends a duty period or a series of duty periods and where, under normal circumstances, the operator is not responsible for the accommodation of the crew member concerned.

 

To me, it sounds like most drill camps would be considered "Home Base", while my actual "Home Base" might not be.

 

On most of our jobs, the client signs a contract that states the client is responsible for pilot accomodations (single occupancy when available); whereas, most of our helicopter pilots who are at main base stay at accommodations provided by the operator (in the local crew house).

 

Of the 25 pilots employed at our organization, I have one pilot (other than the C.P. and Operations Manager) who actually live in the same community as our "Home Base"; the rest are scattered throughout Canada (and elsewhere) and flown to job sites.

[Brian Jenner]

The potential for arguing the merits of any give FDT regime is endless. But when push comes to shove, like the proposed new FDT rules or not Canada has signed a treaty whereby it has agreed to abide international standards. So, screaming and bitting operator associations notwithstanding, the best anyone can do is encourage TC to translate the international standards into Canadian, eh.

 

Having served in the FDT wars of 1987, 1992 and 1994/1996 I lose no love over the prima donnas from ALPA. Nor do I have any respect for those operators, who have forced regulations on the entire industry because they lack regard for anything but unfettered profitability.

 

That being said, in the name of minimal interference with the reasonable majority, the present regulations give free rein to abuse by a minority of operators - the new regulations would make everyone prove they have a better way of reaching safety objectives while making the abusive minority toe the line. That is the price to pay, for having everyone respect their employees and their competitors.

 

The new system will be a pain for the majority of operators who don't need regulations to do things right in the first place; but it will do no significant economic harm to the industry.

 

In spite of all the operator associations crying wolf, the cost of establishing internationally recognised safety standards is nothing, compared to the other cost increases regularly absorbed by industry, without disastrous consequences. On the contrary, although, in the last 30 years the price of helicopter services has increased approximately 4 fold, the demand for services rose steadily.

 

Pilots will not suffer financially from the new rules either. Business is business now and forever. Pilots are paid and will continue to be paid what the market values their services at. That has more to do with availability than productivity. On that basis, if industry suddenly needs more pilots, relative scarcity will put upward pressure on pilot wages, especially for the best. But don't get your hopes up, unlike the price of helicopter services, pilot wages will not quadruple anytime soon - the increased demand for pilots under the new regulations is grossly exaggerated by operator associations; and the matter of supply a simple function of "where ther's a will, there's a way".

 

In practical terms, I find the new regime has little to genuinely worry about, from any point of view - except days free from duty - commonly referred to as days off.

 

Flight duty time rules and short term flight time limits seek to mitigate the accumulation of acute fatigue. Rest periods are should normally cure any accumulated acute fatigue. Long term flight limits and days off are meant to prevent and/or relieve chronic fatigue.

 

Under the present rules the 5 continuous days off, in 42, encourages operators to bring crews home, once in a while (I know its not much but its there). Under the new rules, bringing crews home for 5 consecutive days, every 2 weeks, would be a great but will all operators do it.

 

The cost of a trip home every 42 days is offset by the increased productivity operators achieve during the shift. However, at once every 2 weeks, the productivity advantages no longer out way lost the cost of a trip home - the trip home now becomes a considerable net lose.

 

While under the new rules the enlightened majority of operators will likely adopt a 2/1 or 2/2 schedule, some operators will no doubt seek to increase profits by giving pilots a day off away from home, once a week. That's not good for a pilot's love life or for the competitive balance between operators.

 

So, for my part, I will be exercising my right to comment on NPA 2014-019 by suggesting TC change the new definition of "single day free from duty" to:

 

"single day free from duty" means a time free from all duties and free from any requirement to be away from home base ...

 

Rather than running around the country crying wolf from every tribune, industry associations would do their members better, if they too stopped trying to block the coming regulations. Their energy would be more productively spent trying to massage the new regime, so as to facilitate the use of industry standards in the adoption of operations specifications, that are objectively necessary and of an equivalent level of safety

[Brian Jenner]

Since you brought up "Home Base", I'm hoping you will indulge me with a conversation about the new proposed Definition for "Home Base": means the location nominated by the operator to the crew member from where the crew member normally starts and ends a duty period or a series of duty periods and where, under normal circumstances, the operator is not responsible for the accommodation of the crew member concerned.

 

To me, it sounds like most drill camps would be considered "Home Base", while my actual "Home Base" might not be.

 

On most of our jobs, the client signs a contract that states the client is responsible for pilot accomodations (single occupancy when available); whereas, most of our helicopter pilots who are at main base stay at accommodations provided by the operator (in the local crew house).

 

Of the 25 pilots employed at our organization, I have one pilot (other than the C.P. and Operations Manager) who actually live in the same community as our "Home Base"; the rest are scattered throughout Canada (and elsewhere) and flown to job sites.

At first glance I had similar misgivings Freewheel. Then I read again and again... "Home Base" is a place where the operator does not normally supply accommodation.

 

One tends to think the definition should be made clearer. Unfortunately the quest for clarity, precision unequivicallity often creats more loopholes than it closes.

 

Without getting paid to masage that definition into pefection I tend to think it reflects the regulatory objective rather well. But then again, maybe I nead to read it again....

[Brian Jenner]

Unfortunately, since you are not part of the airline association (just a Heli pilot), TC and the working group will likely ignore what you are saying. And herein lies the problem. They are not following their own principles of rule making. That is the biggest problem in transportation safety and regulations today: TC not following Their own rules. This is just one little example of issues with these rules; they should all be scrapped and they should start over. They were created contrary to their principles of rule making and their own mandate (and therefore have not taken all risks and hazards into account). Isn't that one of the reason the CARAC process was created?

I think you are being a bit too hard on them - in medio stat veritus - the truth of the matter is somewhere between where they are and where you want to be. One thing for sure! They will not be starting over!

 

Hence, it is time to read carefully and propose ammendments that can be accepted. If we do they will. Otherwise we will be condemmed to enduring what others imposes upon us!

[Skidz]

I split the topic from the petition discussion. I was getting PMs from people who were getting confused...

[Brian Jenner]

I just noticed that in their newfound fever for, respecting Canada's treaty obligations to adopt ICAO standards, TC's FDT NPA includes adopting the ICAO definition of "flight time".

 

Not much different from the present CARs definition of flight time but, noblesse oblige, you gotta do what you gatta do, under the treaty!

 

Did I mention the new definition of flight time will be word for word the ICAO definition of flight time ... for aeroplanes!

 

With 34 pages on this Forum, dedicated to arguing over what constitutes "flight time" for helicopters, why doesn't NPA 2014-019 include the adoption of the ICAO definition, for helicopters, word for word:

 

"Flight time helicopters

 

The total time from the moment a helicopters 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."

 

Keep sending those cards and letters to TC. You have until October 3rd to let them know what the helicopter ondustry thinks of adopting ICAO standards.

[Freewheel]

I just noticed that in their newfound fever for, respecting Canada's treaty obligations to adopt ICAO standards, TC's FDT NPA includes adopting the ICAO definition of "flight time".

 

Not much different from the present CARs definition of flight time but, noblesse oblige, you gotta do what you gatta do, under the treaty!

 

Did I mention the new definition of flight time will be word for word the ICAO definition of flight time ... for aeroplanes!

 

With 34 pages on this Forum, dedicated to arguing over what constitutes "flight time" for helicopters, why doesn't NPA 2014-019 include the adoption of the ICAO definition, for helicopters, word for word:

 

"Flight time helicopters

 

The total time from the moment a helicopters 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."

 

Keep sending those cards and letters to TC. You have until October 3rd to let them know what the helicopter ondustry thinks of adopting ICAO standards.

As I said before, they only listened to the airline pilots...despite the fact the associate director of operations admitted confusion with flight time for helicopters and committed to lead an initiative to clear the confusion amongst TC inspectors and for industry...and a CAIRS was filed. They are in bed with the airlines and their is no integrity. I will be filing a report with public sector integrity commissioner. Borderline corruption.

[Freewheel]

Just came from an airbus conference, where a former Transport Canada inspector (who quit not long ago ) told me Flight Time = Air Time in Quebec Region. (For skid Heli)

[Brian Jenner]

As I said before, they only listened to the airline pilots...despite the fact the associate director of operations admitted confusion with flight time for helicopters and committed to lead an initiative to clear the confusion amongst TC inspectors and for industry...and a CAIRS was filed. They are in bed with the airlines and their is no integrity. I will be filing a report with public sector integrity commissioner. Borderline corruption.

About 15 years ago, I went to them with a power point presentation explainning, the long way, why helicopter flight time must be based on rotors turning. They issued a an AC that, for many years p, essentially adopted the ICAO definition of flight time for helicopters.

 

That just goes to prove "they" listen, provided someone speaks ... The right language, to the right people, at the right time.