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Ye Olde Flight Time Debate


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#21 helonorth

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Posted 22 September 2016 - 14:07

Don't forget about the "50 engine failures". Probably 60 by now.



#22 Nearly Retired

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Posted 22 September 2016 - 14:28

SPOILER ALERT! 

 
First of all, I was not going to mention it, but the POI who modified Becky Whatserface’s pilot flight time policy for helicopter pilots works in a FSDO in the New York  City area, and he oversees a large, busy 135 NYC charter and tour operator.  So he’s not some rogue, renegade FAA inspector in Wyoming or someplace where no one lives and no one cares.
 
Secondly, I will not further undignify Avbug’s response to me, for it is already as undignified as it gets.  Avbug really is a piece of work.  I do enjoy reading the Reverend Father Pastor Doctor Avbug, Esq’s spluttering though.  I imagine him sitting at his computer, all red-faced and huffing-mad, pounding away at his keyboard as if it were one of those old manual Smith-Corona typewriters and he was a cub reporter at the Sacramento Bee who just discovered that the mayor was pocketing funds from the downtown parking meters.
 
Oh, how I chuckle at that imagery!
 
Did I go to college, Avbug?  Of course I did!  I've spent more time in college than you, I’d bet (mostly lounging around in the quad, smoking weed with the other class-cutting stoners - but hey, I was there).  (And no, your “degree” from the now-defunct ITT Technical Ripoff Institute does not count.)  I’ve got so many real degrees I could wallpaper my bathroom with them if I wasn‘t too busy playing Tetris in there.  I loved being in school!  Heck, high school was seven of the best years of my life for crying out loud.  My middle school principal loved me so much that he wouldn’t let me graduate to high school for two extra years!  Whoa!  When I finally did graduate middle school I looked like Aaron from “Fast and Loud.”
 
Look, we’re not supposed to wave our experience level around here; it’s just not done old chap.  Nobody’s opinion has any greater importance than anyone else’s.  The freshly-minted Commercial pilot is just the same as the highest-time 747 ATP.  And if someone comes along and touts their experience level they are shamed and told to go sit in a corner like a petulant child.  If you have experience you should just shut up.
 
Well of course that’s bull.  Some of us have been around for a long, long time.  Take Helinorth.  Perhaps he has been in aviation full-time for 40 years, like I have.  (In 1976 I started working for a helicopter company as a line boy, and then worked my way up to the W30th Street heliport operations manager - then charter dispatcher and then in 1982 a working pilot.)  And by the way?  All of my flight time has been accrued using the “skids-up to skids-down” method.  So, honestly I have no personal stake in this issue.
 
Perhaps helinorth has north of 10,000 hours total time, as I have.  I mean, let’s hope so.  Because then his opinion would *mean* something.  Perhaps we would actually listen when he says something truly bizarre like, “Your airframe is not moving if only a big, huge part of it is moving.”
 
What??
 
Like Helinorth, I too worked at PHI.  And I had some job assignments (Tenneco Oil, yuck!) where I'd consistently do seven days of 75 - 100 landings per day.  I'll tell ya, "blade time" logging would've made my life a whole lot easier!  I would've been timed-out by three in the afternoon.  Obviously, operators *hate* the thought of their pilots logging blade-time as pilot flight time.  We would embrace if...if we were smart.  Which we're not.
 
I think that even the least-experienced Robbie Ranger understands that if a major part of your airframe is moving then the whole airframe can be considered to be “moving.”  It does not take a rocket scientist to make that connection.  Or even a 747 flight engineer.
 
And remember kids, the rule does not state that your “fuselage” must be moving with the intent of taking off.  Lawyers get funny with words, eh?  The rule merely says that your *aircraft* must be moving.  And baby, when your rotor system is moving, your aircraft *is* moving!  It really is that simple.  Just because some non-pilot chick lawyer makes an interpretation of a rule does not mean it’s cast in stone.  Nothing is forever.  It’s why we don’t have Hitler anymore.  Change, like sh*t, happens.
 
But some pilots simply cannot think for themselves. They believe that the FAR’s are the final word! and are therefore non-negotiable.  It’s the equivalent of that bumper sticker: “God said it, I believe it, that settles it!”  Umm, sorry folks but God did not *say* anything.  He did not dictate the Bible like an FAA lawyer dictates a letter to an airman.  And in any event, Becky is not God.  Believe what you want to believe, but don’t force your FAR’s down my throat!
 
We must ask ourselves: Was Becky Whatsername a judge?  Did her “ruling” arise out of some legal case?  No!  She did not set FAA policy; she was merely responding to one letter by one guy.  She probably dictated it to Siri on her way home from Happy Hour after a hard day of “work” one Friday.  (“Hey, if Babbit can do it…*hic*… ehh, is that a cop behind me?”)
 
I would prefer to hear what an Administrative Law Judge would say on the matter, like after a case is tried.  I’d gladly stand before him, thumbs tucked into my suspenders, with my bad comb-over, wiping the sweat from my brow, “Yerrrrr 'onnah!  Mah client nevah had enny inTENshun of violatin’ enny F’n-A-R’s…” 
 
I’m sure the judge would rule with me!
 
And *that* would mean something to me, not the rantings of some ex-FAA attorney who doesn’t know a propshaft from propwash…who doesn’t know VRS from SWP…who doesn’t know Journey from Boston or REO Speedwagon.  (Well, in fairness I can’t tell those three groups apart either)
 
Over the years…check that, over the decades that I’ve been aviation I have met literally hundreds of pilots.  In my observation, I’ve come to realize that some helicopter pilots are, well, aaaaaaahhh, how do we put this politely… “not too bright.”  Intellectually-challenged as it were.  Not burdened with brains and the ability of cognitive reasoning.  Oh, don't get your panties in a wad, I’m not talking about *you*.  You are a genius!  But the other ones, you know who they are: the dummies.  The ones who can’t think their way out of paper bag.  Them. Not. Too. Bright.  Happy that they know how to fly a helicopter so they don’t have to get a real job in a cubicle somewhere and “work” for a living.  Them.  The not-too-bright ones.
 
Airplane pilots, on the other hand, now *they’re* pretty smart cookies!  Talented, hep, the coolest daddios I know!  They can instantly tell Tupac from Ludacris before the first f-bomb drops.  By and large, nearly every airplane pilot I’ve ever met has been a ruggedly handsome, clear-eyed, bouyant extrovert.  (Actually...come to think of it I have met some ruggedly-handsome helicopter pilots. The women.) 
 
Airplane pilots intuitively “get” this issue.  They understand that if our blades are turning then we’re flying!  They get it because they spend a lot of time standing still on the taxiway while logging pilot flight time.  And that’s the thing: airplane pilots understand pilot flight time.  Not component time, not customer billing time.  PILOT flight time. 
 
There are times in life where The Authorities are simply wrong.  This is one of those times.  Dear, misguided Becky got it wrong, poor thing, and now she’s not even around to correct it.  And when she skated off to private practice she left us with this turd in the punchbowl of an *opinion* that some narrow-minded booger-eater pilots think is sacrosanct and immutable.  She shows us very clearly that the FAA does not understand helicopters.  And just as obviously, some helicopter pilots don’t understand helicopters either.  Hmm…
 
We will fix it…eventually.  Fortunately there are smart people in the FAA who do understand helicopters, like this FSDO POI guy in New York.  I’m willing to bet that he had the full approval of his FSDO manager to institute this policy.  Furthermore, that’s probably the policy he’s enforcing at the other 135 operators he oversees, too.
 
At the end of the day, like I say I don’t really care how you log time in the air.  You think I do?  Au contraire, mon frere!  It doesn’t affect me personally anymore.  I just think ol’ Becky’s interpretation is wrong.  But it’s fun to see how emotionally invested some pilots are in this “skids-up to skids-down” thing.  I mean, it’s like they do take it personally! 


#23 avbug

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Posted 22 September 2016 - 17:27

 

  I just think ol’ Becky’s interpretation is wrong. 

 

Your opinion, of course, carries not weight and is irrelevant, but you're free to think whatever you want.  The Assistant Chief Legal Counsel's opinion does carry weight, unlike yours, has validity, and is defensible.   Yours?  Not at all.

 

It's a shame that your writing doesn't reflect any of that education.  What a waste.



#24 Nearly Retired

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Posted 22 September 2016 - 21:09

Daaaaaaamn, Daniel, is that all you got for me?  Do you KNOW how much time I wasted crafting that post?  Lyn ought to pay me for this sh*t - but he gets it for free! 

 

Ye gots to give me more, laddie! 

 

You're killing me, Smalls.



#25 avbug

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Posted 22 September 2016 - 23:41

You entered with a statement that there's a debate.  There isn't, save in your mind, which is hardly fertile ground.  

 

Haven't you some cowering to do in a hangar somewhere, for fear that you might get called to go fly?



#26 Guest_pokey_*

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Posted 23 September 2016 - 03:25

Daaaaaaamn, Daniel, 

 

WHO? is Daniel? have you unmasked our anonymous bug? Maybe now when his mom finds out his attitude on here, she will stop putting quarters in that helicopter in front of walmart.



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Posted 23 September 2016 - 07:02

You entered with a statement that there's a debate.  There isn't, 

 

Just because some lawyer ruled on it, does not mean that the topic is forever closed to debate by intelligent ppls, oh wait? you are lacking in both of those areas (altho you try your damnedest to prove otherwise). Maybe you shouldn't have skipped class that day in Bug U? but you had fun riding the 747 whirl-A-gig at the carnival, i think i may have skipped out too. 



#28 kona4breakfast

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Posted 23 September 2016 - 14:13

Regulations aren't written in stone, they change every year.

 

I think it's interesting that the FAA goes out of its way to use lawyer-speak to craft the FARs, then pays lawyers to provide the official interpretation of what the words those lawyers used really mean.

 

I assert that the FAA's official interpretation of "aircraft moves under its own power" has the practical meaning of "when the contact point of the landing gear and the surface of the earth changes due to deliberate application of aircraft propulsive power," even though the center of gravity of the aircraft begins to oscillate, under the aircraft's own power, when the powertrain begins to drive the rotors (and in the X, Y, and Z axis!).  Is this picking nits?  Of course it is, but words mean things and that's what the words used in the FAR mean.  

 

What the FAR says and what the FAA says it means are two different things.  As a federal agency with the coercive authority of the state, they can do that.  As a good American, I can do what good Americans do, and by that, I mean anonymously post on internet forums and complain about it, of course.  If one decides to log flight time in their logbook using a different meaning from the one that the FAA uses, they'd be wise to use the what I call the Rancher's Rule: shoot, shovel, and shut up.

 

...

 

It appears, from the story about this FSDO that the FAA might be coming around to believe flight time means what the FAR says.  This is probably because, as most helicopter pilots are aware, until your flight control inputs no longer affect the tip path plane, you are most definitely flying the aircraft, and many bad things can happen if you cease to actively 'fly' the aircraft.

 

An analogous point I'd like to make is that there is a difference between what is illegal and what is immoral, even when the laws in question are driven by moral concerns.  The law, or regulations, are usually a lagging indicator of the morals of the population they purport to serve.  Laws and regulations are also written in black and white, while morality never is.

 

I doubt the FAA's official interpretation will change for quite some time barring a tragedy like the decapitation of a passenger during embarkment/disembarkment of a helicopter with rotors turning. I do believe it will change eventually though, and debates like this have the effect of perhaps influencing current and future POIs and FAA ASIs.

 

...

 

The discussion of billed time is totally irrelevant.  A customer and an operator can decide to use whatever definition of billable flight time they want to, clock time, oil pressure Hobbs, collective Hobbs, pick one.  I've used different times on different contracts.

 

The discussion of maintenance time is irrelevant.  Use whatever time the maintenance program calls for, which for my company is collective Hobbs.

 

The flight duty time you fill out on the Flight and Duty Log, which is a report from your company to the FAA, should use what your POI says is pilot flight time.  

 

The pilot flight time you put in your logbook is flight time IAW FAR 1.1.  


I told my mom I wanted to be a pilot when I grew up.  She told me I couldn't do both.

#29 SBuzzkill

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Posted 23 September 2016 - 16:44

I've always thought the rule was interesting.  A helicopter on the ground at 100% RPM is synonymous with an airplane at Vr. 

 

What did the airplane rule used to say, or has it always been written that way?  The "moving under its own power with the intent to takeoff" rule sounds like something made to protect airline pilots during long taxis.  Perhaps the assumption on the rule-makers part is that because of a helicopter's unique flying characteristics the pilot will be taking off with minimal delay after engine start.

 

In any case, it's a rule that needs to change.  Until then I will continue to log IAW the applicable regulations. 


Edited by SBuzzkill, 23 September 2016 - 16:46.


#30 avbug

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Posted 23 September 2016 - 17:36

I assert that the FAA's official interpretation of "aircraft moves under its own power" has the practical meaning of "when the contact point of the landing gear and the surface of the earth changes due to deliberate application of aircraft propulsive power," even though the center of gravity of the aircraft begins to oscillate, under the aircraft's own power, when the powertrain begins to drive the rotors (and in the X, Y, and Z axis!).  Is this picking nits?  Of course it is, but words mean things and that's what the words used in the FAR mean.  

 

What the FAR says and what the FAA says it means are two different things.  As a federal agency with the coercive authority of the state, they can do that.  As a good American, I can do what good Americans do, and by that, I mean anonymously post on internet forums and complain about it, of course.  If one decides to log flight time in their logbook using a different meaning from the one that the FAA uses, they'd be wise to use the what I call the Rancher's Rule: shoot, shovel, and shut up.

 

...

 

It appears, from the story about this FSDO that the FAA might be coming around to believe flight time means what the FAR says.  This is probably because, as most helicopter pilots are aware, until your flight control inputs no longer affect the tip path plane, you are most definitely flying the aircraft, and many bad things can happen if you cease to actively 'fly' the aircraft.

 

An analogous point I'd like to make is that there is a difference between what is illegal and what is immoral, even when the laws in question are driven by moral concerns.  The law, or regulations, are usually a lagging indicator of the morals of the population they purport to serve.  Laws and regulations are also written in black and white, while morality never is.

 

I doubt the FAA's official interpretation will change for quite some time barring a tragedy like the decapitation of a passenger during embarkment/disembarkment of a helicopter with rotors turning. I do believe it will change eventually though, and debates like this have the effect of perhaps influencing current and future POIs and FAA ASIs.

 

...

 

The discussion of billed time is totally irrelevant.  A customer and an operator can decide to use whatever definition of billable flight time they want to, clock time, oil pressure Hobbs, collective Hobbs, pick one.  I've used different times on different contracts.

 

The discussion of maintenance time is irrelevant.  Use whatever time the maintenance program calls for, which for my company is collective Hobbs.

 

The flight duty time you fill out on the Flight and Duty Log, which is a report from your company to the FAA, should use what your POI says is pilot flight time.  

 

The pilot flight time you put in your logbook is flight time IAW FAR 1.1.  

 

Flight time as defined in 14 CFR 1.1, and as expanded upon in the legal interpretation already provided, states applicability when an aircraft (not an aircraft component, but the aircraft) moves under its own power with the intention of flight.  The legal interpretation clarifies that.

 

What you think or what I think is irrelevant. 

 

I don't believe "nearly retired" when he or she states that a FAA POI provided an interpretation of the regulation; the FSDO level is not authorized to do this. "Nearly retired" either does not understand what occurred, or is lying.  I suspect that the POI established the circumstance under which the POI expects an accounting of pilot time for the purposes of flight time limitations under Part 135, and that the POI made no effort to define the regulation with respect to logging time. 

 

If the POI did attempt to make such an "interpretation," it would not be defensible even if in writing, given the complete lack of authorization at the FSDO level.  If, for example, an inspector were to make a written statement that logging of flight time begins with first movement of the rotor, or with application of power with the battery master relay, or with the first note of the Star Spangled Banner, it would not change the regulation nor the interpretation of the regulation as provided by the Administrator's authorized source.  Furthermore, if one based one's logging of flight time on that inspector's "interpretation" and presented that time toward a certificate or rating, the use of the inspector's written statement would not be defensible and would not serve as authorization to log time in any manner other than what the Administrator has allowed.

 

As for the "coercive" state government, you will do well to remember that you have no right to fly, nor a right to operate as a pilot.  These are state-granted privileges (not rights) applied as an Act of Congress, granted through the only person empowered by congress, the Administrator, and those designated by the Administrator.  You gain privilege to fly by the Administrator, and you abide the regulations established by the Administrator in the conduct of that privilege.  Coercion?  Hardly.  Your pilot certificate is a privilege; you are obligated to adhere to the regulation as provided by the same person and organization that grants that privilege, as your retaining that privilege is a function of your ability to abide the regulations that govern it.



#31 r22butters

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Posted 23 September 2016 - 19:25

Regulations aren't written in stone, they change every year



I'm almost certain the 13th commandment was, "Thou shalt only loggeth thy flight time from skids up to skids down"!
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#32 kona4breakfast

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Posted 23 September 2016 - 20:22

There are people that fly in the land of the free without a pilot's license.  Perhaps you should tell them that flying isn't a right. They'll probably tell you the same thing they tell the FAA.  They are, however, smart enough to take out the passenger seats though.  The FAA can't touch them, but the police can.

 

Again, the FAA's interpretation of flight time is incorrect, it is not my opinion it is fact.  If they want to change that then they can re-word the definition, but the definition does not match the interpretation and no amount of harumphing can make it so.

 

I log flight time incorrectly, because that's what the FAA says I have to do, but it is still incorrect.  I can say that they are wrong because I am a sentient human being that understands physics, but I log flight time the way they want me to because I want to continue to exercise the privileges of my pilot certificate.  

 

Av, the only aircraft component that is NOT moving when the rotor blades are turning when an aircraft is on the ground is the landing gear (and even then, only the portion of the landing gear that is in contact with the surface of the earth).  Sometimes not even then, as in the case of landing on ice, or in tundra/marshland, or step in/toe in landings.  

 

If you don't believe me, walk up to a helicopter that is running and put your hand on it.  You'll feel it moving like a jet-fueled vibrator.  


I told my mom I wanted to be a pilot when I grew up.  She told me I couldn't do both.

#33 Astro

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Posted 23 September 2016 - 22:34

I also believe that the FAA has the definition of flight time wrong. Between hot fueling and hot loading, on tours you can sit in a running chopper all day with those blades spinning, but if your skids are on the ground you ain't flying, and if you ain't flying it ain't flight time!
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#34 helonorth

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Posted 24 September 2016 - 06:31

 

 

 

Again, the FAA's interpretation of flight time is incorrect, it is not my opinion it is fact.  

 

 

 

 

 

 

 

 

 

move
mo͞ov/
verb
 
"go in a specified direction or manner; change position"
 
 

Not only is it just your opinion, it is not factual. That is why it is only an opinion.



#35 avbug

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Posted 24 September 2016 - 08:07

There are people that fly in the land of the free without a pilot's license.  Perhaps you should tell them that flying isn't a right. They'll probably tell you the same thing they tell the FAA.  They are, however, smart enough to take out the passenger seats though.  The FAA can't touch them, but the police can.

  

 

 

If by "land of the free,"  you mean  Alaska, then yes, a lot of people do fly without a pilot certificate (there is no pilot license in the USA).  This is not legal, and yes, the FAA does have jurisdiction over their activities as operation of an aircraft that requires a pilot certificate in the national airspace system is under the purview of the FAA.   The FAA can pursue enforcement action on both an Administrative level, and on a criminal basis as well, and can impose civil fines.  A given law enforcement agency may also pursue separate action.

 

You're far afield of the thread topic now, and your tangent is quite irrelevant to the thread, but you are wrong on several counts.  No, flying is not a right.  Nowhere is it identified as a right, and there is no right as a citizen to operate an aircraft.  Like driving a car, it is a legal privilege obtained under a particular authority.  To operate a motor vehicle in violation of the regulation that governs that operation, or to operate an aircraft contrary to the regulation, is not legal, and one has no right to do so.  Flying is a privilege which is contingent on adherence to the regulation that governs that privilege.  

 

That some elect to fly aircraft illegally does not confer upon them a right, any more than one has a right to drive on the wrong side of the road, or to drive without a license when a license is required.

 

Removal of a passenger seat in an aircraft does not invalidate the requirement to hold a pilot certificate to operate that aircraft.  I operate single seat aircraft quite a bit.  Lack of a passenger seat would not entitle me to operate those aircraft without a pilot certificate.  When I operate that aircraft, I am expected to abide the regulation; failure to do so may result in loss of privileges, including suspension or revocation of my pilot certificate.  Without that privilege I have no right to operate those aircraft, regardless of the presence of a passenger seat.  

 

 

 I can say that they are wrong because I am a sentient human being that understands physics, but I log flight time the way they want me to because I want to continue to exercise the privileges of my pilot certificate.  

 

 

It's a privilege and not a right?  Make up your mind.

 

 

If you don't believe me, walk up to a helicopter that is running and put your hand on it.  You'll feel it moving like a jet-fueled vibrator.  

 

 

What I believe is irrelevant.  What you believe is irrelevant, too.  The question of logging time isn't really a question: it's clear-cut, well defined and ample material exists to understand it within the confines of the regulation.  The legal interpretation given by the designee of the Administrator is very clear and specific.  The person who wrote that interpretation did so as an authorized representative of the Administrator, speaking on behalf of the Administrator.  Your opinion or my belief won't change that, and is irrelevant.  Yes, a helicopter shakes and vibrates, and no, it's irrelevant to the understanding of 14 CFR 61.51.

 

The FAA exercises precious little oversight of pilots recording flight time.  The only times in my entire flying career when anyone has made a concerted effort to record my movement times in an aircraft have been in air tanker operations (when pay is down to the hundredth of an hour), and when doing freight work Germany in the 747, when they'd literally note and call out our pushback time.  Other than that, nobody has ever come to the ramp and noted the exact moment the aircraft moved.  The FAA certainly doesn't.

 

If an individual states that he first moved at 10:06, who is going to contest that and suggest it was 10:07?  The pilot is largely responsible for keeping track of that time for purposes that range from logging to flight time limitations to pay.  Even when operating internationally in the Whale, our push times, taxi times, and takeoff times were hand written on the flight sheet.  If Pilot X begins his timing for his flight when the rotor turns vs. when he first lifted a skid, you don't really think that the FAA will be beating down his door with an investigative letter and a notice of proposed certificate action, do you?

 

Again, one can log whatever one wishes, from time spent on the toilet to hours wearing plaid and hunters socks, but if the discussion is about the legal logging of time, it's well established and defined, and there's no controversy in that.  The ONLY authorized party who has input on the matter has provided both the regulation itself, as well as extensive legal interpretation in response to specific situational and general questions that have been posed to the Administrator. 

 

 

Again, the FAA's interpretation of flight time is incorrect, it is not my opinion it is fact.  If they want to change that then they can re-word the definition, but the definition does not match the interpretation and no amount of harumphing can make it so. 

 

 

The definition precisely matches the interpretation.  The definition states that flight time begins when the aircraft (not a component of the aircraft) first moves with the intention of flight.  An aircraft taxiing from the hangar to the fuel farm isn't with the intention of flight, and isn't flight time.  An aircraft performing maintenance runs isn't with the intention of flight, and isn't flight time.  An aircraft that moves to a runway and holds short while waiting to take off is with the intention of flight, and is flight time.  

 

The Legal Interpretation previously cited is quite pointed in establishing that the interpretation of the regulation is exactly according to the "plain words of the regulation," in that regardless of whether fixed wing or rotor wing, flight time commences when the aircraft moves under its own power with the intention of flight.  Further, it clarifies that more specifically in response to Mr. Lloyd's questions, showing that the regulation means moving away from the parking spot.

 

A helicopter's rotor blade turns, and the aircraft shakes and vibrates.  If you've spent any time operating fixed wing radial powered airplanes, you'll understand shaking and vibration, too.  Sitting in the chocks or at the parking spot or helispot or tie down with an engine running, whether it's turning a rotor or propeller, doesn't fulfill the definition of flight time insofar as the logging of flight time is concerned, under the regulation.  The aircraft needs to begin moving under its own power with the intention of flight.  Not just a component of it, but the aircraft.   A bird may begin flapping its wings in the nest, but hasn't begun the flight until it moves from the nest, and the aircraft flight time hasn't begun until the aircraft moves from its parking spot under its own power.

 

As for whether the FAA is wrong about the regulation: it's FAA regulation.  You don't have the right to define or interpret it any more than I do.

 

The FAA Administrator does, and is empowered and chartered to do so by an Act of Congress.  The FAA delegates that authority to the Chief and Regional Legal Counsel, which has used that authority to provide clarification on the FAA position on the regulation, which is the application of the regulation.  You can state that the FAA is wrong about FAA regulation, but without a leg upon which to stand, and without any authority.  Both rest squarely in the FAA camp, which not only creates the regulation, but defines it and enforces it.  Your obligation and requirement is to follow the regulation. During times when regulation is proposed, you have the right to comment on it.  Beyond that, your privileges under the regulation depend entirely on your compliance with the regulation.  You can opine that you think the regulation is wrong, but your opinion doesn't make it so.  The regulation exists entirely independently of whether or not you like it.



#36 Nearly Retired

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Posted 24 September 2016 - 10:23

Avbug rants:

I don't believe "nearly retired" when he or she states that a FAA POI provided an interpretation of the regulation; the FSDO level is not authorized to do this. "Nearly retired" either does not understand what occurred, or is lying.

 

 

Yeah, because I have nothing better to do than make crap up and then come on here and argue with nitwits. 

 

As I stated, I was merely relaying what a pilot friend told me over the phone about the flight time logging policy at the company he works for.  Then again...maybe I made that all up just so I could engage in some witty repartee with some supposed 747 driver.  Avbug, do the letters "F.O." mean anything to you?

 

Look, I think some of you are missing a very big point.  I find it laughable that even a supposedly experienced skygod like Avbug even gets this one wrong.  See, it’s not about when the aircraft begins to fly. 
 
For the purposes of keeping track of overhaulable or life-limited components, the aircraft itself does not start “flying” until the landing gear leaves the ground.  It’s the same for both helicopters and fixed wing; the methodology of keeping track of the flight time of an airplane engine is slightly different but at the end of the day it’s the same.
 
But that’s beside the point.  We’re talking about *pilot* flight time here.  And the FAA decrees that a pilot can begin logging *pilot* flight time when the aircraft moves under its own power with the intention of flight. 
 
I say: Rotor system turning = aircraft moving.
 
Avbug’s analogy about a bird flapping his wings prior to falling out of the nest is just silly.  But it’s what you’d expect from a guy who thinks he’s much smarter than he is.  Of course the bird itself is not flying!  Nobody disputes that.  Again, for those of you too narrow-minded (:::cough-cough::: AVBUG) to get it, we’re not talking about *flying*, we’re talking about *logging.*  I’m beginning to question just exactly how much Avbug really understand about aviation.  His thinking sometimes seems so…flawed.  I'm wondering if he's suffering from that same cognitive defect that got those two FAA guys' panties in such a wad over Bob Hoover.
 
Okay, enough with the light-hearted, friendly banter...
 
I guess we have to get into the minds of the FAA lawyers when they dreamt up that definition.  Why do they even allow fixed-wing pilots to log pilot flight time once their aircraft starts to taxi?  It seems strange, no?  I mean, obviously they’re not yet actually *flying*.  But they’re in control of a machine that can do incredible damage and hurt/kill people if the guy at the controls doesn’t stay awake.  So the FAA gives him that responsibility.  “Okay, yeah, you’re in control so you can start logging pilot flight time.” 
 
(Actually, the NTSB is even different.  Look at the description of an NTSB-reportable accident: Anything that happens from when the passengers start to board the aircraft until they time it’s at the gate at the destination.  Never mind all this “moves with the intention of flight” jazz.  The NTSB holds the pilot responsible from the time people start getting onboard!)
 
Once you, Mr. Helicopter Pilot, start your engine(s) and your rotor starts to spin and you have cyclic control over those blades (NR doesn’t have to be at 100%) you should be able to log pilot flight time.  Why any real helicopter pilot would argue this point this is beyond me.


#37 kona4breakfast

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Posted 24 September 2016 - 12:02

Rotation and vibration are movements.  They are not "flying," of course, no one is saying that, but they are movement, thus satisfying the definition.  If they meant taxi they should've used that word.

 

I never said that flying was a right, by the way.  I was just making the point that there are people that operate aircraft without a pilot certificate, illegally of course, and the FAA can do almost nothing about it except shake their finger and hope that a local law enforcement agency will do what they cannot.  I made the point because you are a mindless authoritarian and I was hoping it would get under your skin.  


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I told my mom I wanted to be a pilot when I grew up.  She told me I couldn't do both.

#38 Astro

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Posted 24 September 2016 - 12:16

I agree that (even though its not "flight time") once the blades start spinning we should be able to log PIC time.

I suppose we could just add another block in our book for skids up to skids down flight time? After all its our book we can put whaterver we want in it! I used to have a block for solo time, but nobody really cared so I stopped putting it in.

#39 avbug

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Posted 24 September 2016 - 20:58

 

Yeah, because I have nothing better to do than make crap up and then come on here and argue. 

 

 

 

Clearly.  When you're afraid to go fly, it seems that this is what's left for you.

 

 

 

 

 

As I stated, I was merely relaying what a pilot friend told me over the phone about the flight time logging policy at the company he works for.  Then again...maybe I made that all up just so I could engage in some witty repartee with some supposed 747 driver.  Avbug, do the letters "F.O." mean anything to you?

 

 

First Officer?  Probably more than to you.  Have you ever been one?

 

Previously, you had an inspector at a FSDO redefining FAA policy and interpreting the regulation.  Now what you have is second hand information that you heard in a phone call.  Your story continues to crumble.   What's next, a fortune cookie?

 

You've said nothing witty thus far.  Will you be starting shortly?

 

 

 

See, it’s not about when the aircraft begins to fly. 

 
For the purposes of keeping track of overhaulable or life-limited components, the aircraft itself does not start “flying” until the landing gear leaves the ground.  It’s the same for both helicopters and fixed wing; the methodology of keeping track of the flight time of an airplane engine is slightly different but at the end of the day it’s the same.

 

 

That is incorrect.

 

I'm a very active mechanic, and have served as a Director of Maintenance twice, and line and repair station inspector, with a fairly extensive maintenance background.  You're absolutely wrong that all maintenance is tracked the same, or that maintenance tracking only begins when the aircraft leaves the ground.  Not true at all.

 

Engine manufacturers base component times, inspections, overhauls, and tracking on several metrics, including thermal cycles, and the engine time has nothing whatsoever to do with gear on the ground.  Airframe time is tracked by hour meters for some components, and in many cases, off a clock; the crew reports the time and it's logged in that way.  Others use tach time, which varies with the speed of the component measured; faster engine operation, for example, results in faster tach time.  Some use electronic hour meters that operate based on a squat switch, airspeed switch, battery master relay, or are wired through an oil pressure switch.  

 

Wheels off the ground is one method, but wheels off the ground applies primarily to cycles and landings, another aspect of airframe and component life, and determining inspection intervals.

 

It's also 100% irrelevant to the logging of flight time, the controversy of which exists not on paper or in the regulation, but only in the cobwebs of your mind.

 

 

I guess we have to get into the minds of the FAA lawyers when they dreamt up that definition.  Why do they even allow fixed-wing pilots to log pilot flight time once their aircraft starts to taxi?  It seems strange, no?  I mean, obviously they’re not yet actually *flying*.  But they’re in control of a machine that can do incredible damage and hurt/kill people if the guy at the controls doesn’t stay awake.  So the FAA gives him that responsibility.  “Okay, yeah, you’re in control so you can start logging pilot flight time.” 

 

 

You're consistent, because you're wrong again.

 

The "FAA lawyers" didn't "dream up" the definition.  The used the definition found in the regulation, and didn't deviate from it.  The regulation defines flight time as beginning when the aircraft moves under with the intention of flight.  The Assistant Chief Legal Counsel didn't add to that at all; her authoritative legal definition is very clear and she simply stated that the definition doesn't differentiate between helicopters and fixed wing; it applies to both equally.  If the airplane begins taxiing with the intent of flight and moves from it's parking spot, then flight time has commenced.  If the helicopter moves from its parking spot for the purpose of flight, then flight time has commenced.  Same, same.

 

The Assistant Chief Legal Counsel said nothing about danger or incredible damage or staying awake.   The Assistant Chief Legal Counsel simply referred the petitioner back to the regulation, which is very clear and easy to understand.  The petitioner got specific about logging time in a helicopter, and those questions were answered by a plain English rendering of the regulation and a reference back to the regulatory definition.  There's no bone thrown to fixed wing pilots, no tacit reference to responsibility or risk or damage or risk to life or limb.  Nothing of the kind.  Simply an upholding of the existing regulation that flight time is defined as commencing when the aircraft first moves with the intention of flight, and ends when it comes to rest after the flight.  In industry parlance, that's "block to block," or referencing your airline comments, block out to block in.

 

The allowance isn't for fixed wing pilots.  It's for everybody, because the regulation doesn't discriminate or differentiate.  Move the aircraft (not a component of the aircraft such as a propeller or rotor) with the intention of flight, and your flight time has begun for the purpose of logging under 14 CFR 61.51.

 

 

(Actually, the NTSB is even different.  Look at the description of an NTSB-reportable accident: Anything that happens from when the passengers start to board the aircraft until they time it’s at the gate at the destination.  Never mind all this “moves with the intention of flight” jazz.  The NTSB holds the pilot responsible from the time people start getting onboard!)

 

 

Wrong again.

 

What the NTSB does is irrelevant to the logging of flight time, but the NTSB understands that the regulation overseeing flight operations is 14 CFR, as is the purview of enforcement.  

 

As you continue to invoke fixed wing operations and you have an unusual fixation on the 747, we'll use that as an example.  The crew is responsible within the scope of their duty during loading of cargo or passengers, but there is no ultimate duty for which anything which happens befalls the pilot or other crew.  I've been upstairs in the cockpit, heard a scream, and come below to find a loadmaster pinned by a cargo container, and have enlisted help in freeing the loadmaster.  Was I responsible for the incident?  Only insofar as I knew about it at all; as the captain I was not automatically responsible for anything that occurred.  I was responsible for addressing it, handling it within the scope of my duties, but no, the NTSB and the FAA and the company did not hold me responsible for everything at all times.  The pilot in command is the final authority (holding joint operational control in the case of the airline operation--shared responsibility with the Director of Operations and with dispatch) over the safe conduct of the flight, but only within the scope of his duty.  

 

The NTSB looks closely at what a pilot ate, how he slept, his personal life, recent flight experience, and numerous other factors, but you're invoking an organization which primarily addresses flight operations from the context of a mishap or crash, and has no input on how pilots log flight time.  Responsibility for passengers as they board the aircraft has nothing whatsoever with the definition of flight time, or with the logging thereof.   You know this.  Introduction is for no other purpose than to attempt to muddy the waters, which are quite clear (just apparently not to you).



#40 Nearly Retired

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Posted 25 September 2016 - 00:49

Good God Avbug, you are such a tool.  Holy cow.  Look, I'll keep this short. 

 

First, let's look at the FAR's Section 1.1 Definitions.  We find this:

 

Time in service, with respect to maintenance time records, means the time from the moment an aircraft leaves the surface of the earth until it touches it at the next point of landing.

 

Got that? Good.

 

Now, let's look at NTSB part 830 for accident reporting, shall we?  I'll just copy and paste it:

 

§830.2   Definitions.

As used in this part the following words or phrases are defined as follows:

 

Aircraft accident means an occurrence associated with the operation of an aircraft which takes place between the time any person boards the aircraft with the intention of flight and all such persons have disembarked, and in which any person suffers death or serious injury, or in which the aircraft receives substantial damage.

 

There.  Components begin accruing flight time ("time in service") when the wheels/landing gear leaves the ground.  Accidents are accidents from the time *any* person boards the aircraft with the intention of flight.

 

NOW will you please shut up?  Sheesh, you're just complicating things with your endless bloviating.






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