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Ye Olde Flight Time Debate


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#41 Guest_pokey_*

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Posted 25 September 2016 - 06:19

this is almost funny. The bug just don't get it. 2 things one can count on when the bug starts up: 1) 747  2) argument 

 

"Mr. KIMBAL !? yes, now that we have identified the bug, how do we get rid of it?"

 

does anyone know this character in real life? he sure likes to hide behind his screen of anonymous animosity. Heck? NR even has his real name on every post and where you can find him, me? Just visit my profile & you can find me too. Most others? i'm sure if we asked they would be happy to tell who they are. but the bug? them damned bugs !  get out the bugspray  



#42 helonorth

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Posted 25 September 2016 - 08:56

There are actually two sub groups in the "flying while on the ground" crowd. The first simply just don't agree with the regulation and the second are in denial of what the regulation says. 
 
I think I understand where this non-debate stems from (for there to be a debate, you need to be able to present two supportable positions. The "flying while on the ground" crowd has not fulfilled their part of the deal). Jealousy and perceived inconsistency.   It boils down to the FAA allowing airplanes to log flight time while taxiing. Since the "aircraft is moving under its own power for the purpose of flight", this is reasonable to me. In a helicopter, only the blades are moving (sorry, vibrations don't count, even down to the skids) but the aircraft is not changing its position. In other words: IT'S NOT MOVING.This confuses and apparently angers some helicopter pilots. They find it inconsistent and unfair. The rational among us sympathize, but also look upon you with a certain amount of pity. 
 
The thing I find most strange about this non-debate is that it is even being discussed at any length. It has no almost no effect on anything. I suggest the "flying while on the ground in a stationary position" crowd just either accept it (as I have done from day one) or do something about it (whining on the internet does not count). 
 
Sure regulations change, but until this one does (and I think it is extremely unlikely that it ever will) please stop dragging this up every year or two and bothering us with this nonsense.
 
I am also skeptical of the story that there is a POI out there so completely clueless about the FAR's (and it's interpretations) that he/she would just arbitrarily decide to amend a GOM with verbiage completely contrary to the FAA's own regulation. I'm sure your friend could make a copy of this page of the GOM and NR could post it? 
 
 
 
 


#43 Nearly Retired

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Posted 25 September 2016 - 10:09

Well Helonorth, I did not want to drag their name into it, but the company is HFS in NYC.  ​I do not know the POI's name, but I suppose I can find it, and I suppose he's the same one who handles Zip and whatever other 135's are up in that area.

 

And again, with all due respect you're kind of missing the point.  It's not about "flying while on the ground."  We all can admit that airplane pilots are not "flying while on the ground" when they're taxiing for takeoff. 

 

It has nothing to do with the aircraft.

 

It's about logging flying while on the ground. 

 

You contend that a helicopter is not moving when its blades are spinning.  Okay, that's fine, and your position falls in line with the current FAA interpretation.

 

I contend the opposite.  I contend that a helicopter is indeed "moving" even though it is not changing position with relation to the ground.  I contend that the two chicks in the FAA's legal department who rendered that opinion to Barry Lloyd are simply wrong.  I think that if they were educated about helicopters and discovered (to their amazement, I'm sure) that rotor blades are airframe parts and not analogous to propellers, they would change their opinions.  I contend that an ALJ (administrative law judge) would absolutely rule that they are wrong. 

 

And it's not about jealousy.  It's simply about consistency.  The current FAA interpretation of "pilot flight time" for helicopter pilots is, I think, incorrect.   At least one guy in the FAA system seems to agree with me.  That is all that I said in my original post in this thread.  That produced nearly three pages of people telling me I'm an idiot.



#44 avbug

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Posted 25 September 2016 - 12:15

And it's not about jealousy.  It's simply about consistency.  The current FAA interpretation of "pilot flight time" for helicopter pilots is, I think, incorrect.   At least one guy in the FAA system seems to agree with me.  That is all that I said in my original post in this thread.  That produced nearly three pages of people telling me I'm an idiot.

 

 

You're not an idiot for recognizing the fact that a pilot in an aircraft with a turning rotor has a full measure of responsibility.  That doesn't make you an idiot at all.  Your'e correct about that.

 

Your commentary is largely idiotic.

 

Your point that a pilot sitting at the controls of a helicopter on the ramp, when the blades are turning, is performing pilot duties and must control the aircraft is well taken, and correct, from wind input to watching for obstacles or people to the potential of dynamic rollover, etc.  Clearly one must be vigilant.  Bear in mind that a mechanic who is run-trained could be doing the same thing, legally, just as a mechanic in a fixed wing airplane could be doing runs (and often do). The mechanic in the fixed wing can and does move the aircraft around the airfield for engine runs, compass swings, etc, and as it's not with the intent of flight, the time isn't flight time.  

 

Mechanics in helicopters don't move skid-equipped aircraft with the engine running; to do so would be lifting the skids, and that would be with the intention of flight.  Wheel equipped helicopters, however, can be taxied without the intent of flight, and a mechanic, properly trained and authorized, can do this as well as a pilot.  It's not flight time.  Once the aircraft, be it fixed wing or helicopter, is moved with the intent of flight, then it becomes flight time, and that's supported in the plain english rendering of the regulation, as well as the wholly-consistent legal interpretation provided by the FAA Chief Legal Counsel's office.

 

Your assertion that run time in place on the ground constitutes loggable flight time is incorrect, and your name calling, lies regarding the firing of FAA legal counsel, and your childish insults to other posters as well as aviation profesionals within the Agency (et al) don't change that fact.  Neither do your repeated assertions that it should be some other way because that's what you want.  Your comments are borderline childish, churlish, and yes, in several cases, idiotic.

 

Usually these "controversies" are wrought by those who simply don't understand the regulation.  A popular "debate" is the logging of pilot in command time, which is not debatable or in doubt.  Such debates are simply displays of ignorance, much like your own assertion of "controversy" here.  In the case of logging PIC, there are cases when two pilots in a single pilot aircraft can log it, times when the pilot flying can log it, times when the pilot not flying can log it, and times when neither pilot can log it.  Understanding the regulation (and the interpretations thereof) make this clear; why it continues to cause confusion isn't a function of complexity, but of ignorance.  The "controversy" of logging  time for a helicopter is the same with respect to understanding the regulation and its interpretation.

 

"Nearly Retired" appears as an upset child, crying that the regulation shouldn't be the way it is, and demanding that changes be made to accommodate "nearly retired."  Along the way there's name calling, insults, libel, etc, and an absolute lack of maturity and professionalism, as well as a painful display of ignorance.  His comment about the nature of running a helicopter on the ground is correct; it does require vigilance, attention, responsibility, etc.  It's not pilot time, not flight time, and doesn't meet the requirements for either one; a non-pilot can do it (and often does).  Movement on the surface doesn't require a pilot either, unless the movement is with the intention of flight, at which time one may be logging time time, whether in an airplane or helicopter.  



#45 kona4breakfast

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Posted 25 September 2016 - 12:45

Pilot time that commences when an aircraft moves taxis under its own power for the purpose of flight or takes off and ends when the aircraft comes to rest after landing lands or ceases to taxi.

 

This definition matches the FAA interpretation, and the language is precise.

 

All taxiing is movement, but not all movement is taxiing.  Vibration and rotation are movement.  If they aren't movement, I'd like to know what they are. 


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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.

#46 avbug

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Posted 25 September 2016 - 13:26

Pilot time that commences when an aircraft moves taxis under its own power for the purpose of flight or takes off and ends when the aircraft comes to rest after landing lands or ceases to taxi.

 

This definition matches the FAA interpretation, and the language is precise.

 

All taxiing is movement, but not all movement is taxiing.  Vibration and rotation are movement.  If they aren't movement, I'd like to know what they are. 

 

 

The regulation doesn't need to be altered to match the legal interpretation.  

 

The legal interpretation was provided in answer to a question regarding the regulation, and serves to clarify that question.  It doesn't change the regulation.  

 

There's nothing in the regulation that suggests moving a part of the aircraft qualifies as "flight time." Moving the propeller, turning or starting an engine, or moving the rotor aren't "flight time."  

 

When the aircraft moves, not a part of the aircraft moves, with the intention of flight, then it becomes flight time.  

 

The legal interpretation is very clear about that.  A plain english rendering of the regulation is also very clear.  

 

If one simply wished to move a part of the aircraft, one could sit in a Cessna and rock the ailerons back and forth all day long and dream of flying, and attempt to assert that the aircraft moved with the intention of flight...and log it.  That would be idiotic.  Moving a part of the aircraft, not the aircraft itself, does not qualify.  The fact that the aircraft sits in place and vibrates or shakes does not qualify.  

 

The regulation really is dirt simple.  When the aircraft moves with the intent of flight, period.  It doesn't matter if it's taking off or taxiing.  Both are encompassed in the language of the regulation, and made clear in the interpretation.  There's no ambiguity there.



#47 r22butters

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Posted 25 September 2016 - 13:34

Filling out my book for last night's flight, its a 1.8,...but wait that's off the hobbs and its an R22 which works off the oil light! So do I put 1.8 or 1.7?

I don't know what to do! I feel frozen with indecision, haunted by conflicts of morality, ethics, and common sense!

What do I do!? What do I do!? WHAT DO I DO!!!!!!!!?

AAAAAAAAAAAAAH!
:)
Side boob is just so awesome,...yes it is!

#48 kona4breakfast

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Posted 25 September 2016 - 14:14

Rocking the ailerons isn't under it's own power, it's under yours, and it wouldn't be with the intent of flying without applying the aircraft's engine power.  

 

Applying engine power to the drivetrain causes the rotors to turn, which causes the entire aircraft to vibrate as the CGs of the rotor systems oscillate, and under the aircraft's own power.  It is moving.  It is not at rest.

 

Regulation says moving.  Interpretation says taxiing/taking off.  


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#49 Wally

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Posted 25 September 2016 - 14:41

Filling out my book for last night's flight, its a 1.8,...but wait that's off the hobbs and its an R22 which works off the oil light! So do I put 1.8 or 1.7?

I don't know what to do! I feel frozen with indecision, haunted by conflicts of morality, ethics, and common sense!

What do I do!? What do I do!? WHAT DO I DO!!!!!!!!?

AAAAAAAAAAAAAH!
:)

Have another drink and relax. In the long run we are all dead.


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Just a pilot (retired, so I have a LOT of time)...


#50 Guest_pokey_*

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Posted 25 September 2016 - 15:57

the solution is really quite simple, fly only wheel equipped helicopters, and be done with it.



#51 avbug

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Posted 25 September 2016 - 19:32

Rocking the ailerons isn't under it's own power, it's under yours, and it wouldn't be with the intent of flying without applying the aircraft's engine power.  

 

Applying engine power to the drivetrain causes the rotors to turn, which causes the entire aircraft to vibrate as the CGs of the rotor systems oscillate, and under the aircraft's own power.  It is moving.  It is not at rest.

 

Regulation says moving.  Interpretation says taxiing/taking off.  

 

 

Components of the aircraft are at rest.  Operation of the powerplant and rotor isn't part of the flight until the aircraft moves with the intent of flight; not merely operates at its parking spot.

 

A mechanic may perform an engine run and operate the aircraft, but not with the intention of flight.  The rotor turning, being done by a mechanic, doesn't make it flight time, and it's not flight time until a pilot moves the aircraft with the intention of flight.  Vibrating, shaking, rotor turning, electrical system generating...don't make it flight time.

 

The regulation, and interpretation agree, and are quite clear.


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#52 Nearly Retired

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Posted 25 September 2016 - 23:09

Oh man...this is getting tiring...

 

Avbug, yes a mechanic can run up a helicopter or taxi an airplane around with no intention of flying and it's not "pilot flight time."  This is because a person who does not have a pilot certificate of some sort *cannot* log pilot flight time.  I'm sure we all realize this...I'm surprised you don't.  A rated pilot can do those things too and it not be "pilot flight time" if no flight is intended.

 

So what's your point?

 

You make a stupid...yes, stupid analogy about moving the ailerons of an airplane...or something...I didn't really read it that closely.  But then Kona correctly pointed out that the ailerons don't move under their own power, something that *is* required for "pilot flight time" to be logged.

 

Jeebus!

 

There seem to be a lot of helicopter pilots who simply don't understand helicopters.  It's sad, really.  Because if *we* don't understand them, how can we expect the FAA to?

 

When your wings are moving, your aircraft can be said to be "moving" whether you are taxiing or not.  As Kona points out, the regulation does not say, "taxies under its own power."  Clever, those lawyer bastards!

 

 

So...let's revisit a couple of things. 

 

1) I made the statement that for all aircraft, flight time is measured from what we colloquially call "skids-up to skids-down."  Avbug spent three pages disagreeing with me while citing all kinds of fixed-wing and turbine bullshit.  Then I reprinted the definition from FAR 1.1 which says EXACTLY what I stated.

 

2)  I stated that the NTSB considers a "reportable accident" as anything that happens from the time people start to board the aircraft with the intention of flight.  I would guess that many pilots don't even know this.  Avbug spent another three pages disagreeing with me.  Then I reprinted the pertinent section of NTSB part 830 which spells out EXACTLY what I stated.

 

But did Avbug recant?  Did he apologize?  Did he issue a correction?  Did he post, "Yes, you're right, Bob.  I was wrong.  You are clearly the superior intellect and human being."  Nope.  Not a peep out of him.  Hey, when I'm wrong about something, at least I'm man enough to admit it.  And yes, it happens.

 

But noooooo.  Instead of doing anything publicly, Avbug just pesters me on Facebook.  He keeps sending me Friend requests...and I keep turning them down.  It's creepy. I mean, I kind of know now what Corey Haim must have felt like back when he was at one of those famous Hollywood parties when he was fifteen, walking around high on coke and weed and roofies, with a Jack and Coke in his hand, desperately trying to avoid making eye contact with Tom Cruise.

 

Anyway, I think we've beaten this topic to death.

 



#53 avbug

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Posted 26 September 2016 - 03:18

Anyway, I think we've beaten this topic to death.

 

 

 

And yet here you are, out of the ether once again, to prosecute the matter.  You don't really think it's been beaten to death.  No need to lie.


Edited by avbug, 26 September 2016 - 03:38.


#54 avbug

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Posted 26 September 2016 - 03:38

But noooooo.  Instead of doing anything publicly, Avbug just pesters me on Facebook.  He keeps sending me Friend requests...and I keep turning them down.  

 

You cannot speak, it seems, but to tell a lie.  I don't use facebook, you see.  You have an integrity and honesty issue, to say nothing of the maturity of a fourteen year old.

 

 

 

2)  I stated that the NTSB considers a "reportable accident" as anything that happens from the time people start to board the aircraft with the intention of flight.  I would guess that many pilots don't even know this.  

 

 

 

It was irrelevant when you stated it before, and it still is, as it has nothing to do with the logging of flight time.  

 

Every pilot is required to understand NTSB 830, and the definitions that apply.  It's on the knowledge tests for each level of pilot certification, after all.  You would guess incorrectly.  Your guess is still irrelevant.

 

 

 

1) I made the statement that for all aircraft, flight time is measured from what we colloquially call "skids-up to skids-down."  Avbug spent three pages disagreeing with me while citing all kinds of fixed-wing and turbine bullshit.  Then I reprinted the definition from FAR 1.1 which says EXACTLY what I stated.

 

 

 

You incorrectly stated that maintenance time is wheels up to wheels down, and you got it wrong.  Either you're that ignorant, or you lied.  You've just lied about what you said, and it seems to be a consistency for you.  In fact, there's practically nothing that you've stated in this thread which is correct.  Further, the definition of flight time as identified in 1.1 is not at all what you stated, nor what you've just stated.  Wrong again.

 

 

 

When your wings are moving, your aircraft can be said to be "moving" whether you are taxiing or not.  As Kona points out, the regulation does not say, "taxies under its own power."  Clever, those lawyer bastards!

 

 

The regulation doesn't say "taxies under its own power, because some aircraft are pushed back, others are towed.  The regulation encompasses all aircraft, from balloons to gliders to helicopters to airplanes, etc.  No, when the wings are moving it doesn't mean the aircraft is moving; if the rotors are turning, it doesn't mean that the aircraft has moved with the intention of flight, and the legal interpretation already provided clearly bears that out.  If the rotors are turning, a portion of the aircraft is turning, every bit as much as if a propeller is moving, flaps are in transit, ailerons moving, etc.  It's not flight time when a mechanic does it, not flight time when a pilot does it either.

 

 

You make a stupid...yes, stupid analogy about moving the ailerons of an airplane...or something...I didn't really read it that closely.  But then Kona correctly pointed out that the ailerons don't move under their own power, something that *is* required for "pilot flight time" to be logged.

 

 

The regulation doesn't require the aircraft to move under its own power, as you just pointed out.  Now you point out that kona pointed out that moving ailerons aren't moving under "their own power."  Irrelevant.  Moving under their own power isn't necessary, but as you brought it up vicariously through kona, some ailerons in some aircraft do move under their own power, whether hydraulic or electric, including input from the aircraft flight control system.  Still irrelevant, but you're wrong twice.

 

Moving a component of the aircraft, be it a flap, aileron, rotor, propeller, inverter, generator, hydraulic pump, fuel pump, piston, or flight control does not mean the aircraft has moved.  Simply a component of the aircraft.  The regulation requires that the aircraft move with the intention of flight.  Not merely a component.  

 

 

 

But did Avbug recant?  Did he apologize?  Did he issue a correction?  Did he post, "Yes, you're right, Bob.  I was wrong.  You are clearly the superior intellect and human being."  Nope.  Not a peep out of him.  Hey, when I'm wrong about something, at least I'm man enough to admit it.  And yes, it happens.

 

 

 

No need to recant, apologize, or issue a correction.  I'm correct.  You are not.  I've backed up my statements with FAA regulation and legal interpretation, both of which are authoritative, official, and represent the most current information available.  You've done nothing more than engage in name calling, juvenile conjecture, and tell lies.  

 

I won't apologize for your lies.  You can do that for yourself.



#55 helonorth

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Posted 26 September 2016 - 08:45

 

Vibration and rotation are movement.  If they aren't movement, I'd like to know what they are. 

 

 

Allow me to help you, as you seem to be myopically focused on your own interpretation of the regulation, which is irrelevant and, more importantly, incorrect.

 

 

1. May a pilot log as "flight time" to qualify for a certificate or rating under 14 CFR Part 61, or for purposes of qualifying under 14 CFR 135.243( b )(2), that time accrued in a helicopter when the aircraft is sitting on the ground with the engine running and rotor blades turning, but the aircraft has not moved from it's parking place and flight has not yet commenced?

2. Maya pilot log as "flight time" to qualify fora certificate or rating under 14 CFR Part 61, or for purposes of qualifying under 14 CFR 135.243( b )(2), that time accrued in a helicopter after the end of a flight prior to shut down when the helicopter has set down and come to a rest at its parking place, flight has ceased, but the engine is still running and rotor blades are still turning? 

 

 
The answer to all three questions is that flight time may not be logged.
 
If it's in the same place you left it, it hasn't moved. Not so hard to understand. Nobody cares if you don't agree with it. 


#56 Astro

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Posted 26 September 2016 - 09:32

Simply log;

"blade time" as PIC

"skids up to skids down time" as flight time

Problem solved!

#57 kona4breakfast

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Posted 26 September 2016 - 14:19

 

 

 

Allow me to help you, as you seem to be myopically focused on your own interpretation of the regulation, which is irrelevant and, more importantly, incorrect.

 

 

1. May a pilot log as "flight time" to qualify for a certificate or rating under 14 CFR Part 61, or for purposes of qualifying under 14 CFR 135.243( b )(2), that time accrued in a helicopter when the aircraft is sitting on the ground with the engine running and rotor blades turning, but the aircraft has not moved from it's parking place and flight has not yet commenced?

2. Maya pilot log as "flight time" to qualify fora certificate or rating under 14 CFR Part 61, or for purposes of qualifying under 14 CFR 135.243( b )(2), that time accrued in a helicopter after the end of a flight prior to shut down when the helicopter has set down and come to a rest at its parking place, flight has ceased, but the engine is still running and rotor blades are still turning? 

 

 
The answer to all three questions is that flight time may not be logged.
 
If it's in the same place you left it, it hasn't moved. Not so hard to understand. Nobody cares if you don't agree with it. 

 

 

I've merely been pointing out that the word the regulation OUGHT to use is "taxi," not "move," in order to square the regulation's meaning with the FAA interpretation.  The "away from its parking place" is not in the regulation itself, it was added in the interpretation.

 

It is relevant because the interpretation modifies what the word "move" means in a substantive way.  Is this myopic?  Yes, because ambiguity in language in federal regulations has significant ramifications.


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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.

#58 Nearly Retired

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Posted 26 September 2016 - 18:58

Man-oh-man.  Avbug, you seem particularly dense and needlessly argumentative.  I bid you...nay, I *beg* you to go back and read my post #40 in this thread.  Read it slowly - it's not long.  In it you will find the FAA's definition of what constitutes "time in service" with respect to maintenance functions.  Of course manufacturers can use whatever other "metrics" they please, but they cannot use anything *less* restrictive than "wheels up-to-wheels down" because THAT is what the FAA considers "component time."  Why do you not understand this relatively simple concept?  You can filibuster and rant and blow smoke all you want that I'm wrong, but I'm not.  You are, Captain

 

As for NTSB notification of accidents, I never said it had anything to do with the FAA's definition of logging flight time...OTHER THAN...from the NTSB's standpoint, a reportable accident occurs from the time people start boarding the aircraft for a flight.  CFR 830.5 requires "the operator" to report such accidents immediately.  In many cases that would be THE PILOT, because not all pilots work for a living (some own their own aircraft), and not all working pilots are employed by others (they own their own company). In fact, in my last corporate flying job, although I was not the owner I certainly was The Operator of said helicopter. 

 

So THE PILOT (meaning me) might be held responsible for an accident if, say, a vehicle ran into the aircraft after the pax were boarded but before the engine or rotors were even started, even though he/I was nowhere even close to logging any pilot flight time.  That is all.  Again, it shouldn't have taken a Rhodes Scholar such as yourself to "get" that connection.

 

Avbug, it is *YOU* who keeps bringing up the 747.  It is *YOU* who keeps going off on irrelevant tangents, cluttering up this thread (perhaps deliberately?) with nonsense.

 

For any long-suffering readers who've managed to stay with us all the way down here, I'll restate my case: I think the way the FAA defines "Pilot Flight Time" for helicopter pilots is wrong and should be changed.  Period.  And now there is at least one FAA POI who agrees with me.

 

Hey, maybe it's the start of a...well...jeez, pardon the bad pun...movement?



#59 adam32

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Posted 26 September 2016 - 19:23

So let me get this straight...logging "flight time" while doing pre-flights is wrong? Same with when hot-fueling??

Dang...now I see why it takes a heli CFI 5 years to get 1000 hours!
  • Nearly Retired likes this

#60 Fred0311

Fred0311

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Posted 26 September 2016 - 19:44

I feel like I'm reading a less funny screen play for grumpy old men.
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