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Logging PIC Time - Employers Rule?


Whiteshadow

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LTE:

 

For me it's always been and always will be about flight time, and that's what gets logged. I personally don't consider sitting on the ground as flying.

 

Well good for you. But that's funny, because the FAA certainly does consider sitting on the ground as flying. For airplanes, that is. Once an airplane pilot taxies away from the parking spot and is headed for the runway with the intention of taking off, all of that time is considered flying (pilot flight time). Even when they sit there for however many minutes at the end of the runway doing the runup and holding for landing traffic...FLIGHT TIME! Same for after landing! All that time spent sitting on the ground, taxiing to the parking spot is still considered flying. (Obviously this amount of time varies depending on how big the airport is. But some airports that serve general aviation are quite large and involve long taxi times.)

 

Strange, isn't it how neurotic helicopter pilots get their panties so wadded up about how FLYING is *only* that time spent in the air, when in fact the FAA doesn't seem to agree on that issue?

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But that's funny, because the FAA certainly does consider sitting on the ground as flying. For airplanes, that is.

 

 

I agree with most everything you said--but the ground movement of aircraft prepping to take off also applies to all the wheeled helos too. Skids, obviously not--when you pickup, is when you pickup and same for coming to rest.

 

Why does most everyone beat around the bush and not quote the actual 14 CFR 1.1?

 

Flight time definition:

Flight time means:

  • (1) Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing; or

    (2) For a glider without self-launch capability, pilot time that commences when the glider is towed for the purpose of flight and ends when the glider comes to rest after landing.

Straight out of 14 CFR 1.1. Rather clear and requires no interpretation.

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Flight time definition:

Flight time means:

 

(2) For a glider without self-launch capability, pilot time that commences when the glider is towed for the purpose of flight and ends when the glider comes to rest after landing.

 

Straight out of 14 CFR 1.1. Rather clear and requires no interpretation.

Seems to me that a glider pilot should not be able to start logging flight time until its released from the tow plane?

 

These things may not need interpretation, but they do need an answer to, why did you write it that way?

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No, METT-TC, we're all familiar with that reg and this issue has been hashed to death on these very pages. We understand that the pilots of wheeled helicopters can log flight time when they're on the ground as long as they're ground-taxiing for takeoff. They just don't taxi very far or very long as airplanes typically do.

 

I just find it funny that so many helicopter pilots get all huffy that pilot flight time is ONLY that time when the skids are off the ground and that anything else is "cheating" when the regs clearly allow otherwise.

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Guest pokey

I feel like I'm missing something... every time this fella comments the hate train rolls on by. What gives?

 

yes, you most certainly are. It's not only him, and myself? i am 100% justified in every remark i make about this guy. I'll just leave it there, unless the owner of this site cares to take down all the lies and bull that he made up about me? well then, eye for an eye.

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No, METT-TC, we're all familiar with that reg and this issue has been hashed to death on these very pages.

Huh. I must have missed those posts.

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The relevant FAA Chief Legal Counsel interpretation you'll need is https://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2007/lloyd%20-%20(2007)%20legal%20interpretation.pdf

 

Not needed. Once again, 14 CFR 1.1 applies...the FAA legal was having to shoot down "interpretations" by the village idiot. Legal counsel went with what 1.1 states.

 

The thread you're seeking is http://helicopterforum.verticalreference.com/topic/19846-ye-olde-flight-time-debate/

 

I'm not seeking-have you all read THIS message thread? It is so full of fail that it is rather astounding to me what my fellow professionals try to promulgate. Unfortunately, primacy applies, so it deserves correcting.

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The relevant FAA Chief Legal Counsel interpretation you'll need is https://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2007/lloyd%20-%20(2007)%20legal%20interpretation.pdf

 

Not needed. Once again, 14 CFR 1.1 applies...the FAA legal was having to shoot down "interpretations" by the village idiot. Legal counsel went with what 1.1 states.

 

The thread you're seeking is http://helicopterforum.verticalreference.com/topic/19846-ye-olde-flight-time-debate/

 

I'm not seeking-have you all read THIS message thread? It is so full of fail that it is rather astounding to me what my fellow professionals try to promulgate. Unfortunately, primacy applies, so it deserves correcting.

 

 

Seeing as you're quoting me and replying to me within my own quote, might you be referring to me when you ask if "you all" have read this thread? Why yes, I have. I've responded to it several times. READ.

 

Your chutzpah not withstanding, the Chief Legal Counsel letters of interpretation are not trivial, and exist for a reason. In this particular case, the language of the regulation (which has been quoted in threads on this subject repeatedly, despite your assertion to the contrary) states that flight time for the purposes of logging begins when the aircraft first moves under its own power. This is a simple concept in a fixed wing aircraft. There are those who believe that the regulation encompasses helicopters with the rotor moving, as the wing is in motion, even though the fuselage and other structure is not.

 

The Administrator made clear that sitting with the rotor turning does NOT constitute loggable flight time insofar as the regulation is concerned. If some feel that they wish to log it, they may do so, along with time in yellow aircraft, time spent reading Cosmo on the toilet, and time spent at the dartboard...as none of those other things constitute loggable time for the purposes of the regulation either. In an adult conversation on the topic, which is one of legality, only the regulation and that which pertains to the regulation is of any consequence. What people *think* should be the case is irrelevant.

 

There are three chief means of understanding the regulation. You do not seem to have a grasp of this. The primary means of understanding the regulation is the Federal Register preambles at the time the regulation is released in final form. This not only provides the language of the regulation, but the intent and the process and commentary that went into it's design and writing. The regulation itself is also used, and the Chief Legal Counsel, and Regional Legal Counsel are authorized by the Administrator to interpret the regulation. These interpretations are defensible, and should be considered by those seeking an understanding of the regulation. The legal counsel interpretations are not merely about "shooting down the village idiot." They have legal value.

 

I provided link to a more detailed discussion of the matter. You say you're not seeking that thread, but you also say you must have missed it. You've missed it no longer. It's been provided for you. If you bother to read it you'll find that the regulation was discussed and quoted repeatedly there.

 

As for employers dictating what an employee will put in his or her logbook, I've never heard of such a thing, nor would I tolerate that from an employer. The employer may dictate one's personal logbook when it becomes the employers. Otherwise, the employer may keep his or her own time. The only consideration an employer should have regarding what goes in a logbook is the employee of a certificate holder who has flight time limitations under the employers operating certificate, to include all commercial flying. An employee that has logged other flight time or flight time in excess of that performed for the employer, has limited his or her utility to the employer; more flying elsewhere means less that can be performed for the employer. It's for this reason that many employers stipulate that pilots may not perform outside flying, as a condition of employment. Logging outside flying may represent a breach of that stipulation, and legal documentation of the aggregate flying time allowed by that pilot.

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blah, blah, extraneous, extraneous.

 

 

 

 

You do like arguing. Even if another senior pilot apparently agrees with you on the majority.

 

Two things I shall say. Once again, FAA Legal Counsel isn't needed in this--unless you (not actually "you" as it seems we both agree on this) are that guy that is on a skidded helo and you are trying to incorrectly figure out how to start logging flight time before you pick that aircraft up off the ground. I can't prove a negative (and neither can FAA Legal) except to say that I agree with 14 CFR 1.1. On the wheeled aircraft I have flown, flight time starts earlier in the FAA world if I ground taxi / conduct engine checks after ground movement and then take off. My skidded aircraft-hell no. I am pretty sure you agree with me on this (and the FAA)? None of us agree with the idiots trying to do otherwise (and keep/say it is legal).

 

Second, I have READ this topic-including the thread byline, the many underwhelming responses (not all, but many/most) where people are putting out absolutely bizarre info--problem is that many without very much experience are also reading this and the straight up BS muddles the definitive in the FAR. I finally had to respond when one of our posters said this: "But that's funny, because the FAA certainly does consider sitting on the ground as flying. For airplanes, that is.". While he has the grasp of the rest it seems, that is a pretty big error excluding helicopters (probably because his time is all in skids and he hadn't thought beyond them to those with wheels). 14 CFR 1.1 applies to all airplanes and helicopters the same--I know you already know this, but you can argue against me just because I restated it if you want...

 

So, don't know what you are arguing in my posts above and here, except to be contrary to what you agree with because someone else is saying it their words and not yours? But have at it. Everything I said is factual and legal and the rest is extraneous.

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...None of us agree with the idiots trying to do otherwise (and keep/say it is legal).

 

Logging flight time while you drive your aircraft down the taxiway is as idiotic as all those CFI's with whom I've flown on numerous time-building flights logging dual given/PIC time while just sitting there with their thumbs up their asses enjoying the view (or more accurately, holding a camera in their hands taking pictures, talking on their phones with their girlfriends, or facebooking on their ipads) while I (a rated pilot) do all the work!

 

If I worked for the FAA I'd change the definition to specifically mention helicopters and use precise language to the effect of something like, skids/wheels up to skids/wheels down yada yada yada...

 

,...but then we'd have all the wheeled guys on here with their "idiotic interpretations"!

 

Starting sh*t is a great way to start the weekend,...but will anyone bite?

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Clearly it is, else the conversation would not have occurred.

 

The matter is settled by the Chief Legal Counsel interpretation, and therein lies the value.

Absolutely. You're right. I'm wrong. You're pretty. I'm not. You win. G'day.

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Maaaaan, I was so happy in Troll Heaven, or Troll Hell...or wherever it is I hang out. But then I had to be dragged out and into this subject again.

 

Oh METT-TC, why so pedantic, dude? I didn't "make an error in excluding helicopters" when it comes to that bit about Pilot Flight Time beginning when the aircraft moves under its own power for the purpose of flight. I left out helicopters for the sake of brevity. We know that FAR 1.1 applies to them as far as when Pilot Flight Time starts being logged, but wheeled helicopters typically do not have any taxi time. They might leave the parking spot and taxi to the pad, or from the pad to parking after landing, but how much time is that...a minute at either end? Not even half a tenth total? Come on.

 

Airplanes on the other hand leave parking, taxi off the ramp, down a taxiway to the end of the runway where they do their pretakeoff checks. Some airplanes require more time than others. Once ready to go they wait for a break in the sequence. Depending on the airport, the time from brake release to takeoff can be quite protracted. Similar thing at the other end. An airplane might have a long taxi from the runway exit point to parking. And it's all considered Pilot Flight Time. Butters might consider it "Idiotic," but it is what it is.

 

The total amount of time spent "flying" on the ground might be as much as .2 or more for the fixed-wing pilot. There is simply no comparison for helicopter pilots. So it is pointless to mention that S-92 pilots can log more flight time than they actually fly.

 

You and Avbug are two peas in a pod. For you to call Avbug argumentative is like Natalie Portman calling Megan Fox pretty. It's like Pacino calling DeNiro a great actor. It's like Chuck Aaron calling Bob Hoover a good pilot. You get the idea.

 

Pilots of skid-equipped helicopters hang on to "The McPherson Letter" as if ol' Becky is God herself. They probably have bumper stickers that read:

She said it

I believe it

That settles it!

 

But wait...

 

Neither Ms. McPherson nor Viola Pando, her assistant in this matter, are pilots. THEY'RE LAWYERS. So they know next to nothing about how airplanes and helicopters fly.

 

In fact, it turns out that Ms. McPherson is no longer even with the FAA. She's in private practice at a big Washington D.C. law firm. One of her new clients was trying to start an Uber-like service using (ahem) private pilots to fly people around for money. It was to be called "Airpooler, Inc." (Carpool...airpool...clever, eh?) Becky petitioned Mark Bury, the FAA's current Assistant Chief Counsel in their behalf. Bury cut her off at the knees, OF COURSE, stating that such a service would be commercial in nature for both the pilots and the aircraft, effectively putting the kibosh on Airpooler, Inc.

 

It is interesting and more than a little ironic that Ms. McPherson would take up the cause of a start-up company that was attempting to do something that is CLEARLY against the FAR's. I mean, you'd think that certainly she would have a handle on what's legal and what's not! And any moron can see that an Uber-for-the-air service would be a commercial operation, amiright? But that's the thing about FAR's: they're arguable; they're open to interpretation. Did Becky really think she could get away with that gambit?

 

Ms. McPherson's former "ruling" on Pilot Flight Time has never been tested in court. And so the common interpretation stands. Which is perhaps a good thing. Can you imagine the chaos at places like PHI and Bristow, where pilots on jobs with a ton of short flights and lots of landings would run out of flight time in the middle of their duty day? I mean, there were days when I'd spend nine or ten hours in the cockpit yet only log 7.9.

 

So METT-TC, don't bust my balls about wheeled helicopters being able to log Pilot Flight Time on the ground. We know that; we get that. It's just that it's irrelevant.

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I understand lower time guys trying to snag every .1 they can, but is this really the best thing for us to argue about? This horse has been beat to death so many times I think theres only a little bloody hair left. How about utility versus EMS pilots? Bell versus Eurocopter, ahem excuse me airbus. Or why does MD have a crippling fear of money and success?

Edited by Fred0311
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Oh I got another. We all know dogs are better than cats. But is it acceptable as a single male helicopter pilot to have a cat instead of a dog because they're more independent? I'm away too much to be able to take care of a dog.

Edited by Fred0311
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So METT-TC, don't bust my balls about wheeled helicopters being able to log Pilot Flight Time on the ground. We know that; we get that. It's just that it's irrelevant.

 

Takes head, bounces against wall. Your lack of experience in flying turbine aircraft is being restated. AH-64, UH-60/S-70, CH-47, S-76, S-92 pilots etc (thousands of pilots and hundreds of movements per day) have the ability to log a 0.2 to 0.3 in their FAA logbook anywhere from 50 to 100% of the time on the FIRST flight of the day because the manufacturer wants to ensure engine degradation against a known parameter has not occurred. This generally entails a movement into the wind and / or movement away from other aircraft / crews as you are pulling in quite a bit of collective for this. U.S. military aviators log differently than FAA, but can maintain an FAA logbook for when they get out. EASA logs differently than both (not going there as it would just make you all mad).

 

But your fail has been addressed--because you were out of your lane and had no idea.

 

And Avbug is still pretty. And I am not.

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Is this what happens to retired helicopter pilots? They come on VR to argue semantics with each other? Yeesh

 

 

 

Oh I got another. We all know dogs are better than cats. But is it acceptable as a single male helicopter pilot to have a cat instead of a dog because they're more independent? I'm away too much to be able to take care of a dog.

 

I think that's perfectly reasonable. The dog can be your reward for retirement, or taking an EMS job. (Which isn't too different)

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Damn, its almost as if the bug split in two and is arguing with himself!

 

As for a single dude owning a cat that always seems kind of strange? I remember a guy once who flew ENG who took his dog up with him,...that could be cool?

 

,...and Bell over Eurocopter, because the 222 is my all time favorite helicopter!

 

I also prefer redheads! :)

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Good God. Another Avbug. Intent on proving his dick is bigger than everyone else's.

 

Don't we have enough pedants around here?

 

Okay, METT, you "win" if that's what you need.

 

And you obviously do.

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It's simple: log what you believe you flew, period. Do it consistently and as you fly it. Do not go back and apply rules of thumb, adjust or any of that BS. If your records are reviewed for consistency, you are starting from the strongest position with this technique: those reviewing your records either smell a rat and are looking for corpses or they want to see confirmation. If your records don't vary by considerable, inexplicable amounts, you are gonna be rock and roll. Employers may charge, and log differently than the pilot without fraud involved.

 

That doesn't mean you will be given any bump, If your records seem to be a couple tenths over consistently and you are close to the minimums, while Competitor A's records are jam on and exceed the minimum, all things being equal, you're not getting the job.

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The bigger issue here isn't who is right or wrong; it's the fact the confusion exists...mainly due to the regulator and they refuse to do anything about it.

 

The same argument has been raging for years in Canada. Our definitions are virtually the same and just as is the case in the US, it appears that the law is not being enforced consistently.

 

In 2005 Transport Canada released a general aviation policy advising stakeholders that some TC inspectors had been erroneously interpreting flight time as equalling air time for skid equipped helicopters. The policy letter which can be seen in the first post of the forum went on to state that stakeholders and inspectors should use the ICAO definition of flight time (rotors turning to rotors stopped) until the CARs were amended.The CARs were never amended and TC cancelled the letter in 2011 with no further clarification to stakeholders.

 

Today the regulator has provided numerous conflicting interpretations, many of which have been posted on the forum. The most recent from the Director General and TC Heafndquarters now claims flight time equals air time. His latest response can be seen on page 52.

 

As many of you have pointed out however, the regulators interpretation means nothing if it doesn't hold up in court. Coincidentally a recent Supreme Court of British Columbia decision seems to directly contradict TCs latest position. The link to this court decision is found on Page 55.

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...the ICAO definition of flight time (rotors turning to rotors stopped)

Your's is a simple fix. Change "flight time" to "PIC time", then there would be no confusion that it does not equal "air time"!

 

Using the words "flight" and "air" to describe two seprate things?,...only a bureaucrat could be that bone headed!

 

I like "air time",...we should use that!

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It's the inconsistency that amuses me. The U.S. military does it differently than the FAA which apparently does it differently than EASA...and on and on. But what's really funny are those helicopter pilots who staunchly maintain that YOU'RE NOT FLYING UNTIL THERE'S AIR UNDER YOUR LANDING GEAR, DAMMIT! And that's just not true for all pilots and, (let's give a nod to METT-TC) not even all helicopter pilots, hundreds of thousands of whom might log a whole .2 or maybe a .3(!) on...well...the, um, first flight of the day prior to taking off.

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