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Logging PIC Time - Employers Rule?


Whiteshadow

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It strikes me that no natter where you operate it would be a simple fix. First the regulator needs to come to a consensus within their own organization . According to both of these forums both the FAA and TC are are interpreting definitions in a variety of ways. In Canada we refer to it as "regional disparity" , but the fact is that it is no longer regional; even within regions, from one inspector to the next,, the regulations are being enforced/applied differently. This is well documented in Canada and by the sounds of the posts on here, it appears that how you log depends on which company you work for.

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It strikes me that no natter where you operate it would be a simple fix. First the regulator needs to come to a consensus within their own organization . According to both of these forums both the FAA and TC are are interpreting definitions in a variety of ways. In Canada we refer to it as "regional disparity" , but the fact is that it is no longer regional; even within regions, from one inspector to the next,, the regulations are being enforced/applied differently. This is well documented in Canada and by the sounds of the posts on here, it appears that how you log depends on which company you work for.

 

 

The issue of logging is a legal one. The requirement to log time to show recency of experience or to meet the requirements of a certificate or rating is established by the regulation, as are the specifics of logging time.

 

A company has no say in the logging of time. That matter is established by the FAA, and is clear. Attempts by posters here to muddy the water or to impose their own ideas are pointless and irrelevant, and do nothing to alter the regulation of it's meaning. That meaning has been clearly spelled out.

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Just leave the ground handling wheels on your skid equipped helicopter and viola! A wheeled helicopter that will be "moving under it's own power" on startup so log time from the ignitor to rotor brake!

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Just for shits and giggles lets entertain some math for all you R22 pilots who log off the hobbs.

 

Now I doubt anyone does each rating at its minimums so the difference between logging from the hobbs vs. a timer probably wouldn't put anyone below minimums for a checkride, however,...

 

To become a 200 hour pilot and thus employable lets guess;

 

50 hours xc with an average flight of 1.7 = 29 flights

150 hours local training averaging 1.2 = 125 flights

That's 154 flights to become a 200 hour R22 CFII

 

Subtract a 0.1 from each flight and that's 15.4 hours

 

15.4 hours at $300/hr = an additional $4,620 to get to 200 hours.

 

Now how about that R22 ATP candidate?

 

500 hours xc averaging 1.7 = 294 flights

700 hours local training averaging 1.2 = 583 flights

So a 1200 hour ATP wannabee has flown 877 flights

 

Take off a 0.1 from each flight and that's 87.1 hours

 

Say an average CFI gets 20 hours a month, that's now 4.4 more months he must work as a CFI to get to that ATP 1200 and his checkride.

 

Now its late and I'm not the best at math (plus I didn't check the FAR's for exact minimums) but these numbers don't seem like the end of the World to me?

 

,...unless maybe you're sleeping in your car and living off peanutbutter and Ramen! :D

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The issue of logging is a legal one. The requirement to log time to show recency of experience or to meet the requirements of a certificate or rating is established by the regulation, as are the specifics of logging time.

 

A company has no say in the logging of time. That matter is established by the FAA, and is clear. Attempts by posters here to muddy the water or to impose their own ideas are pointless and irrelevant, and do nothing to alter the regulation of it's meaning. That meaning has been clearly spelled out.

The meaning has been recently spelled out by the regulator in Canada as well, unfortunately the courts have also recently contradicted the regulators interpretation. http://www.canlii.org/en/bc/bcsc/doc/2016/2016bcsc2214/2016bcsc2214.html?searchUrlHash=AAAAAQCO4oCcYWlycGxhbmXigJ0gT1Ig4oCcYWlybGluZeKAnSBvciDigJxoZWxpY29wdGVy4oCdIE9SIOKAnEF2aWF0aW9u4oCdIE9SIOKAnGFpcmNyYWZ04oCdIE9SIOKAnGFpcndheeKAnSBPUiDigJxhaXJwb3J04oCdIE9SIOKAnGFpciBzZXJ2aWNlc-KAnQAAAAAB

 

http://www.internationallawoffice.com/Newsletters/Aviation/Canada/Bersenas-Jacobsen-Chouest-Thomson-Blackburn-LLP/Helicopter-pilot-fails-in-constructive-dismissal-case#

 

With all due respect, the regulator themselves have muddied the water by spelling out several different meanings over the years lol. Like issuing a policy letter that advised stakeholders to log as per ICAO definition. This policy letter was in effect for 6 years until it was suddenly cancelled in 2011 with no further clarification or explanation. They also refuse to enforce their interpretation when challenged.

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Just out of curiousity: in the US is it industry standard for Flight Training Units to provide students with the minimum licensing requirements in "Air Tine"?

This is not an attempt to argue, but a genuine question.

In Canada that almost never happens. For instance a pilot requires 100 hours flight time for CPL, but the majority of schools don't give students 100 hrs "air time" or time in the air. TC is fully aware of this.

 

Don't take my word for it. Have a look at this letter published in "Helicopters Magazine" from 2011.

http://www.mydigitalpublication.com/publication/index.php?i=59508&m=&l=&p=7&pre=&ver=html5#{"page":7,"issue_id":59508}

 

Nothing has changed with regards to this standard practice despite the recent interpretations from Headquarters and the Director General that state flight time is the same as air time for skid equipped helicopters.

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Guest pokey

does it really matter if you just hired a guy with exactly ONE thousand hours, but the way he logged his time?,, he had only 950? i'm sure the insurance company will try to weasel out of paying if they catch wind once he wrecks. Will the FAA really care? maybe. like butters said , it all boils down to money.

 

When i 1st started training in fixed wings, the hobbs (that went in my logbook) was hooked up to the oil pressure switch on the engine. I can't imagine how many of us the went thru that school were a few tenths short.

 

My personal helicopter? i have 2 hobbs (like everyone else),, what do i log?,,,,,,,,,,,i don't ! :P and i don't expect to get caught and tossed in the pokey for not logging time.

 

what is defined? has been beat to death over and over, go by the "rules" if you want to be a "professional" (and don't get caught if ya don't)

 

 

oh and? happy st paddy's day:

 

Frenchman, German, & Irishman, in pub drinking beer, fly lands in all 3 beers at same time. Frenchman pushes his aside in disgust. German removes fly & continues drinking. Irishman picks out fly and yells at it "YOU SPIT BACK EVERY LAST DROP ! YOU BASTARD! ! ! "

Edited by pokey
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Just out of curiousity: in the US is it industry standard for Flight Training Units to provide students with the minimum licensing requirements in "Air Tine"?

This is not an attempt to argue, but a genuine question.

In Canada that almost never happens. For instance a pilot requires 100 hours flight time for CPL, but the majority of schools don't give students 100 hrs "air time" or time in the air. TC is fully aware of this.

 

Don't take my word for it. Have a look at this letter published in "Helicopters Magazine" from 2011.

http://www.mydigitalpublication.com/publication/index.php?i=59508&m=&l=&p=7&pre=&ver=html5#{"page":7,"issue_id":59508}

 

Nothing has changed with regards to this standard practice despite the recent interpretations from Headquarters and the Director General that state flight time is the same as air time for skid equipped helicopters.

 

I can almost guarantee everyone in the US, including people here arguing against, put the "customer's hobbs" in their logbook while training. (in most cases not in a nefarious way but they didn't know and their instructor maybe didn't either - blind leading the naked and all that)

 

As pointed out by Butters though, unless they actually went for their checkride at the absolute minimums it doesn't really matter.

 

Also note, how many DPEs thereby signed and thereby endorsed an 8710 with "customer hobbs" which was then routed to Oklahoma and endorsed by the FAA themselves.

 

Burn the whole institution down they are all in the wrong !!! hahhaaha

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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?

 

 

Even funnier is the whole argument she made in favor the air pooling thing was in direct contradiction to a Letter of Interpretation that she herself had written !!!

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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.

No link to vertical magazine forum I'm referencing.

 

http://forums.verticalmag.com/topic/19518-flight-time-vs-air-time-personal-logbook/page-1

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Just out of curiousity: in the US is it industry standard for Flight Training Units to provide students with the minimum licensing requirements in "Air Tine"?

 

One of my most favorite stories about this issue occurred during my instrument training in the 44!

 

After my first flight in the 44 my 4,000 hour instrument instructor (who filled out my logbook after each flight) says to me, "We (as in the school) add a .2 to the hobbs for each flight in the 44 since its hobbs works off the collective, as opposed to the 22 which works off the engine."

 

[\video]

 

By the way, we were a pretty decent sized school with five R22's and two R44's at our location,...plus two more in other States!

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One of my most favorite stories about this issue occurred during my instrument training in the 44!

After my first flight in the 44 my 4,000 hour instrument instructor (who filled out my logbook after each flight) says to me, "We (as in the school) add a .2 to the hobbs for each flight in the 44 since its hobbs works off the collective, as opposed to the 22 which works off the engine."

[\video]

By the way, we were a pretty decent sized school with five R22's and two R44's at our location,...plus two more in other States!

I've met many pilots who use this method. 0.1 for start up and 0.1 for shut down. So if a school used this on training flights that generally about an hour in length, a pilot would have 80 hrs instead of the 100 required for a CPL in Canada. This is pretty much which is happening at most FTUs in Canada. So while some posters write this off as a minimal 10th of an hour here and there, it's actually a 20% reduction in hours. Pretty significant if you ask me. I'd ask those who minimize this if they would be this nonchalant if a pilot was that liberal when logging air time on aircraft components.

 

There currently is no minimum standard being enforced because of this confusion and when you consider ICAO minimum licencing and fixed wing standards in Canada, the standards are significantly less. I beleive CPL helicopter licensing standard ICAO is 160 hours and Canadian fixed wing is 200 hours.

 

This method, however,doesn't account for any intermediate landings between start and shut down. Many jobs have multiple short flights per hour with numerous landings between dart and shut down. I've worked on several wher the time on the ground )running) exceeds time in the air. Other jobs like tour rides and aerial spray are similar...

 

Now take this conversation and discuss FATIGUE management and Flight time limits under the regs...20% (or more) difference from one pilot to the next is pretty big. A pilot who flew 8 hrs per day air time would have 10 plus hrs of ICAO flight time PER DAY.

 

Again...which pilot is "executing to standard"?

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And that's the only issue I have with the varying interpretations. Many jobs have you turning and burning sitting in the seat. If you log that, you're off at 3 or 4 in the afternoon while I'm doing your work and mine.

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So let's see how much variation in interpretation there really is...

 

Several very basic questions have been distributed to industry stakeholders (within Canada and internationally). They've also been posted in the Canadian Forum. Why not give them a try for shits and giggles.

 

Here's the first 2:

 

Q1. A pilot flies a Bell 206 Jet Ranger on skids between CYMO (Moosonee Airport) and the Lagoon Heliport (Moose Factory Island) and makes the following entries in his pilot flight log.

Time up is the moment his skids leave the earths surface and Time down is the moment his skids make contact with the earths surface at the next landing.

 

Engine Start Time/Blades turning: 754

 

Time Up Time Dn Air Time Starts Comments

800 804 4 min 1 CYMO Lagoon

809 812 3 min 0 Lagoon CYMO

816 819 3 min 0 CYMO Lagoon

822 825 3 min 0 Lagoon CYMO

829 833 4 min 0 CYMO Lagoon

838 841 3 min 0 Lagoon CYMO

844 847 3 min 0 CYMO Lagoon

850 853 3 min 0 Lagoon CYMO

855 858 3 min 0 CYMO Lagoon

904 909 5 min 0 Lagoon CYMO

 

Engine Shutdown @ 912; Rotors Stopped @ 914

 

 

A1. For the above entries: The pilots calculated Flight Time and Air Time respectively, should be:

 

a. Flight Time = 1.3 / Air Time = 0.6

b. Flight Time = 0.6 / Air Time = 0.6

c. Flight Time = 1.2/ Air Time = 0.6

d. Flight Time = 1.3 / Air Time = 1.3

e. Flight Time = 1.3/ Air Time 1.0

f. Flight Time = 1.2 / Air Time = 1.2

g. Flight Time = 1.2/ Air Time 1.0

h. Flight Time = 0.7/ Air Time = 0.6

i. Other: Flight Time = / Air Time =

 

Q2. A pilot flies a Bell 206 Jet Ranger on skids from CYCN to CYTS with no landings enroute. He makes 1 landing at his destination and shuts down the helicopter.

He makes the following entries in his pilot flight log.

Time up is the moment his skids leave the earths surface and Time down is the moment his skids make contact with the earths surface at the next landing.

 

Engine Start Time/Blades turning: 754

 

Time Up Time Dn Air Time Starts Comments

800 824 24 min 1 CYCN CYTS

 

Engine Shut Down @ 830; Rotors stopped @ 831

 

A2. For the above entries: The pilots calculated Flight Time and Air Time respectively, should be:

 

a) Flight Time = 0.4 / Air Time = 0.4

B) Flight Time = 0.6/Air Time = 0.4

c) Flight Time = 0.5 / Air Time = 0.4

d) Flight Time = 0.4 / Air Time = 0.3

e) Other: Flight Time = Air Time =

 

 

FYI, some respondents have implied that the scenario in Q1 is not a real world scenario. I can attest that this scenario is real world and is exactly what occurrs on a contract that occurrs 12 weeks per year in Northern Canada (for more than 40 years).

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So let's see how much variation in interpretation there really is...

 

 

 

 

In Canada, maybe. In the US, it's irrelevant. The regulation and the interpretation has been given. Individual opinions are without merit, beyond those with the authority to provide such interpretation (Administrator and those designated by the Administrator: Chief and Regional Legal Counsel).

 

There is no other interpretation of value or merit, or with authority in the US.

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In Canada, maybe. In the US, it's irrelevant. The regulation and the interpretation has been given. Individual opinions are without merit, beyond those with the authority to provide such interpretation (Administrator and those designated by the Administrator: Chief and Regional Legal Counsel).

 

There is no other interpretation of value or merit, or with authority in the US.

 

 

Official interpretation has been given in Canada by Headquarters and the Director General (on behalf of the Minister) also, but it obvious to everyone that TC still is not enforcing it consistently and recent court decisions contradict the official interpretation. MANY MANY pilots, schools and operators are not logging in compliance with the official interpretation. So why not humour me And play along? Answer the questions if you're so confident it's not happening in the US.

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I would say the FAA is much more concerned with a pilot's ability than whether they have an extra point one logged per flight. It doesn't seem like TC would be terribly concerned what some guys are logging in a 206 on some job along way from the middle of nowhere, either. "You don't have 5,000 hours flying between here and there, you only have 4,000!" Oh.

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The issue of HOW TO LOG FLIGHT TIME!!! really doesn't apply to pilots who've already gotten their ratings. I mean, who cares? It's rather all about time accrued in hot pursuit of those ratings.

 

A million years ago when I was learning to fly airplanes (I think Avbug was one of my old, decrepit instructors) there were two hour recorders in the plane. One was in the tach - we ignored that one "That's for maintenance," I was told. Sure enough, that's the one Maintenance used to figure out when the next 100-hour inspection was due.

 

The other was your standard-issue Hobbsmeter, and that was the one used for the time that my instructor put in my logbook...and oh yeah that's the one they billed *me* off of.

 

I did notice that the Hobbsmeter usually read .2 *more* than the one in the tach. I never knew why - it's just THE WAY IT IS.

 

It did not seem to bother anyone that we were logging "flight time" while taxiing out and in at the beginning and end of each flight. Some of my instruction took place at little dinky airports where the taxi time was short, but some occurred at larger, tower-controlled fields like KFRG on Long Island, New York or Teterboro Airport in, ugh, New Jersey. Taxi times at these places can be long depending on which runway is in use and how many planes are in the pattern.

 

So theoretically a fixed-wing pilot who takes his checkride with exactly 40 hours in his logbook might only have, ohhh, 32 hours in the air, with his wheels actually off the ground. And you know what? NOBODY CARES. Nobody cares because the national average for pilots getting their ratings was, like, 55 and probably still is.

 

But this is a *huge* deal for helicopter pilots, who think that if you log even one-tenth of a tenth of an hour when your skids aren't clearly and completely off the ground then you're a lyin', cheatin', cold dead-beatin', two-timin', double-dealing, mean mistreatin'...fraud or something. (*Apologies to singer Patty Loveless.)

 

And that's what I find funny.

 

Next up! We'll discuss the hot, steaming controversy over whether we should put one or two spaces after a period when typing a post such as this. Oh, that should be fun!

 

 

 

 

*If you didn't get the reference to a great country music song, watch the video here.

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Official interpretation has been given in Canada by Headquarters and the Director General (on behalf of the Minister) also, but it obvious to everyone that TC still is not enforcing it consistently and recent court decisions contradict the official interpretation. MANY MANY pilots, schools and operators are not logging in compliance with the official interpretation. So why not humour me And play along? Answer the questions if you're so confident it's not happening in the US.

I didnt say it's not happening. There's enough stupid answers here from posters who "think" the regulation should mean this, or that. All are meaningless or irrelevant.

 

The regulation and the Administrator determines the requirement to have a log in the first place, and specifies how time us accounted or logged. That is all that matters.

 

Pilots may choose to log time spent wearing a bow tie, eating fried tomatoes, or playing with themselves in the shower, and it's entirely irrelevant to the correct, legal logging of time. There are NO legitimate interpretations under the US CFR, beyond rhat of the FAA administrator.

 

The authority to interpret the regulation has never been given at the FSDO level. It's never been given to private individuals, to flight instructirs, or FAA inspectors. That authority rests with the FAA Administrator, and the Administrator designates it to the Chief and Regional legal counsels. Period.

 

Beyond that, guesswork, ideas, suggestions, opinions, traditions, or employer directions do not i terpret or change the regulation, which is very clear, as are the case-specific Chief Legal Counsel interpretations. That information has already been provided.

 

If you, or anyone else, elects to log in a method contrary to that prescribed by the regulation, then it speaks to individual ignorance, but means nothing more.

Edited by avbug
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Air time...flight time...PIC time...solo time...pilot time...who cares anymore! All I care about is how the FAA would allow someone with 47 engine failures to keep their A&P and pilot cert????

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Hey I'm not arguing on behalf of any interpretation.

If the law is so very clear, (along with case specific interpretations from the Cheif counsel) then why won't you humour me and answer the two multiple choice questions. It should take significantly less effort than the speeches. I'm not really looking for an argument about what's right or wrong;

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