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Nearly Retired

Ye Olde Flight Time Debate

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I'm sure every last one of you has heard about the argument of: When Does Pilot Flight Time Begin For Helicopters? It's a controversial topic that always generates strong feelings one way or the other.

 

The FAA states that as far as logging time on life-limited or overhaulable components, it's simple: Skids-off to skids-on. Some companies use a Hobbsmeter connected to a switch on the collective to enable tracking this function.

 

Pilot Flight Time is something else. In airplanes, pilots are allowed to log as "flight time" anytime their aircraft is moving with the intention of flight, both before and after. So if you're an airline pilot at JFK and you leave the gate and find yourself #30 in line with a ground-stop for Atlanta departures, all that taxi time is "flight" time, baby! Land in Atlanta (finally!) and have to wait 30 minutes for a gate to open up? More flight time, baby!

 

In helicopters, the FAA says component flight time (i.e. skids-off to skids-on) shall be used to measure pilot flight time as well. The nitwits in their Legal Department have even issued a decree to that effect.

 

There are those of us who disagree. Our (my) main contention is that the main rotor blades are an airframe part. Hence, anytime the airframe is moving, the aircraft can be said to be moving. Our (my) contention is that if the aircraft is moving, you can log flight time, baby! Furthermore, if it ever came to a challenge in a court of law, I believe my position can be successfully argued.

 

But like I say, not everyone agrees with me. They take the FAA's position and that's that.

 

Soooooooo...I was talking with a friend of mine recently. Said friend is working for a large helicopter operator now - I won't say which one and won't say what type of helicopter he flies. But on the phone he sort of casually mentioned that at his company they log "blade-time" for their pilot flight time. I noted that such a procedure is contrary to FAA policy.

 

My friend said that their POI "forced" them to do it that way. It's in their Operations Manual. His reasoning? According to my friend, in the POI's opinion, when the rotor is turning, a major airframe part is moving. That being the case, the aircraft is moving and you're meeting the definition of "pilot flight time" in the FAR's.

 

I was, like, wh-wh-WHAAAAAT? You mean to tell me that there's someone in the FAA with half a brain?? I was stunned...gob-smacked (no, not God-smacked, that's a subject for a different post). Knock me over with a feather. I was delirious, drunk with passion and success. Okay, part of that might have been because of the number of Rum and Cokes I'd already consumed that night. But still... Vindication! Validation! And some other V-words I can't think of right now.

 

At my friend's company, they still log skids-off to skids-on for components and customer billing. Logging "blade-time" for pilot flight time obviously means that pilots will "time-out" sooner on a busy day than if they logged flight time the archaic, old-fashioned way. Bad for the company, good for pilots! Needless to say, my pilot friend did not argue with the policy.

 

However! The opinion of one POI at one FSDO in some Podunk town does not settle the debate. But it's a step in the right direction, I think. Let's hope this smart, forward-thinking POI gets to become CEO or president or whatever of the FAA. He sure gets my vote! Do we even vote on such things? I forget. Anyway, good on him!

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I don't care about logging flight time anymore.

 

Huh,...it felt so refreshing to say that!

:)

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I don't log flight time unless I'm, well, flying. Seems pretty simple and the FAA seems to agree with me. Then again, I haven't done anything with my log book in over three years so I really don't care either way.

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Helonorth, the FAA does not seem to agree with you. An airplane pilot who is taxiing out for departure is "flying" and can log it as such. I might suggest that if those skinny spinny things are going 'round and 'round overhead and you are controlling them with that thing between your legs then you are in fact flying despite the fact that the aircraft is still on the ground.

 

But we've been through all of this before, ad nauseum. I guess my point is that there is finally an FAA guy who agrees with me.

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Youtube has all the answers you seek. HAAAAAAAAA!

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The FSDO level has never been empowered to interpret the regulation. That is reserved for the FAA Chief and Regional Legal Counsel, which legal interpretations are one of three primary sources for clarification and understanding of the regulation (the other two being the regulation itself, and the Federal Register preambles when the regulation is published as a final rule).

 

The FAA Chief legal Counsel interpretations are defensible. Direction at the FSDO level is not.

 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2007/lloyd%20-%20(2007)%20legal%20interpretation.pdf

 

Dear Mr. Lloyd,

This responds to your letter dated December 13, 2006, in which you ask three questions concerning the logging of flight time in a helicopter. The answers all flow from the definition of "flight time" found in section 1.1 of Title14 Code of Federal Regulations.

Your three questions are:

 

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 its 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?

3. If a helicopter is equipped with a "time in service" meter that is actuated only by the collective pitch control, may a pilot add a couple of tenths of an hour of "flight time" to their log book in excess of the aircraft "time in service" meter reading, to account for the time that the aircraft is starting and running up at the beginning of the training period prior to lift off, and that time the engine is idling and cooling down after the last landing, prior to the engine being shut off?

The regulations in pertinent part define "flight time" as "[p Jilot 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." 14 C.F.R. § 1.1. As with fixed-wing aircraft, flight time in a helicopter commences the moment that it moves under its own power away from its parking place for the purpose of flight- whether departure is commenced by lifting off or taxiing. (Helicopters can be equipped with different types of landing gear; and those equipped with wheels or pontoons have the option of a vertical lift-off or taxiing before lift-off.) Flight time ends for any helicopter operation when the helicopter comes to rest after landing.

 

It follows from the plain words ofthe regulation that the circumstances you described could not be logged as flight time.

 

 

The answer to all three questions is that flight time may not be logged.

 

This response was prepared by Viola Pando, Attorney in the Regulations Division of the Chief Counsel and has been coordinated with General Aviation Division of Flight Standards Service. If you have additional questions regarding this matter, please contact us at your convenience at (202) 267-3073 ..

Sincerely,

 

Rebecca MacPherson

Assistant Chief Counsel

Regulations Division.

 

Edited by avbug

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Butters, coincidentally I know Jason (a fellow Floridian!) and I admire what he's doing with his MZero Aviation thing. Usually he's pretty good about stuff. But here he almost goes off the tracks. While he does quote "chapter and verse" of logging pilot flight time from the FAR's, he then recommends that we airplane pilots simply use Hobbs time which, technically is not quite correct. However, since airplane pilots generally don't spend a lot of time idling before taxiing out, using Hobbs time is probably pretty accurate - even endorsed by the DPE's and such that Jason has spoken with.

 

Then, on cue Avbug chimes in, quoting that famous letter to Barry Lloyd from that lawyer Rebecca Whatsername who isn't even a pilot much less a helicopter pilot nor knows or cares anything about helicopters and isn't even with the FAA anymore. She probably got the boot for her cockamamie rulings on FAR's. I mean, why would a career lawyer quit the FAA?? Now she's with some law firm and she specializes in consulting on aviation matters. Well isn't that nice. Heh, I'll bet even Avbug is more of an authority on aviation than that bimbo.

 

 

Avbug says:

The FSDO level has never been empowered to interpret the regulation.

 

 

And yet, that's exactly what one did! This particular operator's POI made them change their manual to reflect *his* interpretation of that FAR. Hmm... We wonder what Mother Administrator in Washington D.C. might say...*IF* he wasn't busy being busted for his "creative interpretation" of our nation's drunk driving laws. Oh wait, that was the last one, not the current one.

 

So confusing!

 

If there is anything we've learned (especially recently with Hillary Whatsername!) it's that everything is open to interpretation. No law is carved in stone like it was the Eleventh Commandment. In fact, I'm pretty sure there are people on this board who don't observe and obey the Ten Commandments as actual commandments, although they certainly are as legally and morally binding as any FAR. Or shalt thou in fact steal? Shalt thou kill? I think not!

 

And those shalt be my final words in this post: "I think not." Appropriate, eh?

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We all get it: you feel if the blades are turning, you should be logging time. And now you found a POI (that may or may not exist) that agrees with you. But the FAA has made it quite clear what their policy is: can't do it. The ruling coming from Washington surely trumps anything a POI comes up with. So until the FAA decides to revisit this issue, it's quite clear: you can't log it and the POI is wrong. No confusion. No room for interpretation.

 

There is one thing though: Ms. MacPherson states that you cannot log this time "towards a certificate or rating". What if you aren't? Log away. Have a ball.

 

I wish this guy was the POI at PHI when I first started there. I flew 6-8 hours a day, collective up to collective down. After a while, I realized for every 3 hours in the seat with blades turning, I was only logging (and billing) about 2 hours of flight time. Good for PHI, as no time on components and I was on a daily rate, good for the oil company as they got much more "flight time" for the money, but not so good for me, as it was rather hot sitting on the deck for 2 or more hours a day while loading, unloading and doing the paperwork.

 

If the FAA does decide to revisit this and determine blades turning is flight time, it would have a major impact on oil and gas flying. Lots and lots of time is spent waiting for passengers, waiting for the flyway, waiting for IFR releases, waiting for ATC, etc. all while blades are turning.

 

If there is a POI somewhere that decides to ignore the asst. chief council's clarification on this, I would think all this operator would have to do is make a phone call or wave Ms. MacPherson's letter in front of him. It could cost his customers a lot of money. It could cost the operator money as the pilots may time out much earlier and probably without the revenue. Nobody is going to pay for flight time for a helicopter sitting on the ground.

 

As of now, the only ones confused are NR and this rogue POI. The POI will get straightened around on this. As for NR, it's hopeless. Trying to rationalize that an aircraft is moving under it's own power just because part(!) of the airframe is moving while the aircraft remains stationary and on the ground, is ridiculous. Same as when an airplane propeller is moving yet the airplane is not. Maybe sometime someone will ask you to "move" a helicopter. Go start it up and shut it down. "See, I 'moved' it and a point one in my logbook!".

 

There is no "debate". It was settled years ago. There is only a few people that choose to ignore the FAA or are ignorant of its rulings.

Edited by helonorth

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There is one thing though: Ms. MacPherson states that you cannot log this time "towards a certificate or rating". What if you aren't? Log away. Have a ball.

So if you wanted to say, "fudge" your book for....?

 

Oooh, we need to bring that one back, it was way fun!!!

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Then, on cue Avbug chimes in, quoting that famous letter to Barry Lloyd from that lawyer Rebecca Whatsername who isn't even a pilot much less a helicopter pilot nor knows or cares anything about helicopters and isn't even with the FAA anymore. She probably got the boot for her cockamamie rulings on FAR's. I mean, why would a career lawyer quit the FAA?? Now she's with some law firm and she specializes in consulting on aviation matters. Well isn't that nice. Heh, I'll bet even Avbug is more of an authority on aviation than that bimbo.

 

 

 

How might you have addressed that if you had a college education?

 

Despite your ignorant conjecture and name-calling, if you can point to a more recent Chief Legal Counsel letter of interpretation that states something different, by all means put it on the table.

 

Everything else you babbled about is irrelevant. Insofar as your backhanded jabs at the FAA Assistant Chief Legal Counsel, you have something you'd like to share that's truthful about her career with the FAA, or just unsubstantiated libel? If, as you assert, she was fired for a "cockamamie ruling," where' the reversal or counter commentary?

 

You quit because you were afraid to fly, as you've told us before. Your'e throwing barbs at her? She has authority on the matter. You, of course, don't. Her letter is defensible. Your comments are not. Her letter has legal standing. Your opinion does not. Her letter defines the regulation and its application. Your opinion does...nothing.

 

Go figure.

 

 

 

If there is anything we've learned (especially recently with Hillary Whatsername!) it's that everything is open to interpretation. No law is carved in stone like it was the Eleventh Commandment. In fact, I'm pretty sure there are people on this board who don't observe and obey the Ten Commandments as actual commandments, although they certainly are as legally and morally binding as any FAR. Or shalt thou in fact steal? Shalt thou kill? I think not!

 

 

 

What you think is irrelevant, as is what anyone does here with respect to religious writ.

 

The issue, which you broached, is that of the logging of flight time, and given that the FAA Chief Legal Counsel is designated to provide the FAA Administrator's interpretation of the regulation and it's application (in this case with regard to the logging of flight time), there's nothing controversial or ambiguous about the rendering, application, or the position of the Administrator on this matter. What part don't you understand? It's very clear.

 

You do not seem to understand the difference between logging of flight time, and flight time as recorded for other purposes. 14 CFR 61.51 regards the logging of flight time, which is not necessarily the same as flight time for other purposes (such as flight and duty limitations under Part 135. Evidently you don't understand that, either). Perhaps you don't understand the difference between acting as pilot in command and logging pilot in command; you wouldn't be alone in ignorance of that.

 

You've whined about fixed wing pilots who can log time after their aircraft has moved at the start of the flight, but failed to note that a helicopter pilot can do the same thing. If a fixed wing pilot pushes back and waits an hour in line to take off, that is loggable. If a helicopter pilot moves the aircraft and waits an hour before departure, the helicopter pilot may do the same thing. No difference with respect to the Administrator's interpretation and explanation of the regulation.

 

In the mean time, you can log whatever you want. If you log time for the purposes of meeting recency of flight requirements, or toward a certificate or rating, it had better be in accordance with 14 CFR 61.51 and the relevant interpretations, and Federal Register preambles. Outside of that, you can put columns in your logbook to show time spent eating a bologna sandwich, time spent being afraid of drying cherries or otherwise flying the aircraft, time spent watching re-runs of simon & simon, or anything else that your heart desires...including padding your logbook with all that rotor-turning time that you crave. Your logbook, and you can dress it out with whatever you want.

 

It would be stupid and you'd look that way, but if it makes you happy to display that kind of ignorance, you go right ahead and knock yourself out.

 

Meanwhile the FAA will continue to employ a lot of people who don't fly, including controllers, mechanics, doctors, administrators, secretaries, etc. Perhaps all of them will be as offensive to you as a Chief Legal Counsel that doesn't fly (or perhaps she does), and all of it will still be entirely irrelevant to the question of whether you can log your rotor-turning time.

 

The relevant FAA Chief Legal Counsel question has been posted, which settles the matter insofar as the legality of logging that time. The controversy, as you call it, and therefore any confusion, is entirely in your own mind.

Edited by avbug

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Guest pokey

 

 

How might you have addressed that if you had a college education?

 

 

The relevant FAA Chief Legal Counsel question has been posted, which settles the matter insofar as the legality of logging that time. The controversy, as you call it, and therefore any confusion, is entirely in your own mind.

 

now you need a college education to post here? our bug has a degree as a philosopher? ( from Bug U, i might add)

 

Lawyers are ALWAYS correct! remember, one always loses too.

 

In the immortal words of my favorite lawyer Oliver Wendal Douglas: "Mr. Kimbal, now that we've identified the bug, how do we get rid of it?"

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Who's been in a job interview where they look at your logbook?

me

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I go with what all the military guys I've worked with do - call the tower, log an hour !

 

Chief don't go for less than 1.0!

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Who's been in a job interview where they look at your logbook?

 

 

I have. Quite a few. Corporate, government, airline, contractor, charter, etc.

 

When I did my ATP (when an authorization was required to take the written, and when it was still actually a written), the FAA examined my logbook very closely prior to issuing the authorization. At the time, having the authorization was proof that the FAA had examined the book(s) and vetted them; it was considered a sort of stamp of approval of one's experience and background; enough so that even if one didn't have the ATP, having the signoff was significant in that it represented the FAA having examined the logs.

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At the time, having the authorization was proof that the FAA had examined the book(s) and vetted them; it was considered a sort of stamp of approval of one's experience and background; enough so that even if one didn't have the ATP, having the signoff was significant in that it represented the FAA having examined the logs.

I call bull manure on that one.

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Guest pokey

I call bull manure on that one.

 

i call bull on the whole bug.. lets see now, crop duster, helo fire pilot, 747 driver, air tanker fire fighter, director of maintenance, government pilot (prolly flew airforce one, no doubt), college graduate (from Bug U)... & the list goes on & on,,,,,this guy must be pushin' all of 150 years old by now?

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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!

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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.

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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.

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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?

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