Jump to content
Sign in to follow this  
Nearly Retired

Ye Olde Flight Time Debate

Recommended Posts

Guest pokey

Daaaaaaamn, Daniel,

 

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

Share this post


Link to post
Share on other sites
Guest pokey

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

 

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

Share this post


Link to post
Share on other sites

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

 

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

 

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

 

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

 

...

 

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

 

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

 

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

 

...

 

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

 

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

 

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

 

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

Share this post


Link to post
Share on other sites

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

 

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

 

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

Edited by SBuzzkill

Share this post


Link to post
Share on other sites

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

 

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

 

...

 

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

 

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

 

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

 

...

 

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

 

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

 

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

 

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

 

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

 

What you think or what I think is irrelevant.

 

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

 

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

 

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

Share this post


Link to post
Share on other sites

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

 

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

  • Like 1

Share this post


Link to post
Share on other sites

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

 

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

 

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

 

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

 

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

Share this post


Link to post
Share on other sites

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

  • Like 1

Share this post


Link to post
Share on other sites

 

 

 

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

 

 

 

 

 

 

 

 

 

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

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

Share this post


Link to post
Share on other sites

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

 

 

 

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

 

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

 

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

 

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

 

 

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

 

 

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

 

 

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

 

 

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

 

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

 

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

 

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

 

 

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

 

 

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

 

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

 

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

 

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

 

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

Share this post


Link to post
Share on other sites

Avbug rants:

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

 

 

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

 

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

 

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

Share this post


Link to post
Share on other sites

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

 

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

  • Like 1

Share this post


Link to post
Share on other sites

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

 

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

Share this post


Link to post
Share on other sites

 

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

 

 

 

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

 

 

 

 

 

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

 

 

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

 

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

 

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

 

 

 

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

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

 

 

That is incorrect.

 

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

 

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

 

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

 

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

 

 

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

 

 

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

 

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

 

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

 

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

 

 

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

 

 

Wrong again.

 

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

 

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

 

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

Share this post


Link to post
Share on other sites

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

 

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

 

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

 

Got that? Good.

 

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

 

§830.2 Definitions.

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

 

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

 

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

 

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

Share this post


Link to post
Share on other sites
Guest pokey

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

Share this post


Link to post
Share on other sites





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?









Share this post


Link to post
Share on other sites

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.

Share this post


Link to post
Share on other sites

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.

Share this post


Link to post
Share on other sites

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.

  • Like 1

Share this post


Link to post
Share on other sites

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.

Share this post


Link to post
Share on other sites

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!

:)

Share this post


Link to post
Share on other sites

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.

Share this post


Link to post
Share on other sites

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.

  • Like 1

Share this post


Link to post
Share on other sites

Join the conversation

You can post now and register later. If you have an account, sign in now to post with your account.
Note: Your post will require moderator approval before it will be visible.

Guest
Reply to this topic...

×   Pasted as rich text.   Paste as plain text instead

  Only 75 emoji are allowed.

×   Your link has been automatically embedded.   Display as a link instead

×   Your previous content has been restored.   Clear editor

×   You cannot paste images directly. Upload or insert images from URL.

Loading...
Sign in to follow this  

×
×
  • Create New...