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Nearly Retired

Ye Olde Flight Time Debate

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

 

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

 

Regulation says moving. Interpretation says taxiing/taking off.

 

 

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

 

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

 

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

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

 

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

 

So what's your point?

 

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

 

Jeebus!

 

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

 

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

 

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

 

 

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

Edited by avbug

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

 

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

 

 

 

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

 

 

 

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

 

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

 

 

 

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

 

 

 

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

 

 

 

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

 

 

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

 

 

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

 

 

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

 

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

 

 

 

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

 

 

 

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

 

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

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

 

 

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

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

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

 

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

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

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

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

 

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

 

 

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

 

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

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

 

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

 

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

 

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

 

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

 

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

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

 

Dang...now I see why it takes a heli CFI 5 years to get 1000 hours!

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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.

 

 

The interpretation states moving from the parking spot with the intention of flight. Read the interpretation. It's been provided.

 

Perhaps you've never flown an aircraft that moves its own ailerons, or an aircraft that powers it's ailerons with something other than the pilot, so perhaps you wouldn't know. The example is valid.

 

The rotor is a component of the aircraft. Not the aircraft. A rotor in motion can turn all day, just like a propeller, and unless the aircraft moves, the requirement of the regulation hasn't been met.

 

An aircraft "vibrating" really is irrelevant, and you won't find an iota of support for that in the regulation or the legal interpretation which attends it.

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Avbug rants:

The rotor is a component of the aircraft. Not the aircraft. A rotor in motion can turn all day, just like a propeller...

 

 

Ooooooh, except it's *not* a propeller, is it? Your rotor blades are your WINGS.

 

Without wings you certainly don't have an aircraft, you have a lawn ornament.

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Avbug rants:

 

 

Ooooooh, except it's *not* a propeller, is it? Your rotor blades are your WINGS.

 

Without wings you certainly don't have an aircraft, you have a lawn ornament.

 

 

You have part of an aircraft. Just as one has ailerons as part of an airplane, or flaps, or a propeller or turbofan.

 

Regardless of how you wish to spin it, you've been shown wrong, you've been shown the regulation, you've been shown the position of the FAA Administrator, and you've been provided the text and the links. That's all that matters.

 

You're welcome to lobby to change the regulation. Good luck with that.

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Avbug rants:

 

 

Ooooooh, except it's *not* a propeller, is it? Your rotor blades are your WINGS.

 

Without wings you certainly don't have an aircraft, you have a lawn ornament.

 

 

Well, they're not really "wings", either. They're an airfoil. And if that airfoil happens to be attached to a helicopter and that helicopter is still in it's parking spot on the ground, you ain't flying and you ain't logging time.

Edited by helonorth

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Well, they're not really "wings", either. They're an airfoil. And if that airfoil happens to be attached to a helicopter and that helicopter is still in it's parking spot on the ground, you ain't flying and you ain't logging time.

But they are producing lift, and that lift must be controlled! Ever read an accident report where some "pilot" ignored his PIC responsibilities and got out while the blades were still spinning and something went horribly wrong?

 

No its not loggable flight time, but it should still be loggable as at least PIC! If anyone is really that hard up for an extra .1?

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The fact that Lloyd had to ask the FAA, and that the FAA, in their official interpretation, had to add language with qualifiers that aren't in the definition, means that the definition, by itself, isn't clear to the lay aviator.

 

I've been quite clear that I know what the Lloyd letter states.

 

The only way I know of Lloyd is because I lurked on this site before I got out of the Army and found a similar discussion. I'd be willing to bet most pilots aren't even aware that the Lloyd interpretation exists. It may not matter at all for someone that's been working for a decade, but for the guys struggling to get their first "real" job, it does.

 

Coming from an academic background in engineering, I know intuitively and technically that vibration is movement; I know that, at ground idle, the main and tail rotor rotation causes the whole aircraft to vibrate as the CG oscillations cause the airframe to vibrate.

 

If I were to write the regulation to reflect what I think it ought to be I'd use pretty much the exact same language that the FAA did. I might have to write a letter of interpretation to avbug stating that an aircraft with an APU and hydraulic flight controls doing pre-flight checks doesn't qualify for pilot flight time, and that it would start when the engines are started. Then I might have to change the definition to specify engine power, but that'd be about the only difference. In practice this would result in everyone using oil pressure Hobbs. Except for the glider pilots, of course.

 

If I were to write the regulation with the FAA's intent in mind, I wouldn't use the word 'move' without the qualifier: away from its parking place. Otherwise I'd use the word taxi. I know pilots that don't log flight time on a helideck, which isn't addressed in Lloyd, though Lloyd seems to indicate that pilot time still accrues during interim landings. I do admit that I don't know if there's a letter of interpretation specifically addressing it. Perhaps someone can enlighten us.

 

The best definition of pilot flight time is when the aircraft is not attached to the ground. It works for airplanes, helicopters, gliders, balloons, and Icarus.

 

I don't know why the FAA drew an arbitrary line in the sand that lets airplane guys log flight time when they've got a free hand to finish their coffee, but most helicopter guys don't get to log time until they are in the air. That's probably why a few of us get worked up about it; it just seems unfair, especially since most of us are too poor to fly helicopters for fun so we have to try to get a job doing it. Why would we lobby to change the regulation? The FAA will only change the definition to reflect Lloyd, screwing over all the current and future students and CFIs who log oil pressure Hobbs.

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The fact that Lloyd had to ask the FAA, and that the FAA, in their official interpretation, had to add language with qualifiers that aren't in the definition, means that the definition, by itself, isn't clear to the lay aviator.

 

 

The FAA has been consistent in interpreting its "intent" with respect to the rule. Seventeen years prior to the 2007 Lloyd letter, the FAA address the same take-off and landing issue.

 

Since the U.S. legal system has a common-law system, prior legal decisions are binding on other legal issues with similar facts that raise similar issues. The concept of precedent, or Stare Decisis, means to follow or adhere to previously decided cases in judging the case at bar. (aka.. play the legal game by our rules)

 

Scan-1%201_zpsb7m8eckn.jpg

Edited by iChris

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If that's true, Chris, Lloyd changed the start time for pilot flight time to include taxi time, whereas in Miller it began at the start of the takeoff roll, unless 1. Miller's question wasn't related to pilot time, or 2. the wording of the definition in the regulation changed.

 

Edit: Regulation addresses 'seatbacks in upright position' ref: 121 ops. Not related to discussion at hand.

Edited by kona4breakfast

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So, an S-61 taxiing around the tarmac for half the day can be logged as "flight time"?

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There would be no point in logging PIC time. If you have more PIC time than flight time, that could be a problem. Seems a moot point...

This whole thread is moot!

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Well, they're not really "wings", either. They're an airfoil. And if that airfoil happens to be attached to a helicopter and that helicopter is still in it's parking spot on the ground, you ain't flying and you ain't logging time.

 

Ohhhhh Helonorth, PLEASE tell me that you are not this dense. PLEASE tell me that you understand that a helicopter rotor is a rotating WING. I refuse to believe that you don't understand this very simple concept! Yes, yes they are wings.

 

But the fact that you're not *flying* is actually beside the point. The reg about logging pilot flight time has nothing to do with *flying.* I'm surprised and disappointed that so many helicopter pilots are still having trouble with this. Airplane pilots, or pilots of any wheeled aircraft who are taxiing for takeoff are not flying either, are they? Of course not. But they're logging pilot flight time. How on earth can that be! It's because there is no requirement for the aircraft to be off the ground for the pilot to be logging time.

 

I know this is difficult for some of you. I know that some of you think that the FAA requires pilots to actually be flying for us to log pilot flight time. But that is just not the case.

 

Adam32 asked:

So, an S-61 taxiing around the tarmac for half the day can be logged as "flight time"?

 

 

Yes! Yes, of course...*IF* the intent was to eventually take off and go flying.

 

And actually, let me edit this to add something. If an S-61 taxied around for two hours, and then lifted off into a hover and set back down, ALL of that time would be considered pilot flight time. The aircraft however would only log .1 or so on its components (engines, rotors, transmission, gearboxes, etc.), depending on the length of the hover.

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So, an S-61 taxiing around the tarmac for half the day can be logged as "flight time"?

 

 

Yes, it can, if you're doing it with the intent of flight. Just the same as a cross country trip of 50 miles in which one spends five hours holding at the mid point, is still five+ hours of cross country.

 

 

 

OAirplane pilots, or pilots of any wheeled aircraft who are taxiing for takeoff are not flying either, are they? Of course not. But they're logging pilot flight time. How on earth can that be! It's because there is no requirement for the aircraft to be off the ground for the pilot to be logging time.

 

 

No, there isn't a requirement for the aircraft to be off the ground, and the same regulation which entitles a fixed wing pilot to log flight time once the aircraft has moved with the intention of flight also allows the helicopter pilot to do the same.

 

The fixed wing pilot can't start engines and simply start logging the time as he sits in the blocks, either. Go figure.

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If that's true, Chris, Lloyd changed the start time for pilot flight time to include taxi time, whereas in Miller it began at the start of the takeoff roll, unless 1. Miller's question wasn't related to pilot time, or 2. the wording of the definition in the regulation changed.

 

So, an S-61 taxiing around the tarmac for half the day can be logged as "flight time"?

 

This whole thread is moot!

 

The key statement in the Miller interpretation:

 

“We wish to point out that legal interpretations are issued in respect to actual or realistic hypothetical fact situations. Since you have presented us with neither situation, while we have done our best to answer your questions, a definitive legal Interpretation would depend upon the facts of the situation in which the rule Is to be applied.”

 

“The act of beginning flight in which an aircraft is accelerated from a state of rest to that of flight. The departure time of the aircraft is considered as the time the aircraft leaves the takeoff surface."

 

So it is with a number of pilots who debate the meaning of the word “move” with respect to the aircraft moving under its own power. They misunderstand the main basis of the legal standing. In this case, legal standing is with the intent of the rule.

 

Any definitive legal Interpretation depends upon the facts of the situation in which the rule is to be applied. As applied by the FAA, flight time was never intended to be applied to an aircraft sitting on the ground with the engine running and rotor blades turning; wherein, the aircraft has not moved from its parking place and flight has not yet commenced.

 

The same holds true for extended periods taxing around the tarmac. Neither meets the intent of the rule. Remember, the 2015 post on “Passenger Carrying Currency Requirements” were Curfury commented on three takeoffs and landings per §61.57: “What qualifies as a take-off when it comes to helicopters? Can you go to a hover, fly forward 10ft, land and call that one evolution? Where does it say you must fly a pattern?” It doesn't say; however, it came down to the intent of the rule. Ref. Post #12, 14, and 15

 

This is really not moot, since there’s no uncertainty and a final decision has already been made. Bottom line is, you have full control over your logbook. If ever confronted by any FAA representative of the Administrator, at least you know the official line to reply with.

 

Moot -

subject to debate, dispute, or uncertainty, and typically not admitting of a final decision.

 

Also see the following link, flight time between taxi & take-off:

 

Kania - (2004) Legal Interpretation (PDF)

Edited by iChris
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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.

 

Part 121 operations account for long extended periods between taxi and take off, see link below:

 

Kania - (2004) Legal Interpretation (PDF)

Edited by iChris
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