Ye Olde Flight Time Debate

[Guest pokey]

God, please let this be true!

 

how many is that so far? i think 4. I'm proud to be on that list !

[adam32]

So, let's all just go fire up the helicopter (that's on a trailer) then let your buddy drive around the airport all day...viola, PIC for you and SIC for him!!! It's moving with the intention of flight isn't it?

[Guest pokey]

So, let's all just go fire up the helicopter (that's on a trailer) then let your buddy drive around the airport all day...viola, PIC for you and SIC for him!!! It's moving with the intention of flight isn't it?

 

Sounds good to me, but? doesn't it have to move under it's own power? Tell buddy to put it in neutral. Then go park (the whole rig, under rotor power) in a new spot, i don't think it has to keep moving? But since i am being ignored by our resident FAA expert, that is to be answered by us mere mortals.

Edited October 1, 2016 by pokey

[kona4breakfast]

 

kona4breakfast, on 30 Sept 2016 - 15:50, said:

I'm not. If they're doing that, they're inventing a category of flight time which doesn't exist."

Perhaps "flight duty time" is defined contractually?

 

 

Wally, I get it. When I started to look into the FARs when I knew I was going to get out of the Army, I thought it was weird that the FAA would define flight time in that way. Why would you call something that wasn't flying "flight time?"

 

If you want to log only time spent in the air as flight time, that's fine. You only have to log flight time in your logbook to document experience to obtain a rating and document flight for currency requirements.

 

However, the flight and duty log for commercial operations is used by the POI to ensure that the operator is complying with flight and duty limitations. I would think that this means you HAVE to document your flight hours IAW the FAR definition on the FDL.

[Guest pokey]

now this? brings new light on: "moving with the intention of flight". My personal opinion? if he flapped a bit harder, he could log it as IFR, because he certainly was up there.

[Pilot4him]

Sorry to revive this old thread...just curious though. None of the links to the FAA interpretation of flight time for Barry LLOYD work anymore. It just says page not found. Could it be the FAA took it down for a reason?

[Pilot4him]

I remember reading it which defends logging collective Hobbs and not oil pressure Hobbs. Im trying to find the Barry Lloyd vs FAA letter online but cant find it anywhere (other than a copied and pasted letter here). Does anyone have a current link?

[Nearly Retired]

You'll probably have to wait until our government is functional(?) again before any of those links work.

 

But the FAA has made it quite clear: For helicopters, "flight time" is skids-up to skids-down. Period. For the FAA it's all about what the cabin is doing. If the cabin ain't moving, it doesn't matter what the wings are doing. Because the wings aren't a big part of the...you know...aircraft.

 

A case can (and should) be made that the FAA's interpretation is wrong, but for the time being, it is what it is. Give this political storm time to blow over. Then I'm sure you'll be able to find the documents you seek.

[avbug]

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2007/lloyd%20-%20(2007)%20legal%20interpretation.pdf

 

The Chief Legal Counsel letter of interpretation is still available and still clear on the subject.

 

Still just as easy to find.

[Nearly Retired]

Rebecca and Viola from the FAA. Sheesh. Chicks. Lawyer chicks. They might know law, but what the hell do they even know about aviation? I bet they couldn't tell a BH-206 (r/w) from a C-206 (f/w) from a B.206 (f/w twin) without Martha Lunken to point it out for them.

[Fred0311]

Why insult women in aviation? It's bad enough the sexual harrassment friends of mine have endured to build flight time. this isn't me too, just be decent to people. Some women are great pilots and some are terrible just like men. If you don't like them insult them as individuals not based on whats between their legs.

[avbug]

Ms. MacPherson is well qualified with respect to regulatory issues, and is presently Regional Administrator for the Great Lakes region, FAA.

 

https://www.faa.gov/about/office_org/headquarters_offices/arc/key_officials/macpherson/

 

 

Rebecca MacPherson is the Regional Administrator for the Great Lakes Region. She was appointed on January 8, 2018. As Regional Administrator, MacPherson serves as the principal executive representative of the FAA Administrator in the region, providing corporate leadership in cross-organizational matters and represents the FAA with industry, the public and governmental organizations. The Great Lakes Region encompasses the geographical area of Ohio, Michigan, Indiana, Illinois, Wisconsin, Minnesota, North Dakota and South Dakota.

From 2013 through 2017, MacPherson worked as a transportation attorney, first as of counsel at Jones Day and then as the principal at Rebecca B. MacPherson, Attorney at Law, PLLC. She specialized in advising clients on the impact of Federal transportation regulations on day-to-day operations, including compliance with Federal Aviation Regulations, hazardous materials regulations, airport slots, and citizenship determinations. She made guest appearances on National Public Radio's The Diane Rehm Show and Marketplace, as well as CNBC, to discuss the impact of FAA initiatives on unmanned aerial vehicles. She authored the chapter "The FAA's Certification and Regulatory Scheme for U.S. and Foreign Air Carriers" in the 2014 publication Aviation Regulation in the United States.

MacPherson served as the FAA's Assistant Chief Counsel for Regulations from 2004 to 2013, where she was responsible for providing legal and policy guidance to senior FAA officials on matters associated with the development of regulations governing all aspects of aviation, as well as overseeing the drafting of new and amended regulations and the day-to-day implementation of existing standards and regulations. MacPherson routinely represented the FAA's interests before the White House and Congress. In 2012, her portfolio was expanded to include legal oversight of the FAA's international and legislative programs and initiatives.

Prior to joining the FAA, MacPherson was a regulatory attorney at the National Highway Traffic Safety Administration and a trial attorney at the U.S. Maritime Administration. She graduated cum laude from Tulane School of Law in 1990 and magna cum laude with a bachelor of arts degree from Loyola University in 1986.

MacPherson is a member of the Maryland and District of Columbia bars. She is a two-time recipient of the Secretary of Transportation's Gold Medal; she was named the Federal Bar Association's Transportation Attorney of the Year for 2008 and was awarded the Department of Transportation's Schneider Award for 1995.

[Pilot4him]

Thanks. That link worked.

[Nearly Retired]

Heh. Avbug must think we're all stupid. Avbug must think that he and only he is capable of opening Google, entering someone's name and following the links. The rest of us nitwits aren't capable of such complicated thinking/acting!

 

Fred0311 comes to the defense of women, which is fine. But then he makes a mistake. He refers to Ms. Macpherson and Ms. Pando as “women in aviation.” Oopsie! Let us acknowledge that Ms. Macpherson and Ms. Pando are not pilots. They are merely attorneys who work for the FAA. You would not say that Roger Goodell is “in sports” because he's the commissioner of the NFL. Similarly, Macpherson and Pando are not “in aviation.” They do not deserve our respect. It is an insult to actual aviators to refer to them as such.

 

Are lawyers experts at anything other than law? No, not usually. Lawyers hire “expert witnesses” such as the great Avbug when they need to prove something. Can a lawyer be wrong? Oh yeah! I've got three in my family, and they are not always right. (They are not often wrong, I'll give them that, but they're not perfect.)

 

In any court proceeding, you'll have two lawyers passionately arguing their side of the case. It is usually up to the judge to decide which one of the lawyers makes a better case. But even that decision is not final. There is a process of Appeal. There are layers upon layers of courts and judges right on up to the Supremes Court (headed by Chief Justice Diana Ross, of course).

 

So these two non-pilot bimbos ain't exactly the final authority when it comes to aviation. They're simply the final authority when it comes to FAA regulations. But I hardly think they're experts on flying and what it takes to fly. As I've said, I'm sure that neither of them could tell the difference between a bumblebee and a helicopter. And with respect to helicopter pilot flight time, I believe Becky to be wrong.

 

Now let's briefly revisit this whole pilot flight time thing, mainly because it's fun for me. Many a helicopter pilot will climb up on his high horse in the pilot lounge and loudly declare and pronounce that “flight time” should only commence when there is space between the helicopter's landing gear and good old Mother Earth, and anything else is “cheating” or otherwise morally corrupt. A nearby eavesdropping fixed-wing pilot might look up from his newspaper, chuckle to himself and think, “What a dope.”

 

See, fixed-wing pilots begin logging pilot flight time once they start taxiing for take-off. They're “flying” without leaving the ground. Now, this interval can be short or long depending on the airport, of course. You might taxi out at JFK and discover that you're 27^th in line for take-off and there's a ground-stop in Atlanta (and there's beer in Texarkana!). So you end up sitting for an hour or so with the parking brake set, your feet up on the dash, playing Tetris on your Gameboy...and logging “flight time” all the while. It's true! It's why you often see airline pilots described as having “107 billion hours” or some such. A lot of it is spent flying on the ground.

 

At the other end of the flight, fixed-wing pilots keep logging “flight time” until they're parked at their final destination. So if you land but keep it running for some reason and then go to take-off again (skydiver loading or student-instruction at an airport where you can't do touch-and-goes), it's ALL flight time, baby! Makes perfect sense, no?

 

The rotor blades of a helicopter are its wings. They're not “analogous” to wings, they ARE the wings. Helicopters are referred to as rotary-WING aircraft. I think...I mean, I'd like to hope that even the dumbest helicopter pilot can understand and grasp that concept. Not all pilots agree, but I say that once those WINGS are moving with the intention of flight, it's exactly the same as that of a fixed-wing aircraft's wings moving (taxiing) before it takes-off. But nooooo, ol' Becky and Viola disagree! Because they're dumber than even the dumbest helicopter pilot. And that's saying something.

 

And in their lack of knowledge of helicopters (and bumblebees), what they've done is create this HUGE inconsistency in how the rules are applied. Will it ever be resolved? Probably not...at least not until the FAA goes after some poor sap of a helicopter pilot who logged “blade-time” while going for a rating, and the (rich) poor sap decides to take them to court. It'd be fun, but that will never happen.

 

After Becky left the FAA and went into private practice at Jones Day in Washington, I sent her a (real) letter, explaining my position and asking her if she would like to revisit her opinion on the matter now that she wasn't with the FAA anymore. Of course I never even received a response. Not a form-letter, nothing. But that's a lawyer for you: They never want to be pinned down on anything, especially something that might come back to haunt them later.

 

So there you have it. We are governed by the FAA, which is staffed by people with little direct knowledge of aviation. And we let women non-pilots interpret the rules for us. What a sad state of affairs.

 

[RegularDude]

I used to be impressed whenever I met a pilot...until I became one. Now I know. And this thread isn’t helping.

[Northoftheborder]

Meanwhile, in the other North American ICAO Member state....

https://copanational.org/en/2019/07/18/tcca-clarifies-helicopter-flight-vs-air-time/

Whatever happened to ICAO Harmonization of regulations?
 

[Mountain Marauder]

Just curious but how would the Feds even go about enforcing this reg?  Would they even care to enforce?

[PRJ]

On 2/20/2021 at 12:54 PM, Mountain Marauder said:

Just curious but how would the Feds even go about enforcing this reg?  Would they even care to enforce?

As with most federal regulations, there are almost zero enforcement efforts...until there needs to be. If you want, you can add a hundred hours a year to your flight time while never leaving the ground and the feds won’t know or care...until you get into an accident or have a flight violation. Same for insurance. You can lie to lower your rate, but a simple slip will end all of that. Indeed, I know a few guys with over 5000 hours who more or less update their logbooks about once or twice a year. 
 

I fly inside the DC FRZ and have been “ramped checked” by the FAA to show my certificate, medical, AW cert, and registration, but never my logbook.