< Browse more articles

Transport Canada recently issued a DRAFT AC to solicit feedback on a new interpretation of Flight Time. Historically, Flight Time has been relevant to Part VII AOC holders, since it is often been used as a tool for invoicing purposes. For Flight Training operators and their students, it is most important for the logging of Flight Time for the purposes of licencing. A few months back, Transport Canada, without consulting with industry, issued an AC that said Flight Time = Air Time, in skid-equipped helicopters.  This had the effect of immediately increasing the number of hours required for a CPL-H licence by roughly 10%, notwithstanding that Flight Training Operators and Charter Operators have historically used “Blades-turning to Blades-Stopped”.  In response to concerns raised by HAC and many Flight Training operators, Transport Canada is now inviting input on the DRAFT AC, referenced above, and more recently has extended the deadline for comment to Feb 15. I have attached a DRAFT HAC submission on the subject, which urges Transport Canada to adopt the ICAO definition for “Flight Time”. While the examples set out in the DRAFT AC also could affect the interpretation of “Air Time” and “Landing” set out in the CARs, HAC has urged Transport Canada to avoid using this AC – aimed at re-interpreting “Flight Time” - to re-interpret the definition of “Air Time” for skid-equipped helicopters.  Changes to this definition could affect the way that Air Time is recorded for maintenance purposes – which would have significant implications for all helicopter operators.  Industry practice has been to include periods of time, when the weight of the helicopter is not fully supported by the skids, like Air Time – when, for example, the helicopter is toeing-in or light on its skids while landing in a swamp. For all the same reasons, fixed-wing aircraft operators do not exclude the ground-run during a touch-and-go from Air Time. The DRAFT HAC submission is attached.  Please provide your comments on the DRAFT to fred.jones@h-a-c.ca, by close-of-business, February 15, 2019.