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Geoffersincornwall
12th Oct 2012, 13:56
A colleague recently asked me if he could record his Level D sim time as 'Flight TIme'.

My instant response was 'don't be silly' but it seems there are a considerable number of people out there who believe that to be the case. They reason that if you can complete a TR on a level D FFS without touching the real aircraft then you must be able to record the sim time as 'flight time'.

Elsewhere on Prune there is a discussion about that question in the fixed wing context and it appears there may be grey areas within certain jurisdictions.

The only relevant reference I can find is in the UK LASORS document. My copy is 2007 and on page 39 of Appendix B to Section A it makes the following statement:

"STD time is creditable towards courses and licence issue but it is not flight time and must not be recorded as such. STD time must be recorded separately from flight time recorded in the logbook."

Can anyone point me towards something with a broader focus, either JAR or EASA derived protocol?

Thanks

G.

Adroight
12th Oct 2012, 19:39
Can't help you there Geoff but I was equally surprised recently to be told by an experienced offshore pilot that he records all of his offshore flying as 'instrument flying' in his logbook. His rationale was that it was all flown on an IFR flight plan!

Don't know about you but the only 'instrument flying' I log is actual IMC.

Geoffersincornwall
12th Oct 2012, 21:02
That's not uncommon. Believe it or not there are many around the word who record any flight on an IFR Flight Plan as IMC. That is wrong of course for the whole purpose of the recording of IMC time is to understand how much experience the pilot has flying by the sole use of instruments. The rationale behind the use of the Flight Plan gag comes from the FW world and based on the fact that if they are flying at 29,000 feet the they must be flying on instruments but of course an offshore pilot a 3,000 feet (or less) may well be VMC most (if not all) of the time.

In the end those that fiddle their logbooks are only cheating themselves for they in fact create a written record of their abuse for eternity. I have met a couple of guys recently who actually rewrote their entire logbook rather than live with what they now knew was wrong.

Of course that doesn't correct the fact that they used their 'fiddled' hours to get employment or maybe even an ATP or CPL. CV Fraud is a fact of life these days.

Before anyone asks - NO YOU CANNOT RECORD SFI TIME WORKING AT THE INSTRUCTOR STATION AS FLIGHT TIME.


G.

Aucky
12th Oct 2012, 21:40
I've not flown offshore, or IFR as P1, but I have been flying about in cloud a bit in the last few weeks on the IR course, It's all pretty new to me so just wondering when your offshore 50-100nm from the nearest platform or land, auto-pilot on, does it really make a difference whether your in cloud or not (outside icing conditions)? As far as track guidance goes even in VMC surely your flying proper IFR for track guidance (perhaps GPS/RNAV in practice) on IFR clearances etc? Not too dissimilar from a guy at 29,000' in VMC? and would the departures and approaches be mostly flown as IFR in VMC or visually?

skillsndrills
13th Oct 2012, 01:51
In my logbook, there are 2 columns for these things.

Column 1 is: "IFR", which I log if it is an IFR flight.
Column 2 is "IF", I assume this means "Instrument Flying". So I log......yep, you guessed it.... instrument flying time.

As you all know, these are two completely separate things.

Needless to say, my "IFR" time is a lot more than my "IF" time.

The above is black and white to me. Anyone cheating their logbook deserves to be "beaten up", which I will log as "fell over".

On the other hand, reference cat D sims:

In the Middle East, I am told to log it under the normal columns, in the UK, I am told to log it in the bit at the front or back of the logbook entitled "sim practice", yet they all count towards the total hours.......

No one seems to agree on which is the correct way to log these hours. I'm open to input on this.

SASless
13th Oct 2012, 02:28
I am confused.

IF and IFR?

Errrrr.....one either flies by reference to instruments or by looking out the Windows. One is Visual Flight and the other is Instrument flight.

Whether you are VFR or IFR has nothing to do with what you log re IF or Visual.

Do you log VFR and VF?

If you fly IFR into uncontrolled airspace, all the time in Clear blue and 22 weather....do you cease logging IFR upon leaving Controlled Airspace as you cannot fly IFR in Uncontrolled Airspace can you?

How do you log IFR in a Sim? You are not in Controlled Airspace...as you never left the inside of a fecking building!

skillsndrills
13th Oct 2012, 02:53
Sasless,

That is my point.

Flying on instruments ("IF" in my logbook) is flying on instruments and has absolutely nothing to do with you being on an IFR flight ("IFR in my logbook") or a VFR flight.

Sorry if I did not explain my point better.

Um... lifting...
13th Oct 2012, 05:14
Ah, but what of those fellows who do an entire TR course on a FFS accumulating X hours, then are sent to the aircraft for a walkaround and a bit of handling for a further Y, then are released to the line with X+Y amount of time in type (as mandated by a client), almost all of which is in the sim? (And Geoffers, your place of synthetic employ most certainly does this) Did our intrepid airperson fly X+Y for the client, operator's, OEM's, training facility's and regulator's purposes or not? Doing it in this fashion becomes more likely with the increasing sophistication / weight / cost of the aircraft in question.

How time is recorded varies so widely worldwide that it almost might as well not be defined at all. I imagine that JAA wouldn't accept my logbook (for one thing, I didn't buy it from them, and they get a bit shirty about that sort of thing), though I can prove every entry in it, every hour of IMC, etc, though it would doubtless take weeks to do.
My logbook has a column for 'ground trainer' among other things, and all sim time goes in there. On the same line, if the sim session is an instrument one, the bulk of that time is also logged as 'simulated instrument'.
In olden times, separate pages in my mil logbook were saved for the sim.
To re-write an accurate logbook from one authority because a second authority doesn't like the format or what-have-you is ridiculous, and invites forgery, fat pencils, and other such abuses. Ultimately a pointless exercise.
Correcting substantive errata is something else entirely.

Certain armed services define any flying without reference to a visible horizon as IMC. Other folks use 'solely with reference to the flight instruments'. I could think of others if I had more coffee and time, but I'm off to log some VMC.

212man
13th Oct 2012, 06:20
Looking through the AMC to Part FCL, it is clear that EASA consider Simulator time as 'Flight Time.'

http://easa.europa.eu/agency-measures/docs/agency-decisions/2011/2011-016-R/AMC%20and%20GM%20to%20Part-FCL.pdf

I see they have also amended the definition of helicopter flight time, compared to the previous UK definition - it now starts from the moment the rotors start turning, rather than when the aircraft first moves (for the purpose of taking off.)

hueyracer
13th Oct 2012, 06:34
I see they have also amended the definition of helicopter flight time

It has been defined like this ("rotor turning time") for (at least!) the last 10 years.....in JAR-FCL 2.

They changed the definition of "instrument flying time" in EASA-nothing any more with "no visible horizon".
The definition is "all the time that one flies an aircraft solely with reference on the instruments"....

Simulator time has NEVER be "real flight time"-and although many authorities advise their pilots to log sim hours in their logbook, they also say NOT to add these hours to the total flying hours...

If you can tell me which authorities would accept sim hours as "real flight time", i would be happy to send a few applications-as i can add another 2000 hours to my flight experience, including some flights on helicopters that i don´t even have a type rating on...

212man
13th Oct 2012, 09:00
Huey, you're right, of course, about the definition of flight time. My comment was badly worded - I really meant that I wondered if the UK had now adopted that definition which previously they had not. I guess the latest ANO will contain the answer !

Did you open the link? It seems to be pretty explicit that you log the time as flight time.

2000 hours of sim time at 36? That's pretty good going - at least 125 hours per year since you were 20. If some of that time is as an instructor then of course it wouldn't count. Neither would time in a type you weren't rated on, as you wouldn't be operating in a genuine crew capacity.

skadi
13th Oct 2012, 09:13
2000 hours of sim time at 36? That's pretty good going - at least 125 hours per year since you were 20.

MS Flight Simulator? :}:}:}

skadi

Geoffersincornwall
13th Oct 2012, 11:31
I followed your link and read the text but failed to find the reference that classified STD time as 'Flight TIme'. Am I looking in the right section?

G.

sanddancer
13th Oct 2012, 11:41
UK ANO (CAP393) Article 79 Sub Para (4)

Aucky
13th Oct 2012, 11:41
Looking at pages 24-25 of the EASA FCL doc would imply to me that it is not 'flight time'. Look at the example shown on page 25 where the FSTD 'session' (not flight) is included in column 11 there is no suggestion in the column 10 that any pilot function is given. That cannot be considered flight time, it is logged separately in it's own FSTD column solely.

hueyracer
13th Oct 2012, 11:53
Yes-i was an instructor...but i guess you did not see the "ironic smiley" (which i forgot to enter after my comment)....

Geoffersincornwall
13th Oct 2012, 12:02
I agree. Looks to me that there is no mechanism for conflating Flight Time and Sim TIme if the Log Book is supposed to differentiate the two.

I have heard it said that sim time can count towards Total Time but not towards Total FLight Time.

I guess it's logical to think that 'flight' time will require you to be 'in flight' but then I have learned to my cost that it's often dangerous to use 'logic' when dealing with authority.

G.

Sandy Toad
13th Oct 2012, 15:10
Why is it that very experienced pilots are not able to find a clear answer to this?
Why do we regularly get debates about whether rules apply and if they do apply, how should they be applied?
How on earth do Authorities expect pilots to comply with rules if they aren't sure what the rules are.
Clarity and KISS.

Back to my GnT....

SASless
13th Oct 2012, 23:16
Sandy....that sounds all nice and neat.....but what is your authority for making that comment. Cite a reference then perhaps it might have some merit. But not till then!

SimFlightTest
14th Oct 2012, 00:12
God help us if operators are allowing pilots that have only spent time in a sim to fly passengers around.

ZFT
14th Oct 2012, 02:47
(Tongue in cheek but) Neil Armstrong did !

squarecrow
14th Oct 2012, 03:03
Air Asia Direct entry Captains in Malaysia do for A320. Only fly the real thing when start line training. FO have to do Endorsement flight in real Aircraft for the DCA there before for rating issue.

212man
14th Oct 2012, 03:07
AMC1 FCL.050 Recording of flight time
GENERAL
(a) The record of the flights flown should contain at least the following information:
(1) personal details: name(s) and address of the pilot;
(2) for each flight:
(i) name(s) of PIC;
(ii) date of flight;
(iii) place and time of departure and arrival;
(iv) type, including make, model and variant, and registration of the aircraft;
(v) indication if the aircraft is SE or ME, if applicable;
(vi) total time of flight;
(vii) accumulated total time of flight.
(3) for each FSTD session, if applicable:
(i) type and qualification number of the training device;
(ii) FSTD instruction;
(iii) date;
(iv) total time of session;
(v) accumulated total time.
(4) details on pilot function, namely PIC, including solo, SPIC and PICUS time, co-pilot, dual, FI or FE;
(5) Operational conditions, namely if the operation takes place at night, or is conducted under instrument flight rules.

If they did not consider it flight time, surely they would not have included it in the section that describes how you record flight time!

Geoffersincornwall
14th Oct 2012, 05:04
I think we are talking semantics here. The entries you list are clearly designed to SEPARATE STD activity from REAL flying so you cannot subscribe to the notion that STD time contributes for example to the PIC flying required for the upgrade of CPL to ATPL where PIC flight time means pilot in command of a real flight.

One good reason for that is that STD time is recorded as 'total session time' not 'flight time'. In some cases a two hour session in the box may have less than one hour of synthetic flight time so use of total session time to inflate genuine PIC time would not, I am sure, be acceptable.

G.

Aucky
14th Oct 2012, 06:40
Why is it that very experienced pilots are not able to find a clear answer to this?
Why do we regularly get debates about whether rules apply and if they do apply, how should they be applied?
How on earth do Authorities expect pilots to comply with rules if they aren't sure what the rules are.
Clarity and KISS.

I Agree! Just as an an (old but still valid) example:

ANO Cap 393 "This Amendment principally contains changes to the Air Navigation Order arising from the EASA Aircrew Regulation" dated 10th August 2012:

UK ANO (CAP393) Article 79 Sub Para (5) - For the purposes of this article, a helicopter is in flight from the moment the helicopter first moves under its own power for the purpose of taking off until the rotors are next stopped.

from EASA PART-FCL AMC page 22):

(g) Flight time is recorded:
(1) for aeroplanes, touring motor gliders and powered-lift aircraft, from the moment an aircraft first moves to taking off until the moment it finally comes to rest at the end of the flight;
(2) for helicopters, from the moment a helicopter’s rotor blades start turning until the moment the helicopter finally comes to rest at the end of the flight, and the rotor blades are stopped;

So which is it? :ugh:

Aucky
14th Oct 2012, 06:57
212 MAN - If they did not consider it flight time, surely they would not have included it in the section that describes how you record flight time!

If you are referring to EASA AMC FCL which it looks like you are then simply look at the example log entries on pages 23 and 25 with a combination of different flight types, one of which is a sim entry - the sim entry clearly has no 'Flight Time', 'PIC', 'Operational condition time', or 'Pilot function time.' It has 'sim session time' and that is all - clearly separated from flight time.

212man
14th Oct 2012, 09:14
Geoff, we may be talking semantics - or even at cross purposes - but I still don't believe that the notion that FFS time can be logged towards total flight time can be dismissed so readily.

For example, the integrated ATPL(H) with IR course requires 195 hours total, of that 65 hours can be in an FFS. There is no distinction as to whether that can be solo or dual, so by inference some of the solo requirements could be logged in the FFS.

The LST to upgrade an ATPL from a CPL can - and should, in my opinion - be done in an FFS.

If you are referring to EASA AMC FCL which it looks like you are then simply look at the example log entries on pages 23 and 25 with a combination of different flight types, one of which is a sim entry - the sim entry clearly has no 'Flight Time', 'PIC', 'Operational condition time', or 'Pilot function time.' It has 'sim session time' and that is all - clearly separated from flight time.

Looking back at my quotation from the AMC, it is clear that they expect you to record what your function was

(ii) FSTD instruction;
(iii) date;
(iv) total time of session;
(v) accumulated total time.
(4) details on pilot function, namely PIC, including solo, SPIC and PICUS time, co-pilot, dual, FI or FE;
(5) Operational conditions, namely if the operation takes place at night, or is conducted under instrument flight rules.

However, they do seem to contradict themselves in the sample log book pages, where they show a B747 LPC in an FFS, but then fail to records the operating capacity or flight rules :ugh:

I think that there is an undertone in some of these posts that somehow there could be a loop hole that would allow pilots to rack up hours falsely towards promotion or qualifications. The reality is that for an average line pilot, his simulator time probably represents about 1-2% of his annual total hours. That's a figure that's probably less than the variation between the EASA and UK flight time definitions quoted above!

Additionally, a typical large level D simulator costs in the region of 1500-2200 USD per hour to rent - so there's no possibility of wannabees trying to boost their hours in one.

Without doubt, 20 hours of LOFT exercises in marginal wx conditions and annoying changes to the schedule and irritating minor defects is far more valuable than sitting in the cruise at FL80 on autopilot eating your Ninian breakfast and reading the paper! So I would have no problem including that time when it came to determining whether a co-pilot met the hours for his command upgrade :ok: Equally, if someone was 20 hours short of a requirement, I'd rather see him get those hours in an FFS than flog around Florida in a Schweizer or C152, or spend another week driving up and down radials for the umpteenth time.

For the record, I log the time in the separate simulator section in an RAF logbook and don't really have a conscious view on whether it's part of my total time. I think once into 5 figures one doesn't really care!

Aucky
14th Oct 2012, 09:31
Looking back at my quotation from the AMC, it is clear that they expect you to record what your function was

I think we look at the indexing format to see what they are saying here, in my opinion parts 4 and 5 are not related specifically to part 3 or they would be 'vi' and 'vii'.

AMC1 FCL.050 Recording of flight time
GENERAL
(a) The record of the flights flown should contain at least the following information:
(1) personal details: name(s) and address of the pilot;
(2) for each flight:
(i) name(s) of PIC;
(ii) date of flight;
(iii) place and time of departure and arrival;
(iv) type, including make, model and variant, and registration of the aircraft;
(v) indication if the aircraft is SE or ME, if applicable;
(vi) total time of flight;
(vii) accumulated total time of flight.
(3) for each FSTD session, if applicable:
(i) type and qualification number of the training device;
(ii) FSTD instruction;
(iii) date;
(iv) total time of session;
(v) accumulated total time.
(4) details on pilot function, namely PIC, including solo, SPIC and PICUS time, co-pilot, dual, FI or FE;
(5) Operational conditions, namely if the operation takes place at night, or is conducted under instrument flight rules.

I read it as Part 3 i-v applying to FSTD's? I do however think it's unclear because if parts 4 and 5 related only to flights in helicopters then they should fall under part 2. It was due to that fact that this was unclear that I referred to the logbook example pages - which I assumed to be correct.

Geoffersincornwall
14th Oct 2012, 10:52
We really are getting into sticky territory. We have to ask ourselves what the author's expectations were when they drafted the requirements for ATPL etc.

If they require 'session time' to be recorded and then state FFS FLIGHT TIME to be counted then where is the column that differentiates between 'session time' and 'flight time'. The latter will ALWAYS be less than the former, sometimes by a lot. Maybe 50/50.

As to the value of sim time I will not dispute your analysis 212. You are absolutely correct but for reasons I can't go into the correct treatment and correct recording of FFS time has become an issue of great import and if it were possible to point to something that was black and white one way or the other then it would help a colleague to understand his personal situation more accurately.

The statement in LASORS (see previous posts) is the clearest and most definite one I have come across, everything else can be interpreted any way you want to see it. LASORS says the FFS time is NOT flight time. CAA document published as a guide to the interpretation of current regulations.


G.

Aucky
17th Oct 2012, 15:26
Response from the CAA:

Further to your email regarding logging of helicopter flight time, in response to your specific query;

“One further discrepancy is the logging of flight time, which appears to differ between ANO CAP 393, and EASA FCL. Could you please advise which documents protocol should be followed:”

Flight crew logs must be kept in accordance with the provisions of Article 79 of the UK ANO as amended and must also conform to Part-FCL (AMC FCL.050 refers). Part-FCL states that flight time shall be recorded in a manner specified by the Authority. For Part-FCL (JAR) licences the requirements of AMC FCL.050 apply ( this is also covered in the definitions of Part-FCL, refer to CAP 804, Section 1, Part B, also Section 1, Part E). The Part-FCL definition is consistent with JAR-FCL 2.001.

“Flight time: For helicopters, it means the total time from the moment a helicopter’s rotor blades start turning until the moment the helicopter finally comes to rest at the end of the flight, and the rotor blades are stopped”

The ANO reference remains in place for helicopter licences being flown on UK National (non-JAR/Part-FCL) licences. EU law supersedes UK National law in relation to EU licences. It is most likely that the ANO’s definition will be revised at some future amendment to align with the definition contained in Part-FCL.


I hope this information satisfactorily answers your query.

212man
18th Oct 2012, 02:04
Thanks for that update Auky - I'm sure a few co-pilots will be wringing their hands in glee!

Seriously, though, I think a change so significant should have been transmitted as a CAA Information Notice, as it has several implications.

I agree that the AMC sections 4&5 cause confusion - if they are intended to be aircraft only then they should form a sub-set of item 2. By listing them as they are, the inference is that section 3 (FSTD) is also part of the overall concept of Flight Time - which is what FCL.050 is dealing with.

Geoffersincornwall
18th Oct 2012, 03:06
It is still difficult to reconcile the notion that sim time can be taken as the same as real flight time when the UK LASORS document so unequivocally states:

"STD time is creditable towards courses and licence issue but it is not flight time and must not be recorded as such. STD time must be recorded separately from flight time recorded in the logbook."

Whatever games are played with words or the absence of words this statement is clear.

SIM TIME IS NOT FLIGHT TIME AND MUST NOT BE RECORDED AS SUCH

I rest my case.

G.

212man
18th Oct 2012, 04:18
LASORS is now obsolete and no longer available to download - having been replaced by CAP804. However, it contains the same wording.

Mind you, that's the UK CAA interpretation......:E:E

8 Synthetic Training Device (STD)
8.1 Particulars of any training session, test or examination undertaken whilst in an STD shall be recorded in the log, including, for each flight simulator, BITD or FNPT session:
a) the date of the session, test or examination (dd/mm/yy);
b) type and qualification number of training device;
c) synthetic training device instruction;
d) the capacity in which the holder acted;
e) the nature of the session, test or examination;
f) total time of session;
g) accumulated total time.
8.2 STD time is creditable towards courses and licence issue but is not flight time and must not be recorded as such. STD time must be logged separately from flight time recorded in the log.

Geoffersincornwall
18th Oct 2012, 07:05
With respect I think the appraisal of the EU FCL you have put forward is an 'interpretation'. The CAA have made a 'statement' clear and unequivocal.

G.

baldeagle73
18th Oct 2012, 19:34
I always thought when flying with you IFR meant "I follow railways"