Flight Times!
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Flight Times!
Hmmmmmm, this from The Australian today:
Regulator's redefinition makes Jetstar jumpy
Steve Creedy
September 09, 2005
JETSTAR is worried that proposals by the aviation regulator to change the way a pilot's work is defined may force it to employ more flight crew and undermine moves to slash costs.
The Civil Aviation Safety Authority is working on a new definition of what constitutes flight deck duty times after it was asked to clarify the issue by the International Federation of Air Line Pilots. CASA initially told the federation that it considered flight deck duty to start when a pilot first entered the cockpit.
However, a spokesman said the authority subsequently discovered that another definition, which only counted airborne time, had been introduced in 1994. It also found at least one airline was using block time, the time between leaving a departure gate and reaching the arrivals gate at the other end of a trip. How the work is defined is important, because CASA imposes limits on the number of hours of flight duty pilots can work each day.
The CASA spokesman said the authority was now reviewing the issue and would get a legal ruling on it. "We'll then talk to the airlines about the definition we intend to adopt and, when everyone's happy, we'll put that into the books and that will void any other definitions," he said.
But the changes could require Jetstar to use two crews on routes where it currently uses just one. Jetstar spokesman Simon Westaway said a change in the definition would clearly affect the way the airline worked.
"We do fly the aircraft for periods of time longer than our parent company, and the way our schedule is driven and the way we have our crew bases, we seek to position crew bases in a minimum number of ports." He said Jetstar had referred the issue to its parent company.
Qantas executives are understood to have visited Canberra this week to lobby against any change. "We'll continue to liaise with CASA," said Qantas chief pilot Chris Manning.
A Virgin Blue spokeswoman said the airline had an approved flight duty time scheme which already included sign-on and all associated pre-flight duties.
Anyone on top of what this is all about? The use of the the term "flight duty" is confusing - as if it's the same thing. But we know it's not. I take it what's being considered here is the definition of "flight time" (as opposed to "duty time"). Does "flight time" commence from pushback or from entry to the flight-deck? Or is the "flight time" limit a misnomer - that it was intended a limit called "flight deck duty" exist, commencing from entry to the flight deck?
If that's what's being reviewed here then there are wider implications for QF than just ol' Jet*. Think about all the two-pilot ops to/from Asia that push the 8hr flight-time limit. And have concessions to go beyond.....
Regulator's redefinition makes Jetstar jumpy
Steve Creedy
September 09, 2005
JETSTAR is worried that proposals by the aviation regulator to change the way a pilot's work is defined may force it to employ more flight crew and undermine moves to slash costs.
The Civil Aviation Safety Authority is working on a new definition of what constitutes flight deck duty times after it was asked to clarify the issue by the International Federation of Air Line Pilots. CASA initially told the federation that it considered flight deck duty to start when a pilot first entered the cockpit.
However, a spokesman said the authority subsequently discovered that another definition, which only counted airborne time, had been introduced in 1994. It also found at least one airline was using block time, the time between leaving a departure gate and reaching the arrivals gate at the other end of a trip. How the work is defined is important, because CASA imposes limits on the number of hours of flight duty pilots can work each day.
The CASA spokesman said the authority was now reviewing the issue and would get a legal ruling on it. "We'll then talk to the airlines about the definition we intend to adopt and, when everyone's happy, we'll put that into the books and that will void any other definitions," he said.
But the changes could require Jetstar to use two crews on routes where it currently uses just one. Jetstar spokesman Simon Westaway said a change in the definition would clearly affect the way the airline worked.
"We do fly the aircraft for periods of time longer than our parent company, and the way our schedule is driven and the way we have our crew bases, we seek to position crew bases in a minimum number of ports." He said Jetstar had referred the issue to its parent company.
Qantas executives are understood to have visited Canberra this week to lobby against any change. "We'll continue to liaise with CASA," said Qantas chief pilot Chris Manning.
A Virgin Blue spokeswoman said the airline had an approved flight duty time scheme which already included sign-on and all associated pre-flight duties.
Anyone on top of what this is all about? The use of the the term "flight duty" is confusing - as if it's the same thing. But we know it's not. I take it what's being considered here is the definition of "flight time" (as opposed to "duty time"). Does "flight time" commence from pushback or from entry to the flight-deck? Or is the "flight time" limit a misnomer - that it was intended a limit called "flight deck duty" exist, commencing from entry to the flight deck?
If that's what's being reviewed here then there are wider implications for QF than just ol' Jet*. Think about all the two-pilot ops to/from Asia that push the 8hr flight-time limit. And have concessions to go beyond.....
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Creedy ever heard of CAO48?
Isn't it all pretty clear as the defined by CAO48:
"flight time means the total time from the moment when the aircraft first moves under its own power for the purpose of taking off until the moment it comes to rest at the end of the flight."
Why is there doubt: surely it's from push-back (that is, the aircraft first moves for the purpose of taking off) until the end of the flight (which has to be when finally at rest at the gate)?
As for 'tour of duty', CAO48 is also quite clear:
tour of duty means the period between the time a flight crew member commences any duties associated with his or her employment prior to making a flight or series of flights until he or she is finally relieved of all such duties after the termination of such flight or series of flights and includes reserve time at the airport.
Again, why should there be doubt unless one is trying to push the envelop to his or her advantage?
Comments?
"flight time means the total time from the moment when the aircraft first moves under its own power for the purpose of taking off until the moment it comes to rest at the end of the flight."
Why is there doubt: surely it's from push-back (that is, the aircraft first moves for the purpose of taking off) until the end of the flight (which has to be when finally at rest at the gate)?
As for 'tour of duty', CAO48 is also quite clear:
tour of duty means the period between the time a flight crew member commences any duties associated with his or her employment prior to making a flight or series of flights until he or she is finally relieved of all such duties after the termination of such flight or series of flights and includes reserve time at the airport.
Again, why should there be doubt unless one is trying to push the envelop to his or her advantage?
Comments?
But when an aircraft is being "pushed back", it's not moving "under its own power".
And what if the aircraft taxis under its own power to the holding point and stops, and then taxis on to the runway and takes off? Did the aircraft "first move…for the purpose of taking off" when it started taxiing to the holding point, or when it starting taxiing from the holding point on to the runway?
Of course, you can never log "flight time" in a glider, because a glider never moves under its own power for the purpose of taking off (unless it's a motor glider).
This is what I love about aviation and regulatory 'reform' in Australia. Powered flight has been around for over a century, and there are still debates going on about what "flight time" means, what is and isn't safe in twin ops and asymmetric training, whether an engine designed in the fourties can safely be operated lean of peak, what ICUS is and who can log it, etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc
And what if the aircraft taxis under its own power to the holding point and stops, and then taxis on to the runway and takes off? Did the aircraft "first move…for the purpose of taking off" when it started taxiing to the holding point, or when it starting taxiing from the holding point on to the runway?
Of course, you can never log "flight time" in a glider, because a glider never moves under its own power for the purpose of taking off (unless it's a motor glider).
This is what I love about aviation and regulatory 'reform' in Australia. Powered flight has been around for over a century, and there are still debates going on about what "flight time" means, what is and isn't safe in twin ops and asymmetric training, whether an engine designed in the fourties can safely be operated lean of peak, what ICUS is and who can log it, etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc etc
They operate to the exemption which is not CAO 48
The exemption has a flight deck duty limit, which is different to a flight time limit - I can't remember what it is - around 9 hrs I seem to recall.
Basically the exmption has no daily flight time limit, it has a flight deck duty limit and a duty limit.
The operator that assumes flight deck duty is block to block is taking liberties as I have yet to see a crew walk on to a flight deck immediately push a button and depart.
The exemption has a flight deck duty limit, which is different to a flight time limit - I can't remember what it is - around 9 hrs I seem to recall.
Basically the exmption has no daily flight time limit, it has a flight deck duty limit and a duty limit.
The operator that assumes flight deck duty is block to block is taking liberties as I have yet to see a crew walk on to a flight deck immediately push a button and depart.
Wait for the howls from the glider pilots...
Rules and regulations written by lawyers in such a way as to keep many more lawyers employed interpreting them for evermore. What a great lurk.
It reminds me of Douglas Adams and "The Hitchhikers Guide to the Galaxy"...what we want is rigidly defined areas of uncertainty...
Rules and regulations written by lawyers in such a way as to keep many more lawyers employed interpreting them for evermore. What a great lurk.
It reminds me of Douglas Adams and "The Hitchhikers Guide to the Galaxy"...what we want is rigidly defined areas of uncertainty...
(groans as Groundhog Day dawns again)
How can anyone – lawyer or not – turn muddleheaded and inconsistent aviation policy into crystal clear words?
Once again, as an act of purest optimism, I throw down the gauntlet:
1. get agreement on this forum as to when flight time should start and end; then
2. draft the crystal clear definition.
If we can't get past 1 – which we won't – it's impossible to do 2.
And therein lies the reason for the regulatory 'reform' program drifting along forever.
How can anyone – lawyer or not – turn muddleheaded and inconsistent aviation policy into crystal clear words?
Once again, as an act of purest optimism, I throw down the gauntlet:
1. get agreement on this forum as to when flight time should start and end; then
2. draft the crystal clear definition.
If we can't get past 1 – which we won't – it's impossible to do 2.
And therein lies the reason for the regulatory 'reform' program drifting along forever.
Creampuff,
The issue as I see it is that they are not talking about flight time BUT flight DECK duty time.
Therein lies the rub - one carrier has defined Flight DECK duty time as Flight time (ie off blocks to on blocks)
The exemption has no daily limit if I recall correctly for FLIGHT TIME but does for flightdeck duty time.
Flight deck duty time is nebulious because there was no definition of what it meant in the list of definitions in the exemption
The issue as I see it is that they are not talking about flight time BUT flight DECK duty time.
Therein lies the rub - one carrier has defined Flight DECK duty time as Flight time (ie off blocks to on blocks)
The exemption has no daily limit if I recall correctly for FLIGHT TIME but does for flightdeck duty time.
Flight deck duty time is nebulious because there was no definition of what it meant in the list of definitions in the exemption
Flight and duty times
Anyone else who did their training in Australia that finds the definition for flight or duty time according to this article a bit strange? More importantly CASA, what sort of rediculous ruling are you trying to allow considering that you have prosecuted or threatened to prosecute people over this issue in audits etc. for years??
merged and edited by Woomera.
merged and edited by Woomera.
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Cream Puff,
From the CASA website-
Flight Time
means, in the case of a heavier-than-air aircraft, the total time from when the aircraft first moves under its own power for the purpose of taking-off until the moment at which it comes to rest after landing. This is synonymous with 'chock to chock', 'block to block' or 'push back to block' time.
Bloggs
From the CASA website-
Flight Time
means, in the case of a heavier-than-air aircraft, the total time from when the aircraft first moves under its own power for the purpose of taking-off until the moment at which it comes to rest after landing. This is synonymous with 'chock to chock', 'block to block' or 'push back to block' time.
Bloggs
The text quoted by FO Bloggs is verbatim from CAR 2(1), up to this patently inaccurate and internally inconsistent assertion (presumably by someone with a bright idea and a desire for a fat logbook):
An aircraft that is being pushed back is not moving under its own power, and is therefore not in “flight” at least during the period of push back, either in terms of the CAR definition or as a matter of common sense.
Perhaps the “moment at which [an] aircraft first moves under its own power for the purpose of taking off” is the moment the aircraft starts the take off run on the runway. Perhaps “the moment at which [an aircraft] comes to rest after landing” is the moment at which the aircraft completes the landing run.
There’s this quaint concept about words meaning what they say.
And then there are all those odd people who think that “flight” only occurs when you’re in the air.
Perhaps the drafters of the ‘new’ regulations need to look to the Air Navigation Act, which seems to have resolved the uncertainty, without the benefit of 10 years of navel gazing:
This [i.e. the effect of the definition of “flight time”] is synonymous with 'chock to chock', 'block to block' or 'push back to block' time.
Perhaps the “moment at which [an] aircraft first moves under its own power for the purpose of taking off” is the moment the aircraft starts the take off run on the runway. Perhaps “the moment at which [an aircraft] comes to rest after landing” is the moment at which the aircraft completes the landing run.
There’s this quaint concept about words meaning what they say.
And then there are all those odd people who think that “flight” only occurs when you’re in the air.
Perhaps the drafters of the ‘new’ regulations need to look to the Air Navigation Act, which seems to have resolved the uncertainty, without the benefit of 10 years of navel gazing:
SECT 3AB Aircraft flights: when do they start?
For the purposes of this Act, a flight of an aircraft is taken to start:
(a) when the last external door is closed in preparation for the first movement of the aircraft for the purpose of taking off on the flight; or
(b) if the aircraft moves, before all the external doors are closed, for the purpose of taking off on the flight—when it first so moves.
SECT 3AC Aircraft flights: when do they end?
(1) Subject to this section, a flight of an aircraft is, for the purposes of this Act, taken to end when the first external door is opened after the aircraft comes to rest on the next landing it makes after starting the flight.
(2) If an aircraft makes a forced landing, its flight is, for the purposes of this Act, taken to end when the competent authorities take over responsibility for the aircraft and for the people and property on board.
(3) If, after an aircraft starts a flight:
(a) the aircraft is destroyed before the flight is taken to have ended under subsection (1) or (2); or
(b) the flight is abandoned;
the flight is, for the purposes of this Act, taken to end when the aircraft is destroyed, or the flight is abandoned, as the case may be.
For the purposes of this Act, a flight of an aircraft is taken to start:
(a) when the last external door is closed in preparation for the first movement of the aircraft for the purpose of taking off on the flight; or
(b) if the aircraft moves, before all the external doors are closed, for the purpose of taking off on the flight—when it first so moves.
SECT 3AC Aircraft flights: when do they end?
(1) Subject to this section, a flight of an aircraft is, for the purposes of this Act, taken to end when the first external door is opened after the aircraft comes to rest on the next landing it makes after starting the flight.
(2) If an aircraft makes a forced landing, its flight is, for the purposes of this Act, taken to end when the competent authorities take over responsibility for the aircraft and for the people and property on board.
(3) If, after an aircraft starts a flight:
(a) the aircraft is destroyed before the flight is taken to have ended under subsection (1) or (2); or
(b) the flight is abandoned;
the flight is, for the purposes of this Act, taken to end when the aircraft is destroyed, or the flight is abandoned, as the case may be.
