(Tongue in cheek but) Neil Armstrong did !

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.

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!

212
 

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.

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:

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.

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.

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

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!

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.

MMMMMmmmmm......
 

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.

Incase anyone is interested on the logging of flight time in gerenal
 

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.

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.

212 et al
 

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:

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.

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

212
 

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.

Hi Geoff
 

I always thought when flying with you IFR meant "I follow railways"