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Old 04-18-2018, 08:14 AM
  #19571  
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Originally Posted by Casualinterest View Post
I'm not entirely sure how much clearer they can be on this. I've seen it in at least 3 different communications that flight time for logbook calculation remains unchanged. They also said early on this was all run through the faa.



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Blue skies has a point. Regulatory limitations involves more than just daily, monthly and yearly flight time limitations. I would like to see more information on how the FAA was involved in this implementation.
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Old 04-18-2018, 08:21 AM
  #19572  
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Originally Posted by Casualinterest View Post
I'm not entirely sure how much clearer they can be on this. I've seen it in at least 3 different communications that flight time for logbook calculation remains unchanged. They also said early on this was all run through the faa.



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So read the last sentence of the quote you provided "all regulatory purposes". 25 hours for OE completion IS a regulatory purpose.

Sounds like they shouldn't schedule OE in New York but even in Atlanta it probably cuts 3-5 minutes minimum off each leg, I've always completed my OE darn close to 25 hrs, maybe 25.5-27 type thing and I'm sure that happens with lots of guys... now they're going to need another trip to finish OE which slows down the training department.

My point is, there are larger implications to saying... "This is our flight time for 117 purposes" They almost certainly can't cherry pick flight time tracking for what helps them and not where it's problematic.

I understand what you're saying, the Company says... "nothing changes for your logbook", and somewhere vaguely "we've run this by the FAA" but I'd want (and maybe will have to ask for) an FAA legal interpretation to support that statement.
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Old 04-18-2018, 08:28 AM
  #19573  
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Originally Posted by Blueskies21 View Post
So read the last sentence of the quote you provided "all regulatory purposes". 25 hours for OE completion IS a regulatory purpose.

Sounds like they shouldn't schedule OE in New York but even in Atlanta it probably cuts 3-5 minutes minimum off each leg, I've always completed my OE darn close to 25 hrs, maybe 25.5-27 type thing and I'm sure that happens with lots of guys... now they're going to need another trip to finish OE which slows down the training department.

My point is, there are larger implications to saying... "This is our flight time for 117 purposes" They almost certainly can't cherry pick flight time tracking for what helps them and not where it's problematic.

I understand what you're saying, the Company says... "nothing changes for your logbook", and somewhere vaguely "we've run this by the FAA" but I'd want (and maybe will have to ask for) an FAA legal interpretation to support that statement.
FAR 1.1 has always had the same definition for flight time.
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Old 04-18-2018, 08:31 AM
  #19574  
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And I'll tell you, when we're hiring and upgrading, I'd bet a lot more OE is completed close to 25 hrs than the number of flights that wouldn't have been cancelled in NY for 117 flight time limit.

But I don't have that data and the Company does. Maybe I'm wrong and they cancelled 1000 flights in NYC last year that would have been saved by this change and only 5 people on OE would have been negatively affected, or a high mins captain swapped off or cancelled bc he's 10 hrs short.

Doesn't seem likely to me but I don't have the data, so I can't really say.

Maybe they've considered all those impacts and still think this is the better solution, that's possible but I'd want them to specifically tell us they have.

I want this company to succeed, I've got a vested interest in it, consequently I want to be sure this isn't something that's going to come back and bite us on 300 pilot's OE in 2018 to save 10 flights in NYC.

Probably we should all be concerned about that rather than just saying.... the Company said....
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Old 04-18-2018, 08:35 AM
  #19575  
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Originally Posted by mojo6911 View Post
FAR 1.1 has always had the same definition for flight time.
Completely agree and up until now, I think we all had a solid argument that block time was the best approximation of flight time meeting the FAA definition and that to require us to track pushback to forward movement was an "undue burden" (to use some legalese).

If the Company is now going to track flight time that exactly meets the FAA definition of flight time (though that definition is unchanged as you've noted), what possible excuse would I have to log anything else?
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Old 04-18-2018, 09:09 AM
  #19576  
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Originally Posted by Blueskies21 View Post
And I'll tell you, when we're hiring and upgrading, I'd bet a lot more OE is completed close to 25 hrs than the number of flights that wouldn't have been cancelled in NY for 117 flight time limit.

But I don't have that data and the Company does. Maybe I'm wrong and they cancelled 1000 flights in NYC last year that would have been saved by this change and only 5 people on OE would have been negatively affected, or a high mins captain swapped off or cancelled bc he's 10 hrs short.

Doesn't seem likely to me but I don't have the data, so I can't really say.

Maybe they've considered all those impacts and still think this is the better solution, that's possible but I'd want them to specifically tell us they have.

I want this company to succeed, I've got a vested interest in it, consequently I want to be sure this isn't something that's going to come back and bite us on 300 pilot's OE in 2018 to save 10 flights in NYC.

Probably we should all be concerned about that rather than just saying.... the Company said....
You're a big boy, call the POI. When he says, "you understand I'm in the room when the company makes regulatory decisions? Furthermore you aren't the first airline to do this...just like the stupid iPads." Maybe you'll feel better about it.

This topic discussion is astounding.
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Old 04-18-2018, 09:34 AM
  #19577  
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Originally Posted by theUpsideDown View Post
You're a big boy, call the POI. When he says, "you understand I'm in the room when the company makes regulatory decisions? Furthermore you aren't the first airline to do this...just like the stupid iPads." Maybe you'll feel better about it.

This topic discussion is astounding.
I guess you have more insight into the process than I do.

You're in the meetings with the FAA and management when they talk through these things?

I'm thinking the the conversation probably went

Company: "Can we use forward movement to track flight time?"

FAA: "Do you have a way to track that?"

Company: "No, but we think we can make one."

FAA: "Alright, if you can make one, that would be a good way to track flight time since it meet the definition."

I should probably be a playwright and admittedly I dumbed it down here for space but I seriously doubt the Company said "can we use this 5th OOOI for FAR 117 purposes and block time for everything else" and the FAA said "Sure that makes sense."

Maybe I'm wrong.

And you're correct, I am a big boy and if it come down to it, I will request a letter of interpretation from the FAA. (Though frankly, I don't think it should be up to an individual pilot to do that, the Union should be requesting that on behalf of all of us)

Will I just ASSUME that the Company and the FAA have discussed in depth all of the implications of this 5th OOOI time, not necessarily.

Thanks for your input on the situation though, maybe the POI would tell me "I'm in the room for all decisions" but he's not the one I'd be asking.
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Old 04-18-2018, 09:42 AM
  #19578  
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Originally Posted by Blueskies21 View Post
I guess you have more insight into the process than I do.

You're in the meetings with the FAA and management when they talk through these things?

I'm thinking the the conversation probably went

Company: "Can we use forward movement to track flight time?"

FAA: "Do you have a way to track that?"

Company: "No, but we think we can make one."

FAA: "Alright, if you can make one, that would be a good way to track flight time since it meet the definition."

I should probably be a playwright and admittedly I dumbed it down here for space but I seriously doubt the Company said "can we use this 5th OOOI for FAR 117 purposes and block time for everything else" and the FAA said "Sure that makes sense."

Maybe I'm wrong.

And you're correct, I am a big boy and if it come down to it, I will request a letter of interpretation from the FAA. (Though frankly, I don't think it should be up to an individual pilot to do that, the Union should be requesting that on behalf of all of us)

Will I just ASSUME that the Company and the FAA have discussed in depth all of the implications of this 5th OOOI time, not necessarily.

Thanks for your input on the situation though, maybe the POI would tell me "I'm in the room for all decisions" but he's not the one I'd be asking.
The POI will get sent your request for the letter of interpretation, so you'll do the same thing in effect.

You work for an airline. The FAA expects airline pilots to ask relevant questions to the company and the company is legally responsible for it's answer. I usually suggest a fleet standards director but it would benefit you to just talk to the FAA appointed here to learn how this works.

Are you prior 135 or something?

You understand this new policy to us is old policy for many airlines right? This is OLD ground.
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Old 04-18-2018, 10:32 AM
  #19579  
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Originally Posted by theUpsideDown View Post
You're a big boy, call the POI. When he says, "you understand I'm in the room when the company makes regulatory decisions? Furthermore you aren't the first airline to do this...just like the stupid iPads." Maybe you'll feel better about it.

This topic discussion is astounding.
I know right!?

Outstanding indeed.

The airline is gonna track your flight time by block out/block in. So anything the faa requests to verify your logbook will be based on block out block in. The people interviewing you at a major all tracked it by block out block in. The records they see will be based on block out block in.

I'm confused where the confusion is? You want to put less time in your logbook go ahead. But this is the accepted way to log time in this industry, and the company flight time records would back that up if necessary.



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Old 04-18-2018, 10:34 AM
  #19580  
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Originally Posted by Casualinterest View Post
I know right!?

Outstanding indeed.

The airline is gonna track your flight time by block out/block in. So anything the faa requests to verify your logbook will be based on block out block in. The people interviewing you at a major all tracked it by block out block in. The records they see will be based on block out block in.

I'm confused where the confusion is? You want to put less time in your logbook go ahead. But this is the accepted way to log time in this industry, and the company flight time records would back that up if necessary.



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Is the company going to use rainmaker to track flight time records now? Cause that’s the only place block time is recorded...
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