As a commercial pilot, have you ever been stuck with a long ground delay, been forced to reject a takeoff, or return to the gate? Can you log the flight time? Maintaining the accuracy of your logbook is a notoriously complex, intricate task. When your takeoff is delayed or canceled, the definition of "flight time" isn't always so straightforward.
In this article, we'll walk through several Part 121 scenarios, and then a Part 91 scenario at the end.
The Not So Black-And-White Definition Of 'Flight Time'
We've received a lot of questions about logging flight time properly. Keeping your logbook accurate is a top priority for most pilots, but especially those continuing a professional career. The definition of "flight time" is found in 14 CFR 1.1, the definitions section of our favorite federal regulations:
"Flight Time Means: Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing."
Seems fairly straightforward, right? Nope. There are plenty of odd situations you'll face when you reject a takeoff, return to the gate, divert, and more. And the simplified definition of flight time doesn't cover any of those. Fortunately, there are some letters of interpretation published by the FAA to clarify many situations. Unfortunately, there are still a few cases where letters of interpretation haven't covered everything. And that's where YOU come in. Read this article and let us know what you think in the comments below.
Delayed Takeoff
Let's start with an easy scenario. You're taxiing to your departure runway and something breaks on your airplane. You need a few minutes to stop on the taxiway and look through your maintenance manuals or MEL to decide if you're safe/legal for departure. After you look through the books, you decide that you can continue with your departure. A few minutes later, you take off. Does the time spent parked on the ground count as flight time?
Yes. According to the Kania 2004 FAA Interpretation, as long as the flight was not terminated or suspended, you're 100% legal to log each minute as "flight time" while parked on the taxiway. The same concept holds true for ground delays when you're awaiting takeoff clearance.
Lengthy De-Icing Procedures
Ok, let's take things a step further. It's snowing outside and you taxi to a de-ice pad where you'll spend about 20 minutes applying Type I and Type IV de/anti-ice fluid to your plane with the engines off. Decades ago, one airline tried to argue with its pilots that flight time would only be counted after they commenced taxi from the de-ice pad to the runway for departure. That's how this letter of interpretation became written when one frustrated pilot mailed the FAA a question. So, does the time parked de-icing count as flight time?
Yes, according to the Johnson 2000 FAA Interpretation. Here's the exact verbiage:
"In our opinion, the logic and principles of the enforcement cases and our prior interpretation support the conclusion that FAA-required de-icing procedures are "preparatory to flight," and when the aircraft taxis under its own power from the gate to the de-icing pad, it is "for the purpose of flight." This, we further conclude that flight time starts at the moment when the aircraft taxis under its own power from the gate to the de-icing pad, and the flight time continues until the moment the aircraft comes to rest as the next point of landing. And, all of that time is flight time, and must be credited for the purposes of the flight time limitations of section 121.471.
In the Kania 2004 FAA Interpretation, the FAA reinforces this decision by saying that, "the performance of FAA required de-icing procedures does not suspend the accrual of flight time, even though the aircraft's engines are shut down at the de-icing pad."
You Return To The Gate
Here's where things get a lot more confusing. You're taxiing to the runway and something breaks that's not able to be written off or MEL'd by you, the PIC. You return to your gate where maintenance will come on board to fix the item or perform a maintenance write-off. You could also imagine a similar scenario applying to a dispatch decision to load more cargo or passengers into your plane once you've already left the gate. Once you've parked back at the gate, does this pause in the flight count as flight time?
The answer may surprise you. Under certain circumstances, yes, the Kania 2004 FAA Interpretation allows you to continue logging flight time...
"When the pilot must remain on board, this constitutes a delay that does not interrupt the accrual of flight time, because of the continuing "purpose of flight." In this situation, flight time starts when the aircraft first taxis under its own power from the gate, continues through the period of delay when the aircraft returns to the gate and in which the pilot must remain on board, and ends at the moment the aircraft comes to a rest at the point of landing at the destination airport. An unforeseen mechanical problem that causes the accumulation of this extra flight time is, under section 121.471(g), a "circumstance beyond the control of the certificate holder."
A good example of this could be that the aircraft needs to complete a pressurization test or engine run. If this happens, and the unforeseen additional flight time puts you over the daily limit on this flight, that's perfectly legal because it's "beyond the control of the certificate holder." However, if you take off and have another (separate) flight afterward, this time spent fixing the problem with you onboard would impact the cumulative daily limit of flight time. You must ensure you're complying with duty limits for each additional flight.
These "what-ifs" may seem overly specific, but these events can and will happen to you. Let's say you return to the gate, you can't fix the plane, and dispatch swaps you into another aircraft. You de-plane, re-board, and take off, albeit slightly delayed. What can/can't be logged as flight time? Again, the Kania Letter has the answer for us!
"The flight time that must be counted as the time the first aircraft moves under its own power from the gate to the time of the return of the first aircraft to the gate, PLUS flight time from the time the replacement aircraft moves under its own power from the gate to the point where the replacement aircraft comes to rest at landing at the destination airport."
Wow, that was a mouthful. In the case of a plane swap, any time the plane for your intended or actual flight has moved under its own power, you can log flight time. Hopefully, that simplifies things.
You've Diverted: Now What?
There are plenty of reasons why you could choose to divert. But what happens to flight time if you continue to your destination after landing once? In each scenario presented within the following letter, the flight crew remains on the airplane in cases where the engines were shut off, when passengers were deplaned, or when parked on a remote section of the airport. According to the Johnson 2016 FAA Interpretation,
"In a 2004 interpretation issued to Randall C. Kania, the FAA explained that once flight time commences, it continues to accrue as long as the pilot is required to remain onboard the aircraft. Thus, an aircraft does not come to rest after landing while the flightcrew is required to remain on the aircraft.
Each of your scenarios presents a fact pattern where flight time has commenced and the aircraft has landed, but the flightcrew is still required to remain on the aircraft. Consequently, the aircraft in each of your scenarios has not come to rest after landing and flight time would continue to accrue in each scenario."
For a breakdown of these specific scenarios, read the letter here.
Engine Warmup/Cooldown
Another key point is that engine warmup and cooldown periods don't necessarily count towards "flight time." Realistically, most pilots use "hobbs time" to log their flights, but strictly following the Lloyd 2007 FAA Interpretation would make you second guess yourself. In this letter, a helicopter pilot asks about time spent warming up and cooling down engines while stationary before and after taxi or landing. The FAA representative concludes...
"It follows from the plain words of the regulation that the circumstances you described could not be logged as flight time"... Flight time in a helicopter (or any aircraft) commences the moment that it moves under its own power away from its parking place for the purpose of flight... Flight time ends for any helicopter operation when the helicopter comes to rest after landing."
This might seem contradictory to our last section, which specifically stated that flight time is eligible to be logged when crewmembers are required to be on the aircraft. If the engine is running, that's obviously the case. The operational difference we can assume is that the cooldown period, for instance, is presumed to be post-landing and not with the intent to continue a flight.
What Do You Think?
The push to log flight time is real for student pilots all over the country. What do you think about these technicalities? Would you follow the FAA's guidance or be more conservative with your logging of flight time? Tell us in the comments below.
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