Submission - Independent Pilots Association

117.13 Flight Time LimitationIPA Proposes:I. New Definition of Flight TimeII. Table A which specifies flight time limits be amended.________________________________________________________________The IPA proposes the following changes:I. The definition of flight time in FAR 1.1 is currently defined as the moment theaircraft fist moves under its own power. However, the PIC and required flight deckcrewmembers are always responsible and must perform their duties when the aircraft ismoved by a tug or sits at a hardstand with the engines running, and that time shouldcount as flight time if the movement is with the intention for flight. This definition isconsistent with EU-OPS subpart Q, which provides:“The time between an aeroplane first moving from its parking place for thepurpose of taking off until it comes to rest on the designated parking positionand all engines or propellers are stopped.”We propose the following definition for flight time:Flight Time – means when the aircraft first moves with the intention offlight until it comes to rest on the designated parking position.12