Incorrect log book tally

Everskyward said:
So every time you enter something in a field it is recorded? Even if the reason is that you made a typo and corrected it a few seconds later? Somehow I find this a little implausible, but you are the software developer. I can't believe that developers of electronic logbooks would go to that trouble. They also don't tell you how to retrieve that information or is that some super-secret conspiracy they have with the FAA? :D
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The software I used on the boats would allow you to make changes on running pages, then went to a pop up where you documented the reason for the change and it would create a record in a changes database that had a red hyperlinked date in the date field that shows the entire record for that entry.

Mostly it's only ever looked at when they examine the oil record logs looking for oil going overboard through "Magic Pipe" systems, it's how most poluters get caught anymore. We still have to have that functionality in all our e-record keeping software if we are required to keep the record.
 
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Henning said:
It's just a standard the government has accepted pertaining to e-signatures and record keeping is all. As long as there is no real money involved, no one is particularly concerned.
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I doubt that's the reason. More likely it's because a secure change audit for pilot logbooks is neither necessary nor sufficient to thwart fraudulent entries. It's not necessary because, for entries requiring signatures, the signer is required to keep an appropriately secure independent record anyway. And it's not sufficient because for all other entries (such as flight experience for currency), it's just an honor system where false entries can easily be made regardless of the security of the logbook's change audit.
 
acrophile said:
I doubt that's the reason. More likely it's because a secure change audit for pilot logbooks is neither necessary nor sufficient to thwart fraudulent entries. It's not necessary because, for entries requiring signatures, the signer is required to keep an appropriately secure independent record anyway. And it's not sufficient because for all other entries (such as flight experience for currency), it's just an honor system where false entries can easily be made regardless of the security of the logbook's change audit.
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All pilot logs are an honor system for the same reason, there is no economic incentive to have them otherwise. Paper logs are no different.
 
Henning said:
The software I used on the boats would allow you to make changes on running pages, then went to a pop up where you documented the reason for the change and it would create a record in a changes database that had a red hyperlinked date in the date field that shows the entire record for that entry.

Mostly it's only ever looked at when they examine the oil record logs looking for oil going overboard through "Magic Pipe" systems, it's how most poluters get caught anymore. We still have to have that functionality in all our e-record keeping software if we are required to keep the record.
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The commercial electronic logbook I use has nothing like that.
 
Pencil is the way to go to avoid messy corrections. I verify my results in an Excel spreadsheet. Now my question is if you start a new logbook, are you still required to show the DPE the old logbooks for the checkride or can you show the the current logbook?
 
Everskyward said:
The commercial electronic logbook I use has nothing like that.
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So it likely does not meet the AC 120.xxx reference either, but again, nobody cares. The thing a pilot e-log would have to do is invalidate an esignature if there was a line change.
 
Henning said:
All pilot logs are an honor system for the same reason, there is no economic incentive to have them otherwise. Paper logs are no different.
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I agree that there's insufficient incentive, economic or otherwise.

It's appropriate to apply a cost-benefit tradeoff to the matter. Until there's an established, widely available, reliable, convenient, free or almost-free secure-logbook technology, the FAA should continue its current lax standard for paper and electronic logbooks alike.
 
acrophile said:
I agree that there's insufficient incentive, economic or otherwise.

It's appropriate to apply a cost-benefit tradeoff to the matter. Until there's an established, widely available, reliable, convenient, free or almost-free secure-logbook technology, the FAA should continue its current lax standard for paper and electronic logbooks alike.
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The compliant software exists for those who care to be compliant, 2 different copies have been mentioned in this thread, no worries. It's not particularly rocket science difficult to make it compliant with the predicated standard, actually an iPad app would likely be pretty simple. I doubt it costs more either. Use it if you want, if you don't, no big deal.
 
If the FAA or anyone really cared about pilot logs, we'd be keeping them on DUAT(S).
 
Henning said:
So it likely does not meet the AC 120.xxx reference either, but again, nobody cares. The thing a pilot e-log would have to do is invalidate an esignature if there was a line change.
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No one has ever signed my electronic logbook and, as I mentioned before, I don't think anyone has signed my paper one in years. Any documentation I need is in other forms. I don't even need to keep a logbook and I know some who don't.
 
Slightly unrelated question, but let's say I keep an electronic record of my hours along side my logbook. One day I lose the logbook, it gets destroyed somehow, etc.

Is the electronic record viable at that point? Let's say for the sake of discussion that it's an excel spreadsheet.
 
Everskyward said:
No one has ever signed my electronic logbook and, as I mentioned before, I don't think anyone has signed my paper one in years. Any documentation I need is in other forms. I don't even need to keep a logbook and I know some who don't.
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All that has gone in my log for a long time is my BFR and IPC flights (and they all get signed) and flights I needed to prove currency to carry passengers on the next flight that I likely won't log.

This again is why nobody really cares. A pilot may one day run into a jackpot where they get an extra paragraph of bitching out, but that's about it. Never will it in and of itself end in anything at all.
 
The regulation says your logbook, including signatures, must be kept in a manner which is acceptable to the Administrator. AC 120-78 says what is acceptable to the Administrator with electronic signatures and recordkeeping. And yes, the average GA pilot really is an operator operating under Part 91 -- check 14 CFR 1.1.

And I'm done.
 
Henning said:
Exactly the same as for paper logs, which is why the "One line strike out" method of correcting paper logs. All the electronic protocol does is preserves that same transparency of historic corrections.
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Assuming you happen to use the standard bound book form of pilot logbook. OTOH, if you use a loosleaf type, the removal or insertion of a page - which is exactly what I would do if I found an error in an entry while using that type of logbook - is just as "untransparent" as an electronic record without the protocols to monitor changes.
 
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Ron Levy said:
The regulation says your logbook, including signatures, must be kept in a manner which is acceptable to the Administrator. AC 120-78 says what is acceptable to the Administrator with electronic signatures and recordkeeping. And yes, the average GA pilot really is an operator operating under Part 91 -- check 14 CFR 1.1.

And I'm done.
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I don't think that AC is in reference to pilot logbooks and recordkeeping. Otherwise you would need to do this.

8. How does an operator or individual receive FAA approval to use an electronic recordkeeping system?

a. Announcing Intent to Use Electronic Recordkeeping. Certificate holders and operators intending to use electronic recordkeeping should consult with their local FSDO or CHDO before implementing an electronic system. To obtain FAA approval, the certificate holder or operator must submit a letter to the appropriate FSDO or CHDO (see Appendix 1 for sample letter) describing the proposed system and include the proposed section or revision to the operator’s manual.

b. Description of Electronic System and Proposed Manual Changes. The electronic system description should explain how the electronic recordkeeping will be used in the operator’s maintenance and operational activities. The proposed manual section or revision should clearly state who in the organization has authority and the overall responsibility for implementing, modifying, revising, and monitoring the electronic recordkeeping computer software.

c. FAA Approval Process. The appropriate FAA Principal Inspector will review the electronic recordkeeping proposal. If the proposed electronic hardware and computer software system meets the elements of this AC, the inspector will make the appropriate entry on the operator’s operation specifications. For a part 91 operator, the regulations do not require FAA approval; however, if the part 91 operator wants to submit its electronic system to the local FSDO, the FSDO will review the operator’s proposed procedures. If the procedures are acceptable, the FSDO will provide the operator with a letter of acceptance (see Appendix 2 for sample letter).
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Ron Levy said:
And yes, the average GA pilot really is an operator operating under Part 91 -- check 14 CFR 1.1.
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Already did. There's no definition of "operator" there. There is a definition of "commercial operator", which does not apply to me. And there is a very broad definition of "operate", but the FAA does not use the term "operator" to mean people who "operate" an airplane in that very-broad sense.
 
midlifeflyer said:
Assuming you happen to use the standard bound book form of pilot logbook. OTOH, if you use a loosleaf type, the removal or insertion of a page - which is exactly what I would do if I found an error in an entry while using that type of logbook - is just as "untransparent" as an electronic record without the protocols to monitor changes.
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Again, pilot logs, not one single person really gives a flying ****. It's the most minor, inconsequential thing about aviation there is. The ****s just never leave the hangar.
 
Ron Levy said:
The regulation says your logbook, including signatures, must be kept in a manner which is acceptable to the Administrator.
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Correct.

Ron Levy said:
AC 120-78 says what is acceptable to the Administrator with electronic signatures and recordkeeping.
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Correct. It does not cover pilot logbooks (personal).


Ron Levy said:
And yes, the average GA pilot really is an operator operating under Part 91 -- check 14 CFR 1.1.
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In the context of the AC "Operators under 14 CFR parts 91, 125, 133, or 137" are in reference to Air Tour, Large Aircraft, external load and agriculture. It does not mean Joe Private Pilot in a 172.
 
acrophile said:
Already did. There's no definition of "operator" there. There is a definition of "commercial operator", which does not apply to me. And there is a very broad definition of "operate", but the FAA does not use the term "operator" to mean people who "operate" an airplane in that very-broad sense.
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Thank you. You are absolutely correct in this.
 
Blueangel said:
Now my question is if you start a new logbook, are you still required to show the DPE the old logbooks for the checkride or can you show the the current logbook?
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He might or he might not, best bet is to bring it anyway, also better scan and upload it for safe keeping, old and no longer used logs have a way of vanishing on people.


Everskyward said:
No one has ever signed my electronic logbook and, as I mentioned before, I don't think anyone has signed my paper one in years. Any documentation I need is in other forms. I don't even need to keep a logbook and I know some who don't.
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Hope you have had someone sign it with in the last 2 years :)

Unless you're using a 293 or 297 ride to cover you as far as BFRs go.
 
Bonchie said:
Slightly unrelated question, but let's say I keep an electronic record of my hours along side my logbook. One day I lose the logbook, it gets destroyed somehow, etc.

Is the electronic record viable at that point? Let's say for the sake of discussion that it's an excel spreadsheet.
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No guarantees but it should be enough, except for endorsements requiring a signature. As I mentioned earlier there is at least one NTSB case when an Excel spreadsheet was the logbook and the FAA brought an enforcement action claiming there were false entries in it. Biggest question may be whether your Excel spreadsheet has the required entries for each flight [See 61.51(b)] (I personally stopped using a paper logbook except for endorsements almost 2 years ago)

The question of whether an excel spreadsheet can be a logbook was never raised but it's kind of hard to argue that one can make false entries in something that doesn't exist.
 
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acrophile said:
Acceptable for a list of specified purposes, conspicuously omitting pilot logbooks.
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I believe it does include logbooks. It specifically applies to "Electronic Recordkeeping" - would that not be a logbook?

I am the author of MyFlightbook.com, by the way, and this link here (http://myflightbook.com/logbook/Public/CFISigs.aspx) has the gory details of why I believe that I am compliant with AC-120-70. As far as I can tell from my efforts at certification, the FAA does not certify logbooks, they just specify the guidelines.
 
EricBe said:
I believe it does include logbooks. It specifically applies to "Electronic Recordkeeping" - would that not be a logbook?
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As discussed earlier in this thread, see the AC's "Who does this AC apply to?" section.
 
Right, and the AC says "Operators under 14 CFR parts 91, 125, 133, or 137" for "who does this apply to.". If I'm a pilot flying under part 91, doesn't that mean me?
 
EricBe said:
Right, and the AC says "Operators under 14 CFR parts 91, 125, 133, or 137" for "who does this apply to.". If I'm a pilot flying under part 91, doesn't that mean me?
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Already discussed extensively in this thread. No reason to type it all in again.
 
EricBe said:
Right, and the AC says "Operators under 14 CFR parts 91, 125, 133, or 137" for "who does this apply to.". If I'm a pilot flying under part 91, doesn't that mean me?
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No, you are not an Air Operator.

An Air Operator is 91 LOA holders, 125 Large Aircraft, 133 External Load and 137 Agriculture.
 
RotorAndWing said:
No, you are not an Air Operator.

An Air Operator is 91 LOA holders, 125 Large Aircraft, 133 External Load and 137 Agriculture.
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Where is that defined? The only definition I can find is a "Commerical operator" and that's very explicitly defined. Are you basing that off of the AOC definition? I ask because I figure the FAA would say "air operators" then instead of "operators".

Looking back through the thread, this came up in the past few pages, but isn't really discussed. Regardless, the first statement says, "This AC is not mandatory and does not constitute a regulation," so what's it really matter? Has anybody actually talked to an ASI or the FSDO about this?
 
The AC doesn't use the phrase "Air Operator" anywhere, it simply uses the word "Operator", which (as has been pointed out) is not specifically defined anywhere. But Part 91 uses the word "operate" (and its various conjugations) all over the place in a way that unambiguously means the pilot.

So I obviously read it differently than you do, and will go on record here as saying that my interpretation of the words of AC 120-78 is that it does in fact apply to an individual part 91 pilot, even though that interpretation is (obviously) not universally shared. OK, we can disagree on that.

But I'll go one step further: the AC also says that it is not regulatory, and that it describes acceptable means for complying with requirements. It then goes on to describe fairly generic security measures (non-repudiation, uniqueness, traceability, etc.) which are not specific to anything aviation, much less logbooks. These to me translate to "if you want to sign things digitally, this is how we will want you to do it." I.e., even if you're right and I'm wrong about it applying to personal logbooks, that if the FAA were to come out with a standard for personal logbooks, it would follow these standards, since these standards are not even aviation specific."

For those reasons, I believe that if the FAA were to challenge the validity of a logbook with an entry signed in this manner, if you could show that it "conforms to [the AC] in all important respects" that it would in fact be acceptable.
 
EricBe said:
The AC doesn't use the phrase "Air Operator" anywhere, it simply uses the word "Operator", which (as has been pointed out) is not specifically defined anywhere. But Part 91 uses the word "operate" (and its various conjugations) all over the place in a way that unambiguously means the pilot.
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True, but as far as I'm aware, it never uses the noun "operator" in a way that unambiguously means the pilot.

It's instructive that CFR 161.5 defines "aircraft operator" more narrowly--a person does not qualify just by virtue of being a pilot. Admittedly, that's "aircraft operator" rather than "operator"; and it's only defined for Part 161. Still, it seems implausible that the AC's undefined reference to an "operator" of an aircraft means something much different than the FAA's only available definition of an "aircraft operator".

It's also instructive that the AC starts by listing (section 1a) several uses of electronic record keeping, conspicuously omitting pilot logbooks. Admittedly, those are just examples; they're not exhaustive. Still, pilot logbooks would likely be the most obvious and common example if they were indeed within the scope of the AC, so it would be odd to leave them off the list.

For those reasons, I believe that if the FAA were to challenge the validity of a logbook with an entry signed in this manner, if you could show that it "conforms to [the AC] in all important respects" that it would in fact be acceptable.
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I don't think that's in dispute. The disagreement here concerns the inverse: if an electronic logbook does not conform to the AC, is it unacceptable? Without any documented examples of nonconforming electronic logbooks being rejected during the past decade that they've been widely used, I think we can conclude confidently that there is not a problem.

In contrast, I would expect that if, say, an FBO were to submit its required records and signatures in the form of a plain electronic spreadsheet, the FAA would balk even if they had no specific challenge to any specific entry.

EDIT: By the way, I just glanced at your MyFlightbook--very impressive! I can certainly see the benefit of preparing for the day when the FAA wants to apply its electronic-records standards to pilot logbooks.
 
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acrophile said:
True, but as far as I'm aware, it never uses the noun "operator" in a way that unambiguously means the pilot.
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Apologies for the nitpick, but it absolutely does. One such example (emphasis mine):
91.131 Operations in Class B airspace.

(a) Operating rules. No person may operate an aircraft within a Class B airspace area except in compliance with §91.129 and the following rules:
(1) The operator must receive an ATC clearance from the ATC facility having jurisdiction for that area before operating an aircraft in that area.


Who besides the pilot could be the one who must receive the ATC clearance?



There indeed are other examples of "operator" where it could be ambiguous about whether it specifically means the pilot, but this unambiguous one was easy to find by simply searching for "operator."
 
EricBe said:
I believe it does include logbooks. It specifically applies to "Electronic Recordkeeping" - would that not be a logbook?

I am the author of MyFlightbook.com, by the way, and this link here (http://myflightbook.com/logbook/Public/CFISigs.aspx) has the gory details of why I believe that I am compliant with AC-120-70. As far as I can tell from my efforts at certification, the FAA does not certify logbooks, they just specify the guidelines.
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So you have a letter from the FAA signed by an ASI that has accepted your electronic logbook IAW AC 120-78?
 
EricBe said:
Apologies for the nitpick, but it absolutely does. One such example (emphasis mine):
91.131 Operations in Class B airspace.

(a) Operating rules. No person may operate an aircraft within a Class B airspace area except in compliance with §91.129 and the following rules:
(1) The operator must receive an ATC clearance from the ATC facility having jurisdiction for that area before operating an aircraft in that area.


Who besides the pilot could be the one who must receive the ATC clearance?



There indeed are other examples of "operator" where it could be ambiguous about whether it specifically means the pilot, but this unambiguous one was easy to find by simply searching for "operator."
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From 8900.1

2-1. GENERAL INFORMATION.The purpose of the certification process is to provide a means by which prospective air operators or air agencies are authorized to conduct business in a manner which complies with all applicable regulations, the Federal Aviation Act (FA Act) of 1958, and Federal Aviation Administration (FAA) directives. The process is designed to preclude the certification of applicants who are unwilling or unable to comply with the regulations or to conform to safe operating practices.
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Preparation of FAA Air Operator Certificates


Computer Based Recordkeeping
 
EricBe said:
Apologies for the nitpick, but it absolutely does. One such example (emphasis mine):
91.131 Operations in Class B airspace.

(a) Operating rules. No person may operate an aircraft within a Class B airspace area except in compliance with §91.129 and the following rules:
(1) The operator must receive an ATC clearance from the ATC facility having jurisdiction for that area before operating an aircraft in that area.

Who besides the pilot could be the one who must receive the ATC clearance?
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You're absolutely right. Thanks for the correction!
 
RotorAndWing said:
So you have a letter from the FAA signed by an ASI that has accepted your electronic logbook IAW AC 120-78?
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Nope. As far as I can tell, the FAA does not provide such certification. At least I haven't been able to find anybody who does so. But they did point me to the AC. I think more than anything else it's that this has not been tested. Ie, validity of an electronically signed logbook entry has not been challenged/ adjudicated.
 
The FAA absolutely uses "air operator" in a particular way. But they also use the word "operator" to refer to the person literally operating the aircraft (ie, the pilot), so they do not use it exclusively to refer to one or the other. The FAA inflicts much abuse upon the English language; this is hardly the only example of ambiguous meaning. (Take a look at 61.57(c) for some disastrously bad use of language, for example)
 
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