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EASA Journey Log requirements

Peter wrote:

The only explanation I can think of is that the legal requirement for a journey log sets up an “entrapment framework” whereby if they cannot bust you for the flight which they can prove you did, but they think (but can’t prove) it was illegal, they can bust you for not having logged it.

Really Peter? Is this a joke? It is a conspiracy to entrap pilots?

EGTK Oxford

Really Peter? Is this a joke? It is a conspiracy to entrap pilots?

Well, Jason, you can ridicule a post, or you can do the more difficult bit which is to make a positive contribution.

What do you think a logbook containing a plane’s journeys is good for?

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

What do you think a logbook containing a plane’s journeys is good for?

Nothing. It is an ICAO driven historical anomaly.

EGTK Oxford

ICAO has never proposed that domestic air traffic maintain Journey Logs, as is apparently required in Europe today, so unless “ICAO driven” means that ICAO with its position on international flights pushed EASA regulators in a certain direction and they kept going too far, I can’t see that phrase being accurate. I believe the impetus more likely came from one or more European national CAAs representing countries where the practice was historically mandatory. Or more benignly simple EASA incompetence in understanding the ICAO position.

As I posted in an earlier phase of this thread, maybe what mandatory Journey Logs are ‘good’ for is identifying pilots illegally transporting people or goods to and from key locations, who want to otherwise comply with the law so as not to make themselves obvious. This might have this applied quite ‘well’ to previous political eras in Europe, but not now unless you think GA transport of the undocumented around Europe is a significant problem!

BTW I don’t think advocating elimination of a mandatory journey log requirement is uncomplimentary to individuals who would choose to keep them for their own non-universal reasons. Freedom works both ways – if somebody finds utility in the practice they should do it even if other individuals find it inapplicable and inefficient.

Last Edited by Silvaire at 30 Jan 01:23

Nothing. It is an ICAO driven historical anomaly.

Well, Jason, there you go…

Why do those who want to have a swipe (usually because they live on another forum and want to contribute to EuroGA minimally only) keep using the word “conspiracy”?

It is ridiculous to suggest there is a (criminal) conspiracy.

My point is that there are countless cases where a reporting requirement exists in order to entrap the reporter, in case the reporter fails to comply with the said requirement.

One of thousands of examples is CE compliance on products. You have to generate a Declaration of compliance. This declaration doesn’t change whether the product actually complies (and thousands don’t, especially chinese ones; they stamp “CE” on everything as a default). But the (in this case, EU) requirement for a signed declaration makes it possible to prosecute the signatory in person.

Without the signed declaration all you could do is impose a fine on the company… maybe. Probably not even that, because there are all kinds of exemptions which you can claim to fall under. And there are many standards. The same product sold domestically, sold for industrial use, sold into the high voltage control market, etc, needs to comply with different standards. The old joke is that the great thing about standards is that there are so many to choose from! Whereas in the Declaration you specify the actual standards you are complying with, so your neck – as the named signatory – is nicely sitting in the guillotine.

The actual product can be total crap.

Try “actually making something” in a manufacturing business and you will quite rapidly get the idea

The journey log is no different. You are certifying the information in it is true. If it is false you will still certify it. Why? Because the law requires a journey log and it requires you to sign it.

Administrator
Shoreham EGKA, United Kingdom

Silvaire wrote:

ICAO has never proposed that domestic air traffic maintain Journey Logs, as is apparently required in Europe today, so unless “ICAO driven” means that ICAO with its position on international flights pushed EASA regulators in a certain direction and they kept going too far, I can’t see that phrase being accurate.

I think “ICAO driven” is quite apt.

Recital 78 of the Basic Regulation says:
“When adopting the delegated acts amending the Annexes II to IX to this Regulation, the Commission should take due account of the international standards and recommended practices, and in particular of the international standards set out in all of the Annexes to the Chicago Convention.”

Of course it doesn’t say “must follow”, but it leads to a “can’t go against ICAO” mindset.

Moreover, imagine the task of standardising Ops rules across Europe starting from 28 member states’ individual rulebooks. The most efficient way of doing that was to use ICAO SARPs, which many of the states rules already approximated. For CAT, it works almost perfectly, since CAT operators in Europe were almost always used to flying internationally so had to be adherent with ICAO SARPs. But for, GA it had the effect of imposing regulation that might be considered proportionate for international GA operations on to domestic or even very local operations. We managed to push back against some of the most absurd stuff originally proposed for Part-NCO, but not the journey log requirement.

I believe the impetus more likely came from one or more European national CAAs representing countries where the practice was historically mandatory.

You may be correct that some CAAs would want to continue their national practice. But there’s also an element of many European pilots not being troubled by the requirement.

I think the EASA approach to implementation of the ICAO journey log requirement should have been to rule that the EU or Schengen Zone (eithrer) is for the purposes of ICAO treaty compliance on this issue a single country, and therefore no journey logs are required for flights contained within the region. At the very least my expectation would be that the treaty obligation would be satisfied as it is, for international flights only.

Instead the reaction was to require a journey log for every flight, not only for international flights as required by treaty. In the end, I think people will drown in the lack of leadership represented by a tendency to adopt the lowest common denominator.

Last Edited by Silvaire at 30 Jan 16:52

I keep a spreadsheet list of all my flights in my own aircraft (currently on N register) and flights in any other aircraft, plus sim time, IFR currency, anyone else’s time flying my aircraft, and maintenance.
So this doubles as a pilot logbook and aircraft log/journey log, as well as keeping track of everything I need to know that is time-based.

Times are taken from the knee-pad I carry, checked to the GPS flight time. I do not record actual takeoff/landing times as this could be extracted from the GPS if needed.

No-one has yet asked for the journey time in a ramp check, but I would just show the spreadsheet on my computer, or in cloud storage, as I have done when asked about W&B. The requirement is for “journey log or equivalent”, it does not appear to need to be on paper, even if this might annoy whatever official is checking.

Bluebeard
Ireland

I am not sure (maybe in previous posts?) if there has ever been a single report of a journey log ever having been checked in Europe. I don’t recall any. All the other documents, sure, especially if you are registered in the land of the Great Satan But never the journey log AFAIK.

Administrator
Shoreham EGKA, United Kingdom

I’ve been ramp checked twice in France.
Twice the journey log got checked (once prior toPart-NCO implementation and once after)

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