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German pilot fined €5000 for incorrect pilot logbook entries, and Germany requires paper logbooks

This is 3rd hand info posted on a German domestic site (google translation)

Yesterday an acquaintance told me about a pilot (PPL, VFR) who was checked by the Air Traffic Control Office after he smashed a club plane on landing. Allegedly, he had not shown PIC and total flight time separately in the flight log – and is now supposed to pay a fine of € 5000 FOR THIS.

Germany also appears to require paper logbooks, in addition to any electronic ones used:

I also keep my flight log digitally updated daily, but the NfL clearly states that the paper log must be updated daily.
The NfL is entitled because European law leaves the implementation of the logbook regulations to the countries. This means that the LBA (or the RPs in the case of PPL) has the sovereignty to decide.

A flight log is a document with the character of a certificate. For this reason, it is important to establish and adhere
to the form and manner in which records are kept
4.3 Form and manner of flight log keeping
All flights are to be documented in a flight log permanently and immediately on the day of the respective
flight in accordance with the provisions of this appendix.

Not sure whether this applies to visiting pilots. Does EASA (or Germany) have a regulation requiring the carriage of the pilot logbook?

Administrator
Shoreham EGKA, United Kingdom

Not sure whether this applies to visiting pilots. Does EASA (or Germany) have a regulation requiring the carriage of the pilot logbook?

Unless the visiting pilot is a german license holder, no. Generally, EASA regs say a log has to be provided to the authority on request within reasonable time.

The NfL is entitled because European law leaves the implementation of the logbook regulations to the countries.

FCL.050: „The pilot shall keep a reliable record […] in a form and manner established by the competent authority“

Last Edited by Snoopy at 25 Jun 05:53
always learning
LO__, Austria

Snoopy wrote:

Unless the visiting pilot is a german license holder, no. Generally, EASA regs say a log has to be provided to the authority on request within reasonable time.

The “reasonable time” provision applies equally to German pilots as it is not an AMC but a proper Implementing Rule (FCL.045 c). EASA also requires (AMC to FCL.050 item e) that entries “be made as soon as practicable after any flight undertaken.”

But according to Peter’s quote any failure to carry the log book was not the reason for the fine, but incorrect logging of flight time.

FCL.050: „The pilot shall keep a reliable record […] in a form and manner established by the competent authority“

The reference to the electronic records kept by an operator is because these records are not kept by the pilot him/herself which is a separate case in the EASA regs – AMC to FCL.040 item (c)(1). Item (c)(2) says that the personal records may be in an electronic format and the Nfl doesn’t say otherwise.

So in all, I don’t see that the Nfl imposes any requirements beyond what part-FCL requires.

ESKC (Uppsala/Sundbro), Sweden

The case of the logbook is quite a complex one, as Part.FCL explicitly states local authorities have the right to regulate how a logbook is to be done. German LBA does have a rather special reputation of being hostile to pilots and war against citizens is a traditional cultural habit in Germany.

I saw the posting too, but unfortunately it is hearsay up to now and I am not aware of details being published yet. Only thing we may now take for sort of granted is a relation to an after crash math, so many more things can contribute to the possible fine. Btw, for logbook entries there is a German rule ’o thumb – 50 Euros per wrong entry … so 100 entries may make a 5k fine.

When did you last check your FCL.50 records are done correct (most pilots I know never gave a sh*t to the contemporary Dual rules)?

Last Edited by MichaLSA at 25 Jun 08:10
Germany

MichaLSA wrote:

When did you last check your FCL.50 records are done correct (most pilots I know never gave a sh*t to the contemporary Dual rules)?

I did when I restarted flying in 2013. But in that respect the FCL.050 AMC rules are not different from what the Swedish rules said when I first started flying in 1993.

ESKC (Uppsala/Sundbro), Sweden

So in all, I don’t see that the Nfl imposes any requirements beyond what part-FCL requires.

Unfortunately it does.

NfL:

Form und Weise der Flugbuchführung
Alle Flüge sind in einem Flugbuch dauerhaft und unmittelbar noch am Tag des jeweiligen
Fluges gemäß den Festlegungen dieses Anhangs zu dokumentieren.

Translation (sic): … All flights are to be recorded permanently and immediately on the day the respective flight was performed…

Last Edited by Snoopy at 25 Jun 11:20
always learning
LO__, Austria

Snoopy wrote:

All flights are to be recorded permanently and immediately on the day the respective flight was performed…

What goes beyond part-FCL? The “permanently” part?

The AMC to FCL.050 is clear that you may use an electronic logbook. While a competent authority may approve of or introduce their own AltMOCs, I don’t see that they can invalidate AMCs decided on by EASA. ARA.GEN.120 which deals with AMCs does not mention such a possibility.

ESKC (Uppsala/Sundbro), Sweden

The stipulation to record flights immediately (on the same date of the flight) and permanently (non editable) is in my opinion „gold plating“ and goes against FCL Impl. R. of „present to authority in reasonable time“.

The NfL actually defines the logbook as „a document with the character of an official certificate“ (whatever that’s supposed to mean… sounds like bs) and calls for entries to be permanent and any changes to be recognizable (ie hand written entries corrected by crossing them out with a single centre line so that the original entry is still readable).

BureauCRAZY!

Last Edited by Snoopy at 25 Jun 14:00
always learning
LO__, Austria

The NfL actually defines the logbook as „a document with the character of an official certificate“ (whatever that’s supposed to mean… sounds like bs)

The German legal term ‘Urkunde’ brings the flightlog on level with deeds and authenticated documents, something definitely the rest of world identifies as bs, but the German suppressor gene really loves such things …

Germany

Snoopy wrote:

The stipulation to record flights immediately (on the same date of the flight) and permanently (non editable) is in my opinion „gold plating“ and goes against FCL Impl. R. of „present to authority in reasonable time“.

The AMC to FCL.050 does say "Flight crew logbook entries should be made as soon as practicable after any flight undertaken. " which IMO is even stricter than on the same date as the flight.

ESKC (Uppsala/Sundbro), Sweden
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