CALL TO ACTION: Support a rewrite of Part 135 duty and rest rules

[Inverted]

You can download an app for .99 cents that will take care of it for you, and you guys aren't 121 so it doesn't even apply to you lol.


Sent from my iPhone using Tapatalk

 

[mshunter]

It is simple. Objectively no. Further complicating it with the addition of a chart with different maximum duty periods for different amounts of legs per day won't make it any easier. Beyond that, this is essentially audit proof at the 135 schedule.

This paragraph right here:


How the hell do you keep up with that without using software? You don't reset after a month, or after a quarter, or after a year - no. You have a constant rolling clock you need to look at. First, how the hell does the FAA plan to audit that for 100 small time carriers? Nah, it'll be a CF if the FAA tries to do this to small time 135, and I'm not even sure it's "safer."

135 is like 6 paragraphs of actual information to be responsible for, part 117 is like 8 pages of information to be responsible for.

It's not hard at all to keep up with. Basically, fly less than 100hrs a month, 1000hrs in a year.

"What was my monthly total?" If that looks good, not a whole bunch needs to be looked at for a rolling 28 days. We are regularly approaching guys getting awarded 120hrs a month. Most of us have 3 days off between trips. It makes it ridiculously easy to track. It looks hard on paper when it's written in a regulation. But in practice, it's actually really simple. And once you get a calander going, subtract the trip that's about to drop off, add the trip that's about to start, and you have your answer. I did a series of trips last month that was a real ball buster. I was within 4 hours of timing out. Two back to back three days. Had we taken any delays, I would have timed out. But it was easy to track. I knew what my drop dead time was well in advance.

It's a lot easier than it looks, and sounds.

 

[ppragman]

It's not hard at all to keep up with. Basically, fly less than 100hrs a month, 1000hrs in a year.

"What was my monthly total?" If that looks good, not a whole bunch needs to be looked at for a rolling 28 days. We are regularly approaching guys getting awarded 120hrs a month. Most of us have 3 days off between trips. It makes it ridiculously easy to track. It looks hard on paper when it's written in a regulation. But in practice, it's actually really simple. And once you get a calander going, subtract the trip that's about to drop off, add the trip that's about to start, and you have your answer. I did a series of trips last month that was a real ball buster. I was within 4 hours of timing out. Two back to back three days. Had we taken any delays, I would have timed out. But it was easy to track. I knew what my drop dead time was well in advance.

It's a lot easier than it looks, and sounds.

Or you can have the current regs under 135 where NOTHING has to be looked at on rolling 28 day cycles, and the most challenging thing you can have is 8 or 10 - in - 24.

 

[Inverted]

Nobody is saying going to .117 for part 135. Why we are having .117 and ATP discussions is beyond me...


Sent from my iPhone using Tapatalk

 

[mshunter]

Or you can have the current regs under 135 where NOTHING has to be looked at on rolling 28 day cycles, and the most challenging thing you can have is 8 or 10 - in - 24.

I know what you've done Pat, and where you've worked. You've never had the luxury of being beat to death. A rewrite of rest rules with clear definitions that every FSDO can't interpret how they want, which you know damn well happens, is needed. It doesn't need to look like 117. I've never said it needs to look like 117. But they way they are currently written allows them break the regulations and then cover it up. I've worked at places like that (and quit). I'm pretty sure if memory serves, you haven't.

 

[ctab5060X]

Nobody is saying going to .117 for part 135. Why we are having .117 and ATP discussions is beyond me...


Sent from my iPhone using Tapatalk

Because both are relevant to a discussion of a potential rewrite of 135 Rest and Duty rules.

117 is going to be the go to reference for any scientific based rest and duty time limits for part 135 operations. Remember, it was the rewrite for 121 Rest and Duty rules. It's going to be looked at if you open part 135 to a rewrite.

The ATP discussion is just how out of touch Congress and the FAA can be regarding just how detrimental their forced rewrites have been. You want a rewrite of the 135 Rest and Duty rules, be prepared for some segment of the industry to be hosed.

I am very much in favor of taking a serious look at the issues concerning 135. Do I think we need to jump into a full rewrite right now... no. But a good in depth review of what is in place and what changes could be made to improve things is certainly warranted.

 

[Maurus]

You want a rewrite of the 135 Rest and Duty rules, be prepared for some segment of the industry to be hosed.

My guess is the only shops that go down do to a rewrite are the ones that continuously operated in the "grey". The shops that do things right would only have minor adjustments if any.

Personally I would rather a few 135 places go under than see aircraft with people inside go down yet again due to fatigue.

 

[Inverted]

The operators that get hosed on a rewrite are the same ones that would be hosed by following current regulations. My first company told me that charter is a 24 hour operation, and to survive, you have to be willing to fly 24/7. Think those morons are going to comply with the regs now? Nope, think if they were forced to comply with these regs or new regs that they would either have to do the right thing or fail? Yep.

 

[ppragman]

I know what you've done Pat, and where you've worked. You've never had the luxury of being beat to death. A rewrite of rest rules with clear definitions that every FSDO can't interpret how they want, which you know damn well happens, is needed. It doesn't need to look like 117. I've never said it needs to look like 117. But they way they are currently written allows them break the regulations and then cover it up. I've worked at places like that (and quit). I'm pretty sure if memory serves, you haven't.

What are you trying to insinuate here?

 

[ctab5060X]

My guess is the only shops that go down do to a rewrite are the ones that continuously operated in the "grey". The shops that do things right would only have minor adjustments if any.

Personally I would rather a few 135 places go under than see aircraft with people inside go down yet again due to fatigue.

The operators that get hosed on a rewrite are the same ones that would be hosed by following current regulations. My first company told me that charter is a 24 hour operation, and to survive, you have to be willing to fly 24/7. Think those morons are going to comply with the regs now? Nope, think if they were forced to comply with these regs or new regs that they would either have to do the right thing or fail? Yep.

I'm not talking about operators getting hosed because they don't/won't follow regulations.

My observation was within the context of why the ATP rule needs to be discussed in a rewrite. The intent was well and good for 121 operators to require this new course for the ATP written. However, it has harmed small passenger carrying 135 operators who operate aircraft like Navajos and 402s (and who follow the regs) by requiring potential pilots who don't have an ATP to take an expensive/cost prohibitive/jet oriented course just to take the ATP written.

It is a word to the wise as to be careful what you wish for.

 

[Inverted]

Well, for the same reason that bottom feeder charter outfits wont back us on a duty rest rewrite, NetJets isn't real concerned about focusing on ATP issues seeing as they require every pilot to have one.

 

[mshunter]

What are you trying to insinuate here?

That you've been lucky and worked for companies that respect regulations. A rewrite with more clear rules would prevent the crap ass operators from exploiting them so easy.

 

[ppragman]

That you've been lucky and worked for companies that respect regulations. A rewrite with more clear rules would prevent the crap ass operators from exploiting them so easy.

Dude you know when I met you in person I had just quit a job specifically because they did 24-7 on call?

 

[mshunter]

Dude you know when I met you in person I had just quit a job specifically because they did 24-7 on call?

Nope, I didn't know that, or I don't remember being told. But that's the exact kind of thing a rewrite of the rules needs to specifically address. Becaus it's complete bull.

 

[FlyByWire22]

What do you see as the "root of the problem"?

The fact that the Feds are not enforcing the rules as written currently, and 135 shops cookie cutting their way around them. I think those two issues should be addressed before adding another reg to the book. I support this idea, but I just think that getting a handle on the current issues related to this reg would be a better place to start.

 

[ppragman]

Nope, I didn't know that, or I don't remember being told. But that's the exact kind of thing a rewrite of the rules needs to specifically address. Becaus it's complete bull.

If the FAA doesn't bother to enforce the rules they have on the books now in regards to flight and duty, what makes you think they'll be better with different and more complicated rules?

 

[Inverted]

It isn't about adding another reg, in fact it isn't an addition. For like the 5th time, this is merely the forming of a committee to examine duty and rest rules, and bring a necessary change.

I don't think you guys understand about how companies skirt these regs. They don't shirt them on paper at all. Go look at duty/rest logs at a given company that keeps pilots on call 24/7. They will likely show that the time you were on rest when in fact you were on call. This isn't as simple as merely changing clock times in the FARs, this needs to go much farther. The way you report for duty, the way you are put on rest, the way companies prove this and comply. These are all the core concepts of why a change is necessary.

I am happy if you guys work for operators that only work you 8 hours a day, that is very impressive, but it is not the norm. We work 12 hour days at least, every day while we are on tour, no consideration for fatigue, no consideration for circadian rhythm, and no consideration for time zone changes. All perfectly legal, and if the pilots don't stop it by calling in fatigued, we can be ran right into making a possibly fatal mistake. We are implementing fatigue mitigation software here which is a first for a large 135 operator, and that's a great step in the right direction, but it is unique to our operation. We follow the regs and I am willing to bet we follow the regs farther than most companies, but we work hard for it. Having some science applied to 135 operations, or some better rest penalties against the company for the longer you are on duty etc. might not be a bad idea. That is what everyone should want for the industry.

 

[CFI A&P]

The fact that the Feds are not enforcing the rules as written currently, and 135 shops cookie cutting their way around them. I think those two issues should be addressed before adding another reg to the book. I support this idea, but I just think that getting a handle on the current issues related to this reg would be a better place to start.

This.

It is easier to fix a broken machine than invent another.

 

[CFI A&P]

It isn't about adding another reg, in fact it isn't an addition. For like the 5th time, this is merely the forming of a committee to examine duty and rest rules, and bring a necessary change.

I don't think you guys understand about how companies skirt these regs. They don't shirt them on paper at all. Go look at duty/rest logs at a given company that keeps pilots on call 24/7. They will likely show that the time you were on rest when in fact you were on call. This isn't as simple as merely changing clock times in the FARs, this needs to go much farther. The way you report for duty, the way you are put on rest, the way companies prove this and comply. These are all the core concepts of why a change is necessary.

I am happy if you guys work for operators that only work you 8 hours a day, that is very impressive, but it is not the norm. We work 12 hour days at least, every day while we are on tour, no consideration for fatigue, no consideration for circadian rhythm, and no consideration for time zone changes. All perfectly legal, and if the pilots don't stop it by calling in fatigued, we can be ran right into making a possibly fatal mistake. We are implementing fatigue mitigation software here which is a first for a large 135 operator, and that's a great step in the right direction, but it is unique to our operation. We follow the regs and I am willing to bet we follow the regs farther than most companies, but we work hard for it. Having some science applied to 135 operations, or some better rest penalties against the company for the longer you are on duty etc. might not be a bad idea. That is what everyone should want for the industry.

You applied there and you accepted that position. How is that different from knowing a 135 does 24/7 on call and you go to work there anyway?

My employer recognizes circadian rhythm and assigns extra rest when it is interrupted as well as concerns over time zone changes and fatigue. One of many reasons why I applied here and pursued this job.

 

[Inverted]

You applied there and you accepted that position. How is that different from knowing a 135 does 24/7 on call and you go to work there anyway?

I don't get what you're asking. Are you saying that I knew NetJets pilots worked hard, and I accepted that position, that is the same thing as going to work for somebody that keeps you on call 24/7? You are joking right?