14 CFR 135 rest rules discussion
- Thread starter aviatortolle
- Start date
Re: Cessna 421 ambulance and charter
I find it quite funny some people complaining about rest rules for 135 operations when the majority of us in the 135 side work maybe 2-3 days a week flying passenger charter, and usually only work for 3-5 hours at a time. I have rarely worked a max duty day, and when I do, I am given the time off needed to recoup. If the FAA sees this thread...........
I find it quite funny some people complaining about rest rules for 135 operations when the majority of us in the 135 side work maybe 2-3 days a week flying passenger charter, and usually only work for 3-5 hours at a time. I have rarely worked a max duty day, and when I do, I am given the time off needed to recoup. If the FAA sees this thread...........
ppragman
FLIPY FLAPS!
Re: Cessna 421 ambulance and charter
Did you just prove my point for me there?
POIs have a lot more power than you'd give them credit for. They can push an issue, or they can let something slide (a la 24/7 on duty rest rules), they might even think that that's ok. If they do, and they don't push the issue on something that's illegal because they think its legal, or think its a non-issue, they defacto interpreted the regulations. Saying POIs don't interpret the regs is like saying that DPEs don't interpret the PTS - its exactly what happens.
Did you just prove my point for me there?
POIs have a lot more power than you'd give them credit for. They can push an issue, or they can let something slide (a la 24/7 on duty rest rules), they might even think that that's ok. If they do, and they don't push the issue on something that's illegal because they think its legal, or think its a non-issue, they defacto interpreted the regulations. Saying POIs don't interpret the regs is like saying that DPEs don't interpret the PTS - its exactly what happens.
AviatorGator
Well-Known Member
Re: Cessna 421 ambulance and charter
I agree. I usually fly four days a week myself, and it is pretty rare for me to work a max duty day, and ultra rare to get anywhere near my flight time limitations. I like the 135 rest and duty rules just the way they are. Don't mess with them!
On a different note, I found it interesting in the initial job posting that the crew member was expected to change the cabin configuration from pax to ambulance. We always call maintenance out for that.
I agree. I usually fly four days a week myself, and it is pretty rare for me to work a max duty day, and ultra rare to get anywhere near my flight time limitations. I like the 135 rest and duty rules just the way they are. Don't mess with them!
On a different note, I found it interesting in the initial job posting that the crew member was expected to change the cabin configuration from pax to ambulance. We always call maintenance out for that.
Maurus
The Great Gazoo
Re: Cessna 421 ambulance and charter
FLOPs and NetJets both have Part 135 Certs that they use for a good junk of their flying.
Every fractional that I know of operates with a Part 135 certificate on top of their Part 91K stuff.
FLOPs and NetJets both have Part 135 Certs that they use for a good junk of their flying.
Douglas
Old School KSUX
Re: Cessna 421 ambulance and charter
Wouldn't that be because you aren't flying them to the limit anyway?
IMO, 135 world needs better rest rules just like 121 side.
Wouldn't that be because you aren't flying them to the limit anyway?
IMO, 135 world needs better rest rules just like 121 side.
Autothrust Blue
Welcome aboard the Washington State Ferries
Re: Cessna 421 ambulance and charter
One Level...
Wouldn't that be because you aren't flying them to the limit anyway?
IMO, 135 world needs better rest rules just like 121 side.
One Level...
AviatorGator
Well-Known Member
Re: Cessna 421 ambulance and charter
No, I have that opinion because our rules are simple and easy to follow. We don't have a complicated matrix of "IF/THEN" statements for figuring out rest and duty time allowances. The main hard and fast rule you've got to know in the 135 world is you need 10 hours of "rest" before going on duty (except when you exceed your flight time limitation). That's simple.
As far as the "on-call" debate goes, I'm not obligated to pick up my phone. That said I flew more hours than anyone else in the company the past two years. I didn't do all that flying by turning down a bunch of flights.
Wouldn't that be because you aren't flying them to the limit anyway?
IMO, 135 world needs better rest rules just like 121 side.
No, I have that opinion because our rules are simple and easy to follow. We don't have a complicated matrix of "IF/THEN" statements for figuring out rest and duty time allowances. The main hard and fast rule you've got to know in the 135 world is you need 10 hours of "rest" before going on duty (except when you exceed your flight time limitation). That's simple.
As far as the "on-call" debate goes, I'm not obligated to pick up my phone. That said I flew more hours than anyone else in the company the past two years. I didn't do all that flying by turning down a bunch of flights.
Dugie8
Well-Known Member
Re: Cessna 421 ambulance and charter
I am confused, how did I prove your point. A POI has zero ability to interp regs and rules, nadda, none, zip, zilch. They have a wide variety of pre determined rules they can approve or allow, but no power to read a reg and apply their own interp to it, LEGALLY.
With that cleared up...
The 135 rest rules are simple and straight forward, the Chief Counsel has written a very clear and on point interp of what duty is (since the regs only really discuss rest). If there are 135 jobs out there where you only work 3 days a week for 5 hours each and you are on salary, sign me up.
My heartburn with all of this is all the lowball air ambo operators out there who make their pilot be on call 24/7 and can undercut the legitimate operators who are properly staffed for a 24/7 operation. I had a gal tell me that I can bust duty because it was for an organ run and the "FAA wouldn't mind". She runs one of the bigger air ambulance operations in MN. I can just about imagine what else she pulls with her own pilots.
I am confused, how did I prove your point. A POI has zero ability to interp regs and rules, nadda, none, zip, zilch. They have a wide variety of pre determined rules they can approve or allow, but no power to read a reg and apply their own interp to it, LEGALLY.
With that cleared up...
The 135 rest rules are simple and straight forward, the Chief Counsel has written a very clear and on point interp of what duty is (since the regs only really discuss rest). If there are 135 jobs out there where you only work 3 days a week for 5 hours each and you are on salary, sign me up.
My heartburn with all of this is all the lowball air ambo operators out there who make their pilot be on call 24/7 and can undercut the legitimate operators who are properly staffed for a 24/7 operation. I had a gal tell me that I can bust duty because it was for an organ run and the "FAA wouldn't mind". She runs one of the bigger air ambulance operations in MN. I can just about imagine what else she pulls with her own pilots.
jtrain609
Antisocial Monster
Re: Cessna 421 ambulance and charter
It doesn't relate to the on call 24/7 issue, but if the FAA applies the new part 121 rules to 135 operations, companies like Ameriflight are going to go out of business. They won't have enough duty time to be able to run a great number of their schedules the way they do right now. The way I see it, they're going to have to run EVERYTHING as an out and back in the morning and then again in the evening, with an AM shift of pilots and a PM shift of pilots, basically turning it into a part time job.
It doesn't relate to the on call 24/7 issue, but if the FAA applies the new part 121 rules to 135 operations, companies like Ameriflight are going to go out of business. They won't have enough duty time to be able to run a great number of their schedules the way they do right now. The way I see it, they're going to have to run EVERYTHING as an out and back in the morning and then again in the evening, with an AM shift of pilots and a PM shift of pilots, basically turning it into a part time job.
Re: Cessna 421 ambulance and charter
:yeahthat::yourock:
There is nothing wrong with the 135 side of rest rules. Working a 14 hour duty day on the 135 side usually involves flying for 2-3 hours with 8 hours rest at the stop, and another 2-3 hours flight home, or a hotel aomwhere to get a night of sleep. Rarely does someone fly for the max 14 hours, and if they do, it's to a far off destination with a minication at the stop. I will admit, there has been times when I have flown tired, but I have never flown and felt like I shouldn't have been in the cockpit. If you are having a hard time with the rest rules of the 135 side, don't go 121. From what I read on these forums, the 121 side will wear you out much more because the seem to exploit the rules. If you call in after your 10 hours of rest fatigued, IMHO, thats your own fault for not getting to bed when you were released from duty. While working as a flight instructor, I regularly worked 12 hours a day, drove a hour each way to get to and from work, and flew 6-8 hours, seven days a week. I don't ever remember being to tired to work. Tired, yes, but not exhausted.
My point of view, if you have a problem with 135 rules, get over it. Go talk to a guy who flies for AmFlight and ask him what it's like to work a 14hr day and sit an an outstation for 8-12 hours. You take a nap when you are sitting at an out station. If you can't find a place to rest, find a new company to work for. There are no changes that need to be made because a few people can't handle an actual day of work. Adjust your personal life. If you chose this profession, you need to accept the working rules and conditions. If you're not happy with it, find a new profession.
If the FAA applies the 121 rest rules to the 135 side, look for a whole s-ton of pilots on the streets because many of the smaller 135 operations to go out of business. The y simply don't have the revenue to handle the amount of staffing that would be needed to keep the cockpits full, and will have to have crews in position where ever the airplane lands to take over. It's not that most companies can't afford, because I'd like to think the people who I fly contract for can. But it would cut so deeply into the profits of running the company that it would no longer be worth the risk of running a company, and they would close down just because the reward for running a business would no longer be there. Do you really want that to happen? I sure don't. Just look at what fuel prices do to 135 operations. I can remember when I used to be able to put 140 gallons in our Chieftain for around $550. I put 140 gallons in the airplane the other day and it cost nearly $800. When the airplane only generates $1000 dollars for the that trip when gas was only costing the $550, thats a $250 dollar hit to the profits. And the crew and maint. still has to be paid for of the $750 thats left. So we are stuck tacking on fuel surcharges, which customers always balk at. Just imagine how much more upset they would be if they had to pay for two crews, and the likely hood of loosing more charters to the airlines because it would become cost prohibitive.
Leave 135 rules alone. They aren't broken. Call in fatigued if you are that tired.
:yeahthat::yourock:
There is nothing wrong with the 135 side of rest rules. Working a 14 hour duty day on the 135 side usually involves flying for 2-3 hours with 8 hours rest at the stop, and another 2-3 hours flight home, or a hotel aomwhere to get a night of sleep. Rarely does someone fly for the max 14 hours, and if they do, it's to a far off destination with a minication at the stop. I will admit, there has been times when I have flown tired, but I have never flown and felt like I shouldn't have been in the cockpit. If you are having a hard time with the rest rules of the 135 side, don't go 121. From what I read on these forums, the 121 side will wear you out much more because the seem to exploit the rules. If you call in after your 10 hours of rest fatigued, IMHO, thats your own fault for not getting to bed when you were released from duty. While working as a flight instructor, I regularly worked 12 hours a day, drove a hour each way to get to and from work, and flew 6-8 hours, seven days a week. I don't ever remember being to tired to work. Tired, yes, but not exhausted.
My point of view, if you have a problem with 135 rules, get over it. Go talk to a guy who flies for AmFlight and ask him what it's like to work a 14hr day and sit an an outstation for 8-12 hours. You take a nap when you are sitting at an out station. If you can't find a place to rest, find a new company to work for. There are no changes that need to be made because a few people can't handle an actual day of work. Adjust your personal life. If you chose this profession, you need to accept the working rules and conditions. If you're not happy with it, find a new profession.
If the FAA applies the 121 rest rules to the 135 side, look for a whole s-ton of pilots on the streets because many of the smaller 135 operations to go out of business. The y simply don't have the revenue to handle the amount of staffing that would be needed to keep the cockpits full, and will have to have crews in position where ever the airplane lands to take over. It's not that most companies can't afford, because I'd like to think the people who I fly contract for can. But it would cut so deeply into the profits of running the company that it would no longer be worth the risk of running a company, and they would close down just because the reward for running a business would no longer be there. Do you really want that to happen? I sure don't. Just look at what fuel prices do to 135 operations. I can remember when I used to be able to put 140 gallons in our Chieftain for around $550. I put 140 gallons in the airplane the other day and it cost nearly $800. When the airplane only generates $1000 dollars for the that trip when gas was only costing the $550, thats a $250 dollar hit to the profits. And the crew and maint. still has to be paid for of the $750 thats left. So we are stuck tacking on fuel surcharges, which customers always balk at. Just imagine how much more upset they would be if they had to pay for two crews, and the likely hood of loosing more charters to the airlines because it would become cost prohibitive.
Leave 135 rules alone. They aren't broken. Call in fatigued if you are that tired.
msmspilot
Well-Known Member
Re: Cessna 421 ambulance and charter
Just what I was thinking. And you went and said it. Are you reading my mind?!?! I'll have to call George Noory!
Just what I was thinking. And you went and said it. Are you reading my mind?!?! I'll have to call George Noory!
ppragman
FLIPY FLAPS!
Re: Cessna 421 ambulance and charter
I do. Having flown 14hrs a day 5-6 days a week with 7.5hrs per day with 15-22 legs... yeah... That's not a good idea, nor is it sustainable.
I do. Having flown 14hrs a day 5-6 days a week with 7.5hrs per day with 15-22 legs... yeah... That's not a good idea, nor is it sustainable.
SpiraMirabilis
Possible Subversive
Re: Cessna 421 ambulance and charter
If/when the rest rules trickle down to pt 135 then the UPS and FedEx feeders will have to change their sort times to get the trunk aircraft at the location quicker. They can do it with 1 pilot per run but there won't be any of that 7-9 hours at the outstation, it will be more like 3-5. It's doable.
If/when the rest rules trickle down to pt 135 then the UPS and FedEx feeders will have to change their sort times to get the trunk aircraft at the location quicker. They can do it with 1 pilot per run but there won't be any of that 7-9 hours at the outstation, it will be more like 3-5. It's doable.
Dugie8
Well-Known Member
Re: Cessna 421 ambulance and charter
I do that too, more often than not. Not as many legs, but longer flights with lots of FBO appreciation time. I like the simplicity of the rules though. No reduced rest, no compensatory rest, just 10 hours (or more).
My beef isn't with the rules, its the improper crew planning based on improper interps of the rules. Giving those that don't do it correctly an unfair and illegal advantage over those that do. More importantly putting lives at risk because of it.
I do that too, more often than not. Not as many legs, but longer flights with lots of FBO appreciation time. I like the simplicity of the rules though. No reduced rest, no compensatory rest, just 10 hours (or more).
My beef isn't with the rules, its the improper crew planning based on improper interps of the rules. Giving those that don't do it correctly an unfair and illegal advantage over those that do. More importantly putting lives at risk because of it.
jtrain609
Antisocial Monster
Re: Cessna 421 ambulance and charter
There's no reduced rest with unscheduled part 135 ops?
When did that change? It existed when I was at a part 135 company, and while I'm too lazy to look it up right now, I can't imagine that for cargo operators it has changed in the last few years, because there are some companies that build schedules around reduced rest.
There's no reduced rest with unscheduled part 135 ops?
When did that change? It existed when I was at a part 135 company, and while I'm too lazy to look it up right now, I can't imagine that for cargo operators it has changed in the last few years, because there are some companies that build schedules around reduced rest.
Dugie8
Well-Known Member
Re: Cessna 421 ambulance and charter
As far as I know there has never been reduced rest under 135 (non sched). 135.267 is the reg. The only thing I see there is additional rest if you over fly your 10 or 8 hours (crew makeup dependant).
:dontknow:
edit
Scheduled ops has it, similiar to 121 reduced rest. 135.265. I have never operated under 135 scheduled ops.
As far as I know there has never been reduced rest under 135 (non sched). 135.267 is the reg. The only thing I see there is additional rest if you over fly your 10 or 8 hours (crew makeup dependant).
:dontknow:
edit
Scheduled ops has it, similiar to 121 reduced rest. 135.265. I have never operated under 135 scheduled ops.