ppragman
FLIPY FLAPS!
What in particular is wrong with 135 duty and rest rules other than enforcement?
CALL TO ACTION: Support a rewrite of Part 135 duty and rest rules
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What in particular is wrong with 135 duty and rest rules other than enforcement?
Inverted
mmmmmm wine
It's not very dynamic, it has loopholes that operators use to skirt the regs. And it is old. What was wrong with 121 duty and rest before the rewrite? Is the cargo carve out a good thing? Why anyone advocates to work 14 and 10 day after day makes me scratch my head. We can be doing it better and safer, why not make a change towards doing so?
Inverted
mmmmmm wine
It's a perfect, absolutely perfect example of what's wrong with this industry. Instead of invoking change for the better, it's met with bitching and moaning about how awesome 135 rest rules are.
It literally takes longer to come in here and bitch than it does to send a simple, ALREADY FORMED EMAIL to your local government.
It literally takes longer to come in here and bitch than it does to send a simple, ALREADY FORMED EMAIL to your local government.
Capt. Chaos
Well-Known Member
Well for starters not all 135 is of the same mind set, I know lots of single pilot 135 guys that have 4-5 month to make their money for the year and would like to be able to work longer days. Taking the cookie cutter approach of what is good for the NetJets Union is good for everyone else would be a hard sell here.
Inverted
mmmmmm wine
You are joking right? You're saying that you guys are happy being run ragged, no consideration for fatigue mitigation and rest? Just wow...
BEEF SUPREME
Well-Known Member
It would be nice to have some kind of acknowledgement of back side of the clock operations. Red eyes. Some kind of bonus rest.
Usually someone just starts yelling at me and tells me to suck it up right about now so....
Roger Roger
Bottom of the list
They're too easy to figure out. We need to make it so damn complicated you can never know if you're legal or not.
Roger Roger
Bottom of the list
It's absolutely absurd to require a guy flying pax vfr in a Navajo to have sim training in a big jet.
ppragman
FLIPY FLAPS!
I don't want to work 14 hour days, day after day, but at the same time, the flexibility of being able to do so means things like medevac services are possible. I'd rather "vote with my feet" if the company is abusing me too much than try to get laws that no one abides by anyway passed. How many 135 operations use illegal 24/7 on call? And you think that developing a system akin to 121 would solve that? I don't, the garbage operators will use the complexity of the rule to continue to be garbage operators. Why don't we see to it that current regulations are enforced before we start adding new stuff?
I don't think it's "dumb" I just think that this is the wrong battle to pick, and I don't agree that this an improvement for unscheduled rules. Scheduled rules under 135 are garbage, and way harder to sustain in my experience. 9 hours is not enough to be able to "wash rinse repeat" ad nauseum.
I can agree with this, flying at 2:30am sucks - ask me how I know. Still, I don't think 121-style fatigue programs would be a good fit for 135. I have to preface this with my experience where the "crappiest" schedule I ever had was under Scheduled 135 rules, and not under the on-demand rules. As far as I am concerned, the on-demand rules work fine provided your company has a decent fatigue policy and there are zero penalties for timing out for fatigue. If your company doesn't provide you with the ability to call in fatigued without repercussions do you really think the systemic problems with that company will be fixed by the addition of some rule the POI probably won't be able actually police?
Inverted
mmmmmm wine
I am not familiar with the new rule. it requires you to get sim time in a big jet?
Inverted
mmmmmm wine
What I keep telling you, is that it is a change to the duty and rest portion of part 135, it doesn't mean they are just going to change duty to 12 hours and rest to 12 hours. How about changing the way records are kept, auditing, reporting, tracking? It is one thing to work for a company that complies with regulations, hell NetJets is a poster child for doing it by the book 100%, but you get to share the airspace with tired, fatigued and illegal crews who are an accident waiting to happen. If you are ok with that, then great, you have "voted with your feet"
ppragman
FLIPY FLAPS!
It's not really "run ragged" if you take the entire winter off to do whatever the hell you want. A good friend of mine used to work 5 months in the summer then spend the rest of the year sitting on beaches in SE Asia and trekking around Patagonia. A coworker of mine here did something similar before he came here.
Inverted
mmmmmm wine
I will say something else. Getting congress to vote in approval for a committee is a helluva lot more than anyone else has done for part 135, anybody who is sitting here reading this and not willing to show support to have a committee REVIEW part 135 duty and rest rules is quite frankly a fool.
Inverted
mmmmmm wine
Sweet, I didn't know you could work 10 days strait 14/10 and not get fatigued because you had 5 months off in the winter. WTF does this have to do with rest and duty? I get 3 weeks off for vacation, does that mean that I have to give my company 3 weeks of 14/10 cause I just had vacation? This is blowing my mind...
ASpilot2be
Qbicle seat warmer
I think he is referring to the sim time needed to get the ATP written done.
ppragman
FLIPY FLAPS!
Changing the way records are kept, audited, reported, tracked, etc. would be good... we have that, it's called electronic record keeping, and many 135 operations are moving to this system. The Federales should be pushing for this at every operator and developing a standard system that audit's automagically - that's on their end not on the end of the operator. Also, your "share the airspace" argument is a straw man, that argument could be created for anything - by that standard, no more ultralights, GA, piston twins that don't make climb gradients, single-engine IFR the list goes on and on. Instead, we should focus on the getting the feds to enforce the laws they already have on the books. A law change I would support for 135 would be requiring Full 135 operators (it's overkill for basic and single pilot operators in my mind) to develop SMS and I would be on board with requiring those SMS programs to include fatigue management programs, but thats a different type of change.
Roger Roger
Bottom of the list
To fly scheduled pax flights in a multi engine aircraft (VFR or IFR) one must hold a multi atp. Ergo, unless you hire only guys who got their ATP prior to the new rules, your VFR Navajo pilot has to go through jet sim school. It's freaking retarded.
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