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?