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

Uh, ok, maybe it's just because I'm used to it but 10 hours rest and 8 hours of flying seems pretty dang simple to me.
But it's not that simple. You just operate in a small part of 135 - single pilot unscheduled. There's 2 pilot and more. There's scheduled with reduced rest.
Have you actually read 117?

I mean they more or less even drew a picture for everyone.
 
That's a good thing. Can't comply with the rules, don't operate in federal airspace.
And how, pray tell, does having at ATP CTP make a guy flying a piston twin any safer? As z pointed out, they're just replacing twins with singles. Which isn't really positive progress in my mind.
 
They're complying by parking twins.

Pardon my while my heart breaks. They will also park planes when they have to comply with the duty and rest regs right now. Not saying your company doesn't, but lots don't, and what happens if the regs were enforced today, right now, and every company had to comply? You would see companies shutting down overnight. So why do we want some regs enforced, and some not?
 
They're just flying singles instead. I'd argue it made safety go the wrong direction considering the water they fly over.

No different than companies finding loopholes in other regs, and nobody seems to bat an eye at those. These little AK operators will depart 0/0 with people on board, yet I'm supposed to feel bad that an ATP is required now, and they don't feel like meeting the requirements?
 
Maybe trim some of the duty times, but please please for the love of God do not make us deal with the confusing disaster that is 117.

117 rules when they first came out were an absolute disaster. Now that they have tweaked them, I like it a WHOOOOOOLE bunch better.....oh wait. They didn't tweak them at all. We just understand them now. But now I'm not doing 8 hour overnights with barely 6 hours to sleep followed by loooooong duty days.
 
No different than companies finding loopholes in other regs, and nobody seems to bat an eye at those. These little AK operators will depart 0/0 with people on board, yet I'm supposed to feel bad that an ATP is required now, and they don't feel like meeting the requirements?
No, the requirement to have an ATP isn't new, the requirement for tens of thousands of dollars of irrelevant (and probably in some cases, negative transfer) training is.
 
@Inverted, Why are you suddenly concerned with 135 rest regs? I thought life was perfect over there at 91k Air Force of Columbus, Ohio.


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No, the requirement to have an ATP isn't new, the requirement for tens of thousands of dollars of irrelevant (and probably in some cases, negative transfer) training is.

No different than new pilots having to scrap money together to get to ATP minimums instead of flying an RJ at 250 hours like the old days. Pay your pilots more and it will attract fresh ATP guys to work there. Create a program to get the written done. I don't bleed hearts for companies.
 
No different than new pilots having to scrap money together to get to ATP minimums instead of flying an RJ at 250 hours like the old days. Pay your pilots more and it will attract fresh ATP guys to work there. Create a program to get the written done. I don't bleed hearts for companies.
Must be nice living in your world.
 
@Inverted, Why are you suddenly concerned with 135 rest regs? I thought life was perfect over there at 91k Air Force of Columbus, Ohio.


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I've always been concerned about it. It's something that is very polarizing as far as regulations go, and now I work for a company that has a presence on Capitol Hill and is working hard to make changes that will benefit the industry. It has nothing to do with whether or not things are good at my company, in fact in that regard, we follow the regs to a T. Doesn't mean that we don't get fatigued on the road, and the subject shouldn't be examined further.
 
Must be nice living in your world.

It's not "my world." do you lose sleep at night over the regional airline industry having to park planes and cancel flights because they can't find pilots? Why should I feel bad for AK operators who can't find ATPs?
 
Maybe trim some of the duty times, but please please for the love of God do not make us deal with the confusing disaster that is 117.
Confusing? They spell out everything in 117. Hell, I prefer to just look up the regs rather than ALPA's FAQ if I am not sure of something. They really aren't hard to understand or track. Airlines no longer have the 117 issues they had when it first was introduced.

The main excuse for POIs not following national's interpretation is because they do not agree and don't believe they are bound by the chief counsel. Rewriting the regs to be clearer and more straight forward would be a big leap forward. Defining terms such as "reserve" or "on call" and writing the regs with that in mind would really help clear up any confusion.


I'm not sure why there is an argument about the ATP requirements. It is a completely different subject.
 
Confusing? They spell out everything in 117. Hell, I prefer to just look up the regs rather than ALPA's FAQ if I am not sure of something. They really aren't hard to understand or track. Airlines no longer have the 117 issues they had when it first was introduced.

The main excuse for POIs not following national's interpretation is because they do not agree and don't believe they are bound by the chief counsel. Rewriting the regs to be clearer and more straight forward would be a big leap forward. Defining terms such as "reserve" or "on call" and writing the regs with that in mind would really help clear up any confusion.


I'm not sure why there is an argument about the ATP requirements. It is a completely different subject.

You get the core concept sir. This is spot on.
 
Every time I see this thread at the top of the Gen topics, and the push back it's getting, I just scratch my head and think "WTF!"

I did 135 for more than a few years, less than a lot. The required rest isn't enough, and the way the rules are written lends them to be easily abused. Typical day to day operations usually don't get abused. But the 135 world is so wide and vast, that there are just as many operators out there who abuse the rules and break them as there aren't. Simply put, this is needed.
 
Uh, ok, maybe it's just because I'm used to it but 10 hours rest and 8 hours of flying seems pretty dang simple to me.

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:
§ 117.23 Cumulative limitations. (a) The limitations of this section include all flying by flightcrew members on behalf of any certificate holder or 91K Program Manager during the applicable periods. (b) No certificate holder may schedule and no flightcrew member may accept an assignment if the flightcrew member’s total flight time will exceed the following: (1) 100 hours in any 672 consecutive hours or (2) 1,000 hours in any 365 consecutive calendar day period. (c) No certificate holder may schedule and no flightcrew member may accept an assignment if the flightcrew member’s total Flight Duty Period will exceed: (1) 60 flight duty period hours in any 168 consecutive hours and (2) 190 flight duty period hours in any 672 consecutive hours.

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.
 
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