Calling all Beech 99 Freight Dawgs

I've refused to even consider other POI's LOI because most contradict each other. If my POI says it's cool and isn't going to violate me for it, I'll keep doing it until someone tells me I can't. We operated under 135.265 and complied with all duty and flight time requirements.
 
jhugz said:
I've refused to even consider other POI's LOI because most contradict each other.
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Can't argue with that.

However, I might be wrong here but the local POIs are supposed to follow the reg interpretations of the chief counsel. The FAA has stated in several interpretations that in order for a pilot to elect 135.265 that pilot must start and end his duty day at the same time each day. Your issue might come from another inspector when you're out on the other side of the country doing a trip (kinda unlikely in the 135 world from my experience). With having a "Duel responsibility" for upholding duty/rest times, it may be difficult to hide behind your local POI when push comes to shove. Its your certificates so do whatever.

But again, in my experience, it seems 135 regs seem to be more like guidelines for operators with no one out there to hold the feet to the fire.
 
Irregardless of any compliance, if you step back and ask yourself "is this really safe", I would submit that if one had to one day review this policy after an accident or incident, which happened at the end of one of these supershifts, one might think "what were we thinking?"

Holy run on sentence.....
 
I'm aware that some of the on-demand 135 operators use the scheduled rest rules, but it'd be virtually impossible to justify this practice if push came to shove. Have fun explaining that going on duty at noon and being off duty at 3 the next morning, then coming back on at 8 PM that night to then duty off at 8 AM is "scheduled."
 
Patrick said:
I'm aware that some of the on-demand 135 operators use the scheduled rest rules, but it'd be virtually impossible to justify this practice if push came to shove. Have fun explaining that going on duty at noon and being off duty at 3 the next morning, then coming back on at 8 PM that night to then duty off at 8 AM is "scheduled."
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You're schedule is that you don't have one.
 
Patrick said:
I'm aware that some of the on-demand 135 operators use the scheduled rest rules, but it'd be virtually impossible to justify this practice if push came to shove. Have fun explaining that going on duty at noon and being off duty at 3 the next morning, then coming back on at 8 PM that night to then duty off at 8 AM is "scheduled."
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Pretty easy actually. You show the opsecs stating we can do on demand and then the other showing which rest we us. It's approved by the FAA, so you're good. Mountain out of a mole hill.
 
jhugz said:
Pretty easy actually. You show the opsecs stating we can do on demand and then the other showing which rest we us. It's approved by the FAA, so you're good. Mountain out of a mole hill.
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If I were a 135 on demand operator myself (thank god I'm not) that had to compete with your company for business, I'd be pursuing this pretty heavily. Either to get the competition to play by the same rules or to figure out how to get the same approvals. But I definitely do not want to be the sacrificial pawn/line pilot with a target on my back on that one.

Like I said its your certificates/career so do want you want. Just trying to make a logical assumption between two approvals wouldn't cut it for me though. If it were me, at the very least, I would have a talk with the POI asking specifically how and why your carrier can operate against well established FARs and the blatant interpretations of those FARs.

And if you have that please chat let us know, I'm really curious.
 
jhugz said:
I thought rest was in opsecs but maybe it's in the ops manual. Haven't looked in a while.
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Approval to use the scheduled rest is in the opspecs. Your 100% correct. Signed off and approved by the faa multiple times at that point.
 
jhugz said:
I thought rest was in opsecs but maybe it's in the ops manual. Haven't looked in a while.
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It can be in the opspecs. As I recall at AMF we needed an exemption to operate as a scheduled carrier. It then applies to all operations.

I am fairly sure a carrier can not simply choose what rest regs they want to follow. They need proper scheduled service that they are in control of to operate under the scheduled rest rules unless they get the exemption.
 
Maurus said:
It can be in the opspecs. As I recall at AMF we needed an exemption to operate as a scheduled carrier. It then applies to all operations.

I am fairly sure a carrier can not simply choose what rest regs they want to follow. They need proper scheduled service that they are in control of to operate under the scheduled rest rules unless they get the exemption.
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I don't think it's an exemption. It's the opspec(that authorizes scheduled or unscheduled rest rules are per 135) that you are approved for by your POI/FSDO.
 
Scheduled rest rules have nothing to do with whether or not the company is operating as a scheduled or on demand carrier, only whether or not you as a pilot are scheduled "off" at the same time every day, ie, has a regularly assigned duty period. And a pilot can switch from one set of rules to another as long as they have a 24 hr reset period if I remember correctly. At least I've worked at several companies, both 401 certificate compliance scheduled and on demand operations that did that.
 
That being said, instead of coming up with some • scheme where you're keeping records of possible non compliance, you'd be better off just doctoring the paperwork. My recommendation is don't do anything stupid enough to possibly get your certificate yanked, and if you do, don't blab about it on the Internet,
 
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