Duty Time 135

Here is a situation I ran into the other day. Started the day with a 135 flight with a 9AM report time. Done with the 135 flight around 11. The next thing on the schedule was a 91 flight with the owner of the airplane at 10PM, that would have us duty off after 11PM which would exceed the 14 hour duty day. The guy I fly with was convinced that we were legal to do it since it was Part 91, but I disagree (we ended up getting ten hours of rest during the day, and pushed the departure time for the 91 flight back).
 
AFAICT, you were legal to repo back under 91, but NOT to accept any 135 assignment unti you'd had 10 hours free of duty. Which is not to say that this is a rational way of looking at things, but by some interpretations, it is legal.

Basically, you did your 135 flight, you dutied off. You can now do whatever you like (including Part 91 flying). But before you fly another 135 leg, you must have 10 hours of continuous, uninterrupted rest. FWIW, I would have told them to pound sand, too.
 
vheissu said:
Here is a situation I ran into the other day. Started the day with a 135 flight with a 9AM report time. Done with the 135 flight around 11. The next thing on the schedule was a 91 flight with the owner of the airplane at 10PM, that would have us duty off after 11PM which would exceed the 14 hour duty day. The guy I fly with was convinced that we were legal to do it since it was Part 91, but I disagree (we ended up getting ten hours of rest during the day, and pushed the departure time for the 91 flight back).
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The guy you fly with was correct. You could have flown that 91 leg for 100 hours home if that's what it took. When you got done with the 91 leg, then your 10 hours of rest starts. Unless of course you get another perfectly legal 91 leg at 1am... and at 3 am. Then it starts at the end of those.
 
vheissu said:
Here is a situation I ran into the other day. Started the day with a 135 flight with a 9AM report time. Done with the 135 flight around 11. The next thing on the schedule was a 91 flight with the owner of the airplane at 10PM, that would have us duty off after 11PM which would exceed the 14 hour duty day. The guy I fly with was convinced that we were legal to do it since it was Part 91, but I disagree (we ended up getting ten hours of rest during the day, and pushed the departure time for the 91 flight back).
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The guy that you fly with is correct.

Reference "14 hour duty day": http://forums.jetcareers.com/threads/duty-time-135.146737/page-4#post-2081795
 
SteveC said:
The guy that you fly with is correct.

Reference "14 hour duty day": http://forums.jetcareers.com/threads/duty-time-135.146737/page-4#post-2081795
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I'm not sure I agree with that. We had a duty assignment with a Part 135 leg. Whether the end flight was Part 91 or not shouldn't matter, as we should have to look back at the scheduled end of the day and see our 10 hours of rest in the 24 hour period, which wouldn't be the case the way it was scheduled.

From the Austin Collins duty guide-

"A flight with no customer property and no paying passengers on board may be conducted
under Part 91 (unless you have an FAA-approved company policy that prohibits this). In that case, Part 135
regulations do not apply to that leg. If a duty assignment is scheduled to include even ONE Part 135 flight
(leg), however, then §135.267 applies to the entire assignment in terms of whether you can accept it or not. In
other words, “one drop poisons the whole barrel.”
 
vheissu said:
I'm not sure I agree with that. We had a duty assignment with a Part 135 leg. Whether the end flight was Part 91 or not shouldn't matter, as we should have to look back at the scheduled end of the day and see our 10 hours of rest in the 24 hour period, which wouldn't be the case the way it was scheduled.

From the Austin Collins duty guide-

"A flight with no customer property and no paying passengers on board may be conducted
under Part 91 (unless you have an FAA-approved company policy that prohibits this). In that case, Part 135
regulations do not apply to that leg. If a duty assignment is scheduled to include even ONE Part 135 flight
(leg), however, then §135.267 applies to the entire assignment in terms of whether you can accept it or not. In
other words, “one drop poisons the whole barrel.”
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It applies to the entire 135 assignment. 135.267 governs no one bit of any part 91 leg. If he is really saying what you are, then frankly he is wrong. Where do you think the term 91 home came from?
If you go back and forth between 135 and 91 legs, the rest for 135 does not start until you are done with ALL duty, including the 91 parts.
You need 0 minutes of rest for a 91 leg even if you flew a 135 and maybe a 121 leg that day.
 
vheissu said:
I'm not sure I agree with that. We had a duty assignment with a Part 135 leg. Whether the end flight was Part 91 or not shouldn't matter, as we should have to look back at the scheduled end of the day and see our 10 hours of rest in the 24 hour period, which wouldn't be the case the way it was scheduled.

From the Austin Collins duty guide-

"A flight with no customer property and no paying passengers on board may be conducted
under Part 91 (unless you have an FAA-approved company policy that prohibits this). In that case, Part 135
regulations do not apply to that leg. If a duty assignment is scheduled to include even ONE Part 135 flight
(leg), however, then §135.267 applies to the entire assignment in terms of whether you can accept it or not. In
other words, “one drop poisons the whole barrel.”
Click to expand...

Scenario:

Pilot reports for duty, has to airline to a remote airport to meet the aircraft. Travel time is 6 hours including early arrival at airport, check-in, clearing TSA, and then a 2-leg journey in back of an RJ (with a crappy connection at the hub). Pilot then flies a 2-leg 135 flight assignment for 3 hours, does 30 minutes of paperwork, waits 45 minutes for a shuttle ride from the FBO to the main terminal, then waits another 2.5 hours for his flight home (he gets a nice terminal restaurant dinner). The travel time to the home airport is 4 hours.

Can he accept this assignment?
 
Yes because at the end of the flight he's only been on duty 9 hours. Everything after the 135 flight lands is irrelevant.
 
SteveC said:
Scenario:

Pilot reports for duty, has to airline to a remote airport to meet the aircraft. Travel time is 6 hours including early arrival at airport, check-in, clearing TSA, and then a 2-leg journey in back of an RJ (with a crappy connection at the hub). Pilot then flies a 2-leg 135 flight assignment for 3 hours, does 30 minutes of paperwork, waits 45 minutes for a shuttle ride from the FBO to the main terminal, then waits another 2.5 hours for his flight home (he gets a nice terminal restaurant dinner). The travel time to the home airport is 4 hours.

Can he accept this assignment?
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I say no. His rest starts when he is free from all obligation to the company, which would be the time he arrives at his home base at the end of his very long day. Count back 24 hours from that time. Is there ten hours of uninterrupted rest in this timeframe? In this case there wouldn't be. This is how I always understood it. I am always up for a little reeducation!
 
SteveC said:
Scenario:

Pilot reports for duty, has to airline to a remote airport to meet the aircraft. Travel time is 6 hours including early arrival at airport, check-in, clearing TSA, and then a 2-leg journey in back of an RJ (with a crappy connection at the hub). Pilot then flies a 2-leg 135 flight assignment for 3 hours, does 30 minutes of paperwork, waits 45 minutes for a shuttle ride from the FBO to the main terminal, then waits another 2.5 hours for his flight home (he gets a nice terminal restaurant dinner). The travel time to the home airport is 4 hours.

Can he accept this assignment?
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Absolutely, no question about it.
 
vheissu said:
I say no. His rest starts when he is free from all obligation to the company, which would be the time he arrives at his home base at the end of his very long day. Count back 24 hours from that time. Is there ten hours of uninterrupted rest in this timeframe? In this case there wouldn't be. This is how I always understood it. I am always up for a little reeducation!
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It is a legal assignment.

The only thing you need to add to your understanding is that the rest requirement applies to the completion of the FLIGHT assignment, not all duty. Let me paraphrase the regulation just a little:

At the completion of every 135 flight the pilots must be able to find ten hours of continuous rest within the last twenty-four.
 
I have seen an approved GOM allowing extending your "duty" time under part 135. Essentially its throwing the whole look back out the window.
Just wondering what you all think, could the PIC get in trouble for going over 14 in this scenario?
 
js0305 said:
I have seen an approved op spec for extending "duty" time under part 135. Essentially its throwing the whole look back out the window.
Just wondering what you all think, could the PIC get in trouble for going over 14 in this scenario?
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You know the number of that op spec? And if that really exists, then of course not.
 
js0305 said:
I misspoke, i have seen it in a GOM. Edited previous post.
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You can do over 14 hours in some scenarios. For example for scheduled 135 you can go to 15 but then are on reduced rest.
The GOM does not over rule the FARs though.
 
Boris Badenov said:
*shrug*. We have it from on high that we're allowed to exceed 14, provided we realistically planned 14. And since the way I heard it, we have uhm..."family connections" at CAMTS. Well. I hope there's not a divorce involved in all of this.
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I heard that too. When I mentioned that the CAMTS standards pretty specifically states one should use part 135 flight duty time limits on any flight that has our med crew on board, including coming back to an assigned base I was told rather tersely that our accreditation is based on "substantial compliance" and to please shove off. Yes sir, I said!
 
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