Possible new FAA duty time rules...

This isn't to serve as a hey let's help the pilots out, this is to serve the general public which the government is in charge of protecting. Maybe some 135's don't abuse the duty time regulations but by strenghtening them it can only improve those.

Remember, regulations aren't there to protect you as a pilot, they are rules to follow to keep the public (your passengers) safe, case in point regulations only change after bloodshed.
 
ppragman said:
But that's the thing, part 135 is about being solely responsible for yourself and your pax. Part 135 is as unsafe as the individual pilot makes it, not what regulation says. If you follow the regs to the letter of the law and launch when you shouldn't have, you're still the one responsible. That's the best part about 135. You are master of your own destiny. The duty times we have now are sufficient to maintain safety. I agree that some charter guys are pushing the limits, but, I'll be honest with you, those guys are in the minority, the rest of us are well within the margin of safety and relness. How much time 135 did you have before you went to the 121 ranks? None? I thought so. Its a different style of industry, and apples don't equal oranges. I'd be stoked if this rule applied to 121, not to 135.
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You think there are more freight dawgs than charter people out there? Really? Just to give you a couple of examples of what I think is ludicrous...

1. 13 in a quarter. You can have 1-13 Jan off, and then not have another day off until 17-30 Jun. Seriously, that's sad. Yes, it is mostly a charter area, as I am sure you have some days off. There are on-demand freight guys who go from place to place and run into this also.

2. Switching clocks. When I was at the 'Net, I was a floater. I was "on call" during my 8 days on. We normally flew at night, and then weekends we would normally fly days. So, during the week, I would stay up at night if I wasn't called, and then the weekends would be all messed up. There was one weeknight they called me at 0500 for a 5 leg, 7 hour flight time day. Unfortunately I missed the call. When I called dispatch back, they had found some other poor soul to do the flight. This is the way a lot of charter ops work, whether legal or not. On call 24/7.

We need straightforward rules saying this is acceptable, but do not try doing this to your poor pilots. It is unsafe.

Yes, some people might lose some money. The companies will also. They will have to hire more people. It is the safe thing to do.
 
Stone Cold said:
1. 13 in a quarter.

2. Switching clocks.

This is the way a lot of charter ops work, whether legal or not. On call 24/7.

We need straightforward rules saying this is acceptable, but do not try doing this to your poor pilots. It is unsafe.

Yes, some people might lose some money. The companies will also. They will have to hire more people. It is the safe thing to do.
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Very good points.
 
Seggy / ATN...I just received this in an Aviation Week dated 7/27/09:

"FAA ADMINISTRATOR Randy Babbitt and Margaret Gilligan, associate administrator for aviation safety, reassured the National Air Transportation Association board of directors last week that the newest review of flight and duty time standards will remain focused on Part 121. NATA board members have been concerned that the review would encompass on-demand Part 135 operations, which would endanger recommendations developed by the Part 125/135 ARC specifically for Part 135."

Now I'm confused.

Is the Call To Action program going to impact 135 operations? Is it worth my time to go to Chicago meeting on Thursday, or is it going to be all 121 oriented?

:confused:
 
Stone Cold said:
You think there are more freight dawgs than charter people out there? Really? Just to give you a couple of examples of what I think is ludicrous...

1. 13 in a quarter. You can have 1-13 Jan off, and then not have another day off until 17-30 Jun. Seriously, that's sad. Yes, it is mostly a charter area, as I am sure you have some days off. There are on-demand freight guys who go from place to place and run into this also.

2. Switching clocks. When I was at the 'Net, I was a floater. I was "on call" during my 8 days on. We normally flew at night, and then weekends we would normally fly days. So, during the week, I would stay up at night if I wasn't called, and then the weekends would be all messed up. There was one weeknight they called me at 0500 for a 5 leg, 7 hour flight time day. Unfortunately I missed the call. When I called dispatch back, they had found some other poor soul to do the flight. This is the way a lot of charter ops work, whether legal or not. On call 24/7.

We need straightforward rules saying this is acceptable, but do not try doing this to your poor pilots. It is unsafe.

Yes, some people might lose some money. The companies will also. They will have to hire more people. It is the safe thing to do.
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All I can say to this is if we have straightforward rules that say this is acceptable then people will continue to do it, which defeats your whole plan. To do it consistently isn't exactly the best way to keep crews awake at the wheel but what regulation do you propose that will allow part 135 to maintain its flexibility while simultaneously giving crews more rest. The biggest part of this conundrum I see part 135 is that most operators are unscheduled operators, so this rule would have far reaching implications) and that at the end of the day, the Pilot in Command has sole responsibility in part 135. If you are too tired to take a trip, so you're going to scrub, and the company is going to fire you over it, then you don't want to work there anyway.
 
SteveC said:
Seggy / ATN...I just received this in an Aviation Week dated 7/27/09:

"FAA ADMINISTRATOR Randy Babbitt and Margaret Gilligan, associate administrator for aviation safety, reassured the National Air Transportation Association board of directors last week that the newest review of flight and duty time standards will remain focused on Part 121. NATA board members have been concerned that the review would encompass on-demand Part 135 operations, which would endanger recommendations developed by the Part 125/135 ARC specifically for Part 135."

Now I'm confused.

Is the Call To Action program going to impact 135 operations? Is it worth my time to go to Chicago meeting on Thursday, or is it going to be all 121 oriented?

:confused:
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With that it does look like it will be 121 orientated!
 
Seggy said:
With that it does look like it will be 121 orientated!
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The problem is that the source I quoted is a Business Aviation publication and may have a slant in how they report the issue. Also, the meetings are still having 135 Dir of Ops and Chief Pilots listed as possible attendees.

I was hoping to get some scoop from what your sources (and Todd's) are saying and if you're hearing anything from the meetings so far regarding 135 issues and if they are going to be rolled in with the 121 topics and regulations.

From the FAA website I've registered for this:
We'd like your input and to share the ideas developed at these Safety Forums. Following are instructions to register for a feedback site. The site will also post notes from each FAA Safety Forum as it is held.
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...but it might take a few days for me to get approved according to the response I got. I'm looking for feedback from people that are currently involved in the process.
 
ppragman said:
All I can say to this is if we have straightforward rules that say this is acceptable then people will continue to do it, which defeats your whole plan. To do it consistently isn't exactly the best way to keep crews awake at the wheel but what regulation do you propose that will allow part 135 to maintain its flexibility while simultaneously giving crews more rest. The biggest part of this conundrum I see part 135 is that most operators are unscheduled operators, so this rule would have far reaching implications) and that at the end of the day, the Pilot in Command has sole responsibility in part 135. If you are too tired to take a trip, so you're going to scrub, and the company is going to fire you over it, then you don't want to work there anyway.
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You will probably not be a lifer on your run you have correct? So, why are you arguing against trying to make 135 regs safer?

Right now, companies (trust me on this one) say, well it's legal (or a gray area, so we say it's legal) so go do the trip or we find somebody else. If it is clear cut illegal, then they have no leg to stand on. You will appreciate it more when you branch out to other areas of flying if you stay 135. I know it will suck for you now since you may take a pay hit, but it will be worth it when you don't have a day off from 17 Jan until 17 Jun if you really get into on-demand. I personally went 3 1/2 months without a day off. Running on a set run is nowhere as demanding as getting called any time, day or night, for days on end.

Also, another thing...you know they can give you "a day off" while you are on a trip right now, don't you? There's nothing saying you actually have to be home for a day off. They never tried that with me but others have had it happen.
 
Stone Cold said:
You will probably not be a lifer on your run you have correct? So, why are you arguing against trying to make 135 regs safer?

Right now, companies (trust me on this one) say, well it's legal (or a gray area, so we say it's legal) so go do the trip or we find somebody else. If it is clear cut illegal, then they have no leg to stand on. You will appreciate it more when you branch out to other areas of flying if you stay 135. I know it will suck for you now since you may take a pay hit, but it will be worth it when you don't have a day off from 17 Jan until 17 Jun if you really get into on-demand. I personally went 3 1/2 months without a day off. Running on a set run is nowhere as demanding as getting called any time, day or night, for days on end.

Also, another thing...you know they can give you "a day off" while you are on a trip right now, don't you? There's nothing saying you actually have to be home for a day off. They never tried that with me but others have had it happen.
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I'm not arguing against safety, I'm arguing against duty time requirements taht I don't think match the mission of 135. I don't think a blanket reform of the type that will affect 121 is necessarily the best bet for 135. I don't think that that is the way to go. Colgan 3407 was pilot error, error in judgment, error in planning, error in professionalism. If they would have said, "put another crewmember on, I'm not currently capable to make this flight," I'd be willing to bet things would've turned out differently.

Frankly, its the weather that gets them. Not necessarily the fatigue (though that is a contributing factor). First major commercial airline accident in how many years and we jump all over duty time regulations, not crew training, wx minimums, and experience requirements. I don't think that the prescription fits the disease.

When I worked at ACE, I'd have a 3 weeks to a month without a day off, yeah, it sucked, yeah, it definitely reduced my effectiveness as a crewmember. Had I been a little bit more experienced, I would have decided against taking some of the trips, and face the consequences. Now, if I don't get adequate rest, I don't take the trip. Period.

Really though, what you say makes sense, and I tend to think we're both on the same side of this, we're just looking at it with different perspectives. Personally I'm totally fine with 14 duty days, however I see your point and would rather have regularly assigned "rest-periods" for "float-pilots" or guys who are on demand who don't operate within a specifc period of time.

The problem is the FARs are vague in its certification types. On-demand, eligible on-demand, and scheduled service don't necessarily cover all of the types of operations that are required. I'd rather see a change to the rules that would precipitate the creation of Feeder Service, Scheduled Freight, On-Demand Freight, On-Demand Pax, Medevac, Scheduled Pax, and Ad Hoc of some sort. Where a Feeder Service could only carry cargo under contract from a parent company, Scheduled Freight (a la airnet or flight express or AmFlight in certain cases) would be just that, scheduled freight service, etc. Then you could create regularly assigned duty periods for the sectors of 135 that warrant regulation in that respects, and leave alone the other types. I don't know, look, I want to keep making money, but I see that guys could get pushed into it, so lets find some common ground here. Maybe making a "daily wage" mandatory for all crewmembers? Daily wages are great because you want to fly (that's what we do for a living after all) but you're not a slave to getting hours in before the end of the pay period.
 
Seggy said:
Hmmmm........

Honesetly, I would attend. I doubt they are going to turn anyone away.
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Yeah, I'm going. I was just starting to get whiplash from all the back and forth.

Last week the Director of Ops asks if I want to go. I say no because it looks like it's all 121 related.

This past weekend I read on this thread that it will apply to 135, so I go back and tell him that I do want to go after all because it may well affect us.

Today I get an email (so does the D.O.) that basically says this won't apply to 135 operators.

:insane:
 
ppragman said:
I'm not arguing against safety,...cut for brevity. Look above if you don't remember what was written.
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Just a few quick things. I know you are not trying to argue against safety, but it sure sounds like it.:D I could care less that these regs were put in place years ago and benefit the businesses. It is time to change them while we have momentum. These businesses have been skirting around the gray areas for years, and abusing pilots (not all mind you, but there are some very sketchy operators out there) for too long.

As far as the airlines...I won't say I don't care about them, but it is just as an afterthought that I will watch what is happening to them. At this time, I do not plan on going to an airline. I will not say never, because you never know, but I am only worried about them as far as when my butt is in their seats. I am just riding their coattails while they have the spotlight. If they address 135 also, great, I'll be happy to provide inputs if asked. If it is just for 121 guys, then I'll merely observe while there.

Just because it started with the 121 guys and gals, does not mean we should not take advantage while everybody has the spotlight. Whether it is a knee-jerk reaction is irrelevant, as long as they are looking, let's help out, instead of sitting in the corner watching somebody else dictate what happens to us.

SteveC said:
Yeah, I'm going. I was just starting to get whiplash from all the back and forth.

Last week the Director of Ops asks if I want to go. I say no because it looks like it's all 121 related.

This past weekend I read on this thread that it will apply to 135, so I go back and tell him that I do want to go after all because it may well affect us.

Today I get an email (so does the D.O.) that basically says this won't apply to 135 operators.

:insane:
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Steve, according to the FAA website, as I know you read, it applies to 135 also. Who knows to what extent, but at least we might have a chance to be heard. It couldn't hurt to go, just in case, right?!:beer:
 
I think there's a little bit of misunderstanding of the current 135 "system" going on here. I fly for a Scheduled 135 freight op now. I am on duty for 15 hours a day, with approximately 6 hours on the ground in the city in which I "live". I get my required rest at the outstation, all 9 hours worth, and I generally block just over 6 hours a day, five days a week. On the weekends I get to sleep in my "home" city and try to pull it back together for another week. This is not the company's fault...they're bidding against other companies that will also do the flying the box company is offering, and they are bound to try to do it as cheaply as possible under the regs. They pay a fair wage and do everything they can to make my life less unpleasant. That said, it's ridiculous that it's legal to work these hours, schedule or no. I'm simply going to be tired by the end of the week. I would like to see the regs change such that this schedule cannot be foisted on anyone else.

That said, I used to work for an Unscheduled 135 freight op. I was at the whim of the cell phone, carrying car parts in the dead of winter, etc etc etc. The flying was far more challenging, the equipment more demanding, and the schedule in theory even worse. But I was never flying tired. In fact, I had a great time.

For my money, I'd love to see planes that fly on a schedule required to work under the rules of Scheduled 135, which IMHO, ought to be at least a bit more restrictive. No more pretending to be Nonsched if you're not. 15/9 for five days in a row is just not livable, especially if there's a lot of flying involved. It's the sort of thing we make fun of Mesa pilots for accepting.

On the Nonscheduled side, though, all that needs to be done is enforce the notion that crews cannot be on call 24/7. At my last employer, I could choose to be available nights or days...no calls after a certain hour, no matter how many trips were up for bid.

In summary, yes to improving Scheduled 135 duty times, although I don't think they should necessarily be the same as 121 regs. No to applying the "new rules" to Nonsched 135, just apply the old ones like you mean it.
 
Boris Badenov said:
I think there's a little bit of misunderstanding of the current 135 "system" going on here. I fly for a Scheduled 135 freight op now. I am on duty for 15 hours a day, with approximately 6 hours on the ground in the city in which I "live". I get my required rest at the outstation, all 9 hours worth, and I generally block just over 6 hours a day, five days a week. On the weekends I get to sleep in my "home" city and try to pull it back together for another week. This is not the company's fault...they're bidding against other companies that will also do the flying the box company is offering, and they are bound to try to do it as cheaply as possible under the regs. They pay a fair wage and do everything they can to make my life less unpleasant. That said, it's ridiculous that it's legal to work these hours, schedule or no. I'm simply going to be tired by the end of the week.
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No wonder you hardly post any more!
 
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