Possible new FAA duty time rules...
- Thread starter Clocks
- Start date
kellwolf
Piece of Trash
To those that are concerned about these rules affecting their bottom line: When I first got into this biz (actually BEFORE I got into it), I got some sage advice from a lot of the old timers on here:budget within your guarantee and anything paid over that is bonus. I was able to do that since I started, and I've never really had to stress over the whole "Oh man, if I don't get 90+ hours next month, I can't make rent" deal. If the rules go through, I'm gonna see a zero impact on my finances month to month for that exact reason. If you're basing what you spend every month on what flying you MIGHT get, you're setting yourself up for a fall down the road.
Stone Cold
Well-Known Member
See, that's the thing...depending on the company, 135 anyways, there may not be a guarantee. At my former charter company, we received a base pay and flight pay. Base was, IIRC, $20K/year, and flight pay was something like $20/hour. So, technically I would have had to budget on regional airline first year pay.
Now, I have a wife that is my sugar momma and didn't have to worry about living off of base pay at the time.I do feel for the guys who are totally on daily pay. It sucks, it will suck, and there's nothing that will help it...it will go down if the rules for 135 change. Look at Boris' post to see how a "normal run" can suck.
Try 3 1/2 months straight without a day off...was I home some? Yes, but for most of that 3 1/2 months it was short overnights at home and right back for another 7+ day trip. I'd have to look it up, but I think I was at home an actual 2 or 3 full days, but on call for that time.
For those flight instructors reading this...I know what you are going to say. "Well, I work 7 days a week and love it. I'm at the office 14 hours a day and can't believe you are complaining." When you are flying high end clientele around into various spots...TEB, ASE, HPN, PBI, MDW, and other places, doing multiple legs per day, and not getting any rest from it, it wears on you. There has to be an end to it some where...my longest trip on the road, solid, was 20 days. This trip included Telluride, Aspen, the "northeast shuttle", some west coast, and everything in between.
Did we have fun? Yes. Did I learn to ski at some of the best places to ski? Absolutely. When we got home, I did not move for 2 days. It was not a good situation by the end of that trip.
surreal1221
Well-Known Member
It's shocking to see that we have experienced 135 pilots trying to provide a little bit of insight into realistic pilot pushing issues and then we have one member who doesn't really understand the negative ramifications of pilot pushing.
Sad really.
Sad really.
kellwolf
Piece of Trash
See, that's the thing...depending on the company, 135 anyways, there may not be a guarantee. At my former charter company, we received a base pay and flight pay. Base was, IIRC, $20K/year, and flight pay was something like $20/hour. So, technically I would have had to budget on regional airline first year pay.
I do feel for the guys who are totally on daily pay. It sucks, it will suck, and there's nothing that will help it...it will go down if the rules for 135 change. Look at Boris' post to see how a "normal run" can suck.
Oh, I understand that. I personally can't and won't speak on 135 ops since I've never flown under them, though. It's just seems odd that we've got people saying the rules are fine and flights are only unsafe if you make them unsafe. It would seem to me that there would ALWAYS be someone out there pushing the envelope of safety. I know at my airline, if there was a reg to be pushed, we'd get the "It's LEGAL, why can't you fly it?" speech. Oh wait, we do. Legal does not always equal safe.
surreal1221
Well-Known Member
TUCKnTRUCK
That guy
I would assume that this will hit 135, as some 121 operators still fly under 135 regs.
OldTownPilot
Well-Known Member
I know of one un-sched 135 operation that on top of being on call 24/7 would "back date" your days off, when counting the 13 off in a quarter etc.
aloft
New Member
You're arguing FOR an unsafe system, which is the same as arguing against safety. If 12 hr duty days become the limit for Pt 121, they should become the limit for Pt 135 as well. There should be ONE safety standard as it pertains to air travel, be it scheduled or on-demand, "mission" be damned.
TUCKnTRUCK
That guy
If you think current 135 is safe, take a browse through the accident synopsis on the ntsb web site. How many 135 accidents do you count over the last 2 years? What's the body count? I bet it's higher than people think. But hey, it's legal, so it must be safe.
ppragman
FLIPY FLAPS!
Compare fatal accidents from the NTSB site:
http://ntsb.gov/aviation/Paxfatal.htm
http://ntsb.gov/aviation/Paxftl35.htm
deadstick
Well-Known Member
What was the impact of 14-hr duty days on that record? I'm just playing devil's advocate, here. I agree that there should be one standard.
gtpilot
Well-Known Member
Both links show at the bottom:
As Disraeli said, there are lies, damn lies and statistics!
Boris Badenov
Fortis Leader
As you say. But then how are we meant to assess whether flying 135 is exhibiting a death wish? Can't have it both ways...either a meaningful analysis can be made, or it can't.
We should go back to ALPA's push to operate under "One Level of Safety" and now push to remove the loophole which allows those airlines to obtain (with the FAA's blessing) the OpSpec exemption to operate under Part 121 rules but still use Part 135 flight time/duty time limitations.
TUCKnTRUCK
That guy
Now pull up the passenger miles/hours flown since 1982. Compare 121 to 135. How many deaths per for each?
Per pax mile/hour, the ratio is not even close. dig deeper if you really want to establish a true report.
One level. that is all.
http://ntsb.gov/aviation/Table8.htm
http://ntsb.gov/aviation/Table9.htm
http://ntsb.gov/aviation/Table6.htm
I'll take 0.107 accidents per 100,000 hours any day over 2.4/ 100,000 hours. I'm sorry, if you want to say improving safety doesn't meet the "135 Mission" then you don't need to be flying. If tighter duty regs is really going to hurt your pay that much, then maybe you should take a close look at what you are actually doing.
deadstick
Well-Known Member
One stat I would like to see is a breakout of the 135 data for 1 vs. 2 pilot operations.
ppragman
FLIPY FLAPS!
Well, yeah, the 135 operators typically don't operate aircraft that go as fast or as far as 121 operators. It's apples and oranges. Comparison doesn't really work.
As for the red, not everything can be scheduled, and I'm not fighting safety, what I am saying is that you can't have everything on one set of rules because the rules that apply to 121 (e.g. IFR almost exclusively, full dispatch with shared responsibility, etc.) aren't necessarily how 135 works in its current incarnation. I think we need better training in decision making skills, because if you don't have the decision making skills or judgment or balls to say "no" when you need to say no with or without a dispatcher, then maybe you don't need to be flying.
The backlash to 3407 is focused almost entirely on pilot flight and duty. What nobody sees here is the necessity for pilots to have a little back bone and take themselves off of a flight if they don't feel capable. Yeah clock switching and really long work hours suck. Yeah layovers at the outstation suck. Yeah, all of that sucks, but ya know what? If you're not safe, then you shouldn't fly, it doesn't matter what the law is. You cannot regulate good judgment.
ppragman
FLIPY FLAPS!
That would be good, and hours per incident. 121 is no doubt safer, I don't doubt that at all, but its not because of flight and duty times. 121 is safer because its almost exclusively IFR airport to airport with big reliable equipment, with deice, and turbines. 135 is typically small piston singles and twins, up to and including king airs, operated in and out of everything from EWR to beaches and gravel bars. 135 flies in the same wx as 121 with equipment that's just not comparable in terms of reliability and durability. Also, as with most of these accidents, they are almost exclusively related to the weather in part 135 accidents, thus to judgment. However, Colgan 3407 was too. It was all judgment.
If you're making the case that their judgment was skewed by lack of rest, I can buy that. However, I'm not sure that that accident wouldn't have happened even if the crew was rested. The guy held the stick in his gut when he stalled. For me anyway, its doubtful that a good nights sleep would have changed that. Really, he shouldn't have been flying around in those icing conditions to begin with, especially not with such a cavalier attitude about it. Ehh, just another winter. Again that whole accident was judgment. Judgment which I believe the crew lacked, and wouldn't have been fixed by changing the laws in a type of flying that bears little resemblance to airline flying.
So the crux of these arguments is that we can save lives by changing flight and duty regulations. Which is no doubt true, because there is a small minority (IMHO) of these accidents where it was the lack of rest on this particular flight that resulted in the crash of an airplane. All things being equal however, if the pilots had the judgment not to take the flight to begin with, none of these things would have happened. So what is solution? I think ATP mins for airline FOs is probably a good one. I think that a gradated system of weather minima for approaches something similar to the airforce system discussed in another thread is a good idea. I think requiring two pilots for certain types of 135 operations, with stipulations for the times when two are required being predicated on flight and duty standards are a good idea. That being said, the knee-jerk reaction is lets make something more "restrictive" when we should be actually solving the problem. I'm open to new ideas, I'm not. however, interested in being called unsafe, unprofessional, a dangerous menace to society for my views on this which are different from yours. Let's have discourse here, and if you change my mind you change my mind, but let's not have a yelling match over things which are outside of our physical control at this time.