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Boy, were getting the short end of the new rules stick aren't we?

Boy, were getting the short end of the new rules stick aren't we?
I agree - what a crock. NATA (the lobbying arm of the 135 industry) just came out with an announcement that they're "pleased" that on-demand 135 operations were not included in the rulemaking.

They claim they're still "committed to the need for a revision of the Part 135 crewmember regulations related to flight hours, duty periods and rest requirements." Yeah, right. As soon as the FAA comes out with anything for the 135 world they'll be screaming bloody murder about how it's too constricting or will cost too much.

The "you're on call 24/7/365" parade continues.

Are you talking about the nprn that came out for 121? My interpretation was it said, amongst other things, "Hey Part 135, you're next! So get ready!" I hope it's so for your sake. But the 121 on call guys must be squirmin!

My interpretation was it said, amongst other things, "Hey Part 135, you're next! So get ready!" I hope it's so for your sake.

That's what I got out of it, too. Also, there are many interpretations from the Chief Counsel's office that 24/7 call is a no-go.

Boy, were getting the short end of the new rules stick aren't we?

Take a deep breath dude! If you read the document it says 135 ops is next in line. Like it or not the rules need to be taylored to the 135 world. It wont work out for anyone if no company can operate under the new rules. Take a chill pill...and stay by your phone:D

New rules are out, if we are fatigued then they can only work us an additional 8 hours.

Take a deep breath dude! If you read the document it says 135 ops is next in line. Like it or not the rules need to be taylored to the 135 world. It wont work out for anyone if no company can operate under the new rules. Take a chill pill...and stay by your phone:D

And how long do you think it will take for that phone call to come? Why don't you hold your breath and I'll call you when they call me.

There are many interpretations from the Chief Counsel's office that 24/7 call is a no-go.

That may be so but it has not made its way to the rank-and-file FSDO level. And it won't, because no FSDO inspector is going to stick his neck out by being the first one to violate a company for "on-call 24/7."

Our company's take on it is that if we do anything to compromise our 24/7 availability it puts us at a competitive disadvantage because there will always be plenty of other operators who are willing to take the trip. We would have to hire twice as many pilots to give everybody a "shift" with 10 hard hours off duty. Until all companies are held to the same standard, nothing is going to change. We put up with it because the only alternative is being unemployed. The threat of a violation is simply not realistic.

Our FSDO has stuck its neck out. We used to be on 12 hour shifts of being on a pager... if the pager went off your duty time started. Which was good because if a call came in at 4pm (6-6 schedule), and was a 5-6 hour medical trip.. you still had 14 hours to git'r'done, instead of timing out in 4 hours.

Well a helicopter guy in our company (not liking that we got to sit at home on a pager while he sat at work) asked teh FAA for clarification. A letter was sent straight to our corporate gus that if we were on a pager... we were on duty... period. So at our company (partially thanks to the Union)... i get 7 days on and 7 hard days off... and at 6am... i have to be at teh base on duty...

So there are a few FSDOs out there already crackin down on teh pager thing....


(and this is a HUGE problem... we have to delay and turn down time critical medical missions because of pilots timing out... and we go out of service wuite often to allow crew rest...but i am glad i do work for a company that isnt willing to risk my ticket so they can make money...)

The "you're on call 24/7/365" parade continues.[/quote]

If you work for a 135 company that requires you to be on call 24/7/365 then they are in violation of FAR 267 (f) which states:

"(f) The certificate holder must provide each flight crewmember at least 13 rest periods of at least 24 consecutive hours each in each calendar quarter".

This has to be scheduled as a day off in advance.

I agree that these new flight time/rest/duty rules should apply to scheduled and on-demand 135 as well. The FAA has a 60-day comment period on this proposed rule change. Nothing is stopping us from submitting comments explaining the reasons why 135 should be included now. Doesn't mean it will happen, but maybe it will encourage the FAA to get 135 rules done a bit earlier and help make our jobs safer.

If you work for a 135 company that requires you to be on call 24/7/365 then they are in violation of FAR 267 (f) which states:

"(f) The certificate holder must provide each flight crewmember at least 13 rest periods of at least 24 consecutive hours each in each calendar quarter".

This has to be scheduled as a day off in advance.

Our company is in compliance with this regulation. Actually, we get 5 hard days off per month (scheduled in advance,) so we get more time off than the regulation requires. I was referring to the "on-call 24/7" aspect of the job.

Our FSDO has stuck its neck out. We used to be on 12 hour shifts of being on a pager... if the pager went off your duty time started. Which was good because if a call came in at 4pm (6-6 schedule), and was a 5-6 hour medical trip.. you still had 14 hours to git'r'done, instead of timing out in 4 hours.

Well a helicopter guy in our company (not liking that we got to sit at home on a pager while he sat at work) asked teh FAA for clarification. A letter was sent straight to our corporate gus that if we were on a pager... we were on duty... period. So at our company (partially thanks to the Union)... i get 7 days on and 7 hard days off... and at 6am... i have to be at teh base on duty...

So there are a few FSDOs out there already crackin down on teh pager thing....

(and this is a HUGE problem... we have to delay and turn down time critical medical missions because of pilots timing out... and we go out of service wuite often to allow crew rest...but i am glad i do work for a company that isnt willing to risk my ticket so they can make money...)

I would say yours is an isolated occurrence. Most FSDOs would have no idea what to do if the rules were to be applied correctly and consistently to passenger 135 charter.

Yeah it will make our jobs alot safer because we wont have them, these rules will not work with on demand 135 period, I wish they would, but I dont see how my company could stay in business and I would rather be a little fatigued for a few more years then be trying to find a new job in this economy

I agree - what a crock. NATA (the lobbying arm of the 135 industry) just came out with an announcement that they're "pleased" that on-demand 135 operations were not included in the rulemaking.

They claim they're still "committed to the need for a revision of the Part 135 crewmember regulations related to flight hours, duty periods and rest requirements." Yeah, right. As soon as the FAA comes out with anything for the 135 world they'll be screaming bloody murder about how it's too constricting or will cost too much.

The "you're on call 24/7/365" parade continues.
Actually, Part 135 flight-duty-rest was dealt with specifically and extensively by industry and FAA participants in the Part 125-135 Aviation Rulemaking Committee several years ago, and regulations based upon the committee's recommendations are slowly grinding their way through the FAA-DOT rulemaking process. A notice of proposed rulemaking addressing those matters will probably appear within the next year or two for public comment . . . and after the comments are evaluated and other hurdles in the rulemaking process are cleared, a change in the applicable regulations will probably follow in due course.

It's worth mentioning that the FAA and industry have been battling over the 135 flight-duty-rest issue for well over a decade, and the results of the 125-135 ARC are as close as they have ever come to agreement . . . although that is no guarantee the FAA will follow all of the committee's recommendations. . . .

Actually, Part 135 flight-duty-rest was dealt with specifically and extensively by industry and FAA participants in the Part 125-135 Aviation Rulemaking Committee several years ago, and regulations based upon the committee's recommendations are slowly grinding their way through the FAA-DOT rulemaking process. A notice of proposed rulemaking addressing those matters will probably appear within the next year or two for public comment . . . and after the comments are evaluated and other hurdles in the rulemaking process are cleared, a change in the applicable regulations will probably follow in due course.

It's worth mentioning that the FAA and industry have been battling over the 135 flight-duty-rest issue for well over a decade, and the results of the 125-135 ARC are as close as they have ever come to agreement . . . although that is no guarantee the FAA will follow all of the committee's recommendations. . . .

Oldog,

Let's be honest. On 9/11 when the Part 121 rulemaking was announced, NATA stated they "...[remain] committed to the need for a revision of the Part 135 crewmember regulations related to flight hours, duty periods and rest requirements."

ONLY 5 DAYS LATER, when Administrator Babbitt says something to the effect of "we're going to be coming up with a rule for 135 next..."

NATA comes out with another press release titled: "FAA Statement Within Part 121 Flight And Rest Rule Raises Concern For Part 135 Community (http://www.nata.aero/News.aspx?newsid=346&sectionid=0)."
Among other things, they whine and moan about "the agency's commitment to honoring the letter and spirit of rulemaking guidance that requires the FAA to consider the specific costs, benefits and regulatory alternatives that may be appropriate for different types of operators." (emphasis mine.)

Pilots become fatigued whether they are flying in 121 or 135 operations. NATA wants to argue that the need for "on-demand" operations should entitle them to some magical exemption from this blatant physical reality. They love to talk a good game as long as the gun isn't pointed at their head. However, when the attention turns to them all of a sudden they start whining about how much it's going to hurt Part 135 operators.

I have absolutely no confidence that any realistic proposal will see the light of day in light of this ongoing stonewalling from Part 135 operators and their lobbying mouthpiece.

The FAA ARC rules were in NPRM back in 2004????. They did the whole NPRM process, and then nothing happened. Heard that the FAA was too busy with the -91/-135 charter problems, and the -135 rules (and 135/121 Rest/Flight/Duty) were put on the back burner.

What does it matter if they change the rules? Judging by most of the comments on this website about 24/7 on call, we aren't following the rules now. So what will it matter if the rules change when no one follows the rules now. The FAA has been very clear that on call is not rest. So if you are violating the rules now, what do you care what they change them to. Will you suddenly become compliant?

What does it matter if they change the rules? Judging by most of the comments on this website about 24/7 on call, we aren't following the rules now. So what will it matter if the rules change when no one follows the rules now. The FAA has been very clear that on call is not rest. So if you are violating the rules now, what do you care what they change them to. Will you suddenly become compliant?

skybob you broke the code.

What does it matter if they change the rules? Judging by most of the comments on this website about 24/7 on call, we aren't following the rules now. So what will it matter if the rules change when no one follows the rules now. The FAA has been very clear that on call is not rest. So if you are violating the rules now, what do you care what they change them to. Will you suddenly become compliant?
Exactly. We'll still hear guys whining about how their company would go out of business if they enforced the rest regulations. You know what? Those companies should go under. If you can't afford to operate by the rules, then you just can't afford to operate.

Well said, bob.

-mini

Exactly. We'll still hear guys whining about how their company would go out of business if they enforced the rest regulations. You know what? Those companies should go under. If you can't afford to operate by the rules, then you just can't afford to operate.

Well said, bob.

-mini

I'm sorry, but such a flippant and black-and-white argument is pretty ignorant of the realities of the Part 135 industry, and therefore deserves a response. First of all, it's not as clear cut as you would like it to be. The "rules" as you put them don't specifically address this situation. All we have to rely on are FAA Chief Counsel opinions that aren't worth a bucket of warm spit until someone is violated. To date I am not aware of any pilots or operators who have been violated for a "24/7 on call" scenario. The FAA is too discombobulated to address the issue.

Let me get one thing straight - I AGREE the interpretations say 24/7 on call isn't legal. I would love nothing more than for the FAA to finally come out with a clear rule prohibiting it (specifying that rest must be prospective, defining "duty," etc.) Until that day comes, just like thousands of other pilots out there, I have to do the job the way the company wants. Other than being on call 24/7 (outside scheduled days off,) I work for a good company. The alternative is pounding the pavement with the thousands of other pilots out on the street. Give me a break. I can't feed my family with standing on principle and neither can you.

Our company has been in business for 11 years and we have a lot of blue-chip clients. We're not some fly-by-night operator that's teetering on the edge of failure daily. We train our people well, pay them decently, and don't skimp on maintenance. But let's be real - if we had to put pilots on shifts so that everyone could have 10 hours of scheduled rest a day, then we'd need twice as many pilots and pay them $35K a year instead of $70K. Or, if we didn't hire anyone, we'd have to turn down a crapload of business due to lack of crew.

Where is the advantage of that? Even if we did play by the rules, there would STILL be operators skirting the regs who would come in and take the trips we couldn't do, and then we'd be put out of business anyway. You claim "oh well, you deserve to go out of business then." I say - take a look around you, pal - until ALL operators are forced to play by the same rulebook then NOBODY can afford to play by the rules. You may dismiss this as nothing more than "whining," but then again, it's always easy to take pot shots from the cheap seats, isn't it?

The alternative is pounding the pavement with the thousands of other pilots out on the street. Give me a break. I can't feed my family with standing on principle and neither can you.
How many would say this exact same thing about 24/7 on call, but show up at a guy's house with a Posse while he's out scabbing a trip for a striking airline?

Just curious. I won't judge.

Our company has been in business for 11 years and we have a lot of blue-chip clients. We're not some fly-by-night operator that's teetering on the edge of failure daily. We train our people well, pay them decently, and don't skimp on maintenance. But let's be real - if we had to put pilots on shifts so that everyone could have 10 hours of scheduled rest a day, then we'd need twice as many pilots and pay them $35K a year instead of $70K. Or, if we didn't hire anyone, we'd have to turn down a crapload of business due to lack of crew.
And?

If you can't afford to operate legally, you need to shut the doors. Or, better put, you need to be forced to shut the doors.

My question is always this. If a company can't abide by pretty simple (135 unscheduled operations rest rules are really pretty simple to understand/follow) rest regulations, then what other regulations or issues are they skipping on? Maintenance? Training? Insurance? I'd be willing to bet my ridiculous September paycheck that there's something else being ignored.

You claim "oh well, you deserve to go out of business then." I say - take a look around you, pal - until ALL operators are forced to play by the same rulebook then NOBODY can afford to play by the rules. You may dismiss this as nothing more than "whining," but then again, it's always easy to take pot shots from the cheap seats, isn't it?
It is whining. As someone who is currently flying 135 (and looking at moving on to a different 135 carrier at the present moment - not that it matters) I'm hardly in the "cheap seats"...pal.

You're the same kind of person that even if the rules did change (and were enforced), you'd look the other way so you could "feed your family". Hey, I won't begrudge you that. If I were in a situation where I had the choice of watching my family go hungry or pretend I'm at rest, I know what I'd do...but the realities of the situation are that even in the worst of economic times, there are jobs out there. You may not enjoy flipping burgers, but sometimes a man just has to do what he has to do so the family has food, shelter and clothes on their back. That doesn't change the fact that 135 operators that don't play by the rules as written should be shut down. 121 Air Carriers would never get away with this and 135 Air Carriers shouldn't. Rationalize it all you want.

-mini

I agree with Ted here in practice, and with Mini in theory. Quite frankly, we used to be able to support 4 pilots on one airplane but those days are gone.

Of course I could say to the aircraft owner, "pony up some more $$ for salaries & sim trainings or say bye-bye to 135"... But he owns the plane because it charters when he's not using it. His 50 hours a year on it doesn't justify the expense of ownership without charter. So, there goes my job.

Bad for me but good for the industry? Guess you can decide that, but I think the cleansing should start from the bottom up and there is a real mess at the bottom which needs addressing first.

The fact of the matter remains, 121 has been found by the FAA to not be able to operate safely, with multi crew and equipment that some of us only wished we had, in the fourteen or fifteen hours of duty time the 135 world lives with. Wouldn't logic dictate that no one could?
ATC: are you GPS equipped? Me: I'm lucky to have oil pressure. (just a joke, well maintained equipment!)

I'm looking forward to a renovation of the Part-135 regulations as well.

In my humble opinion, I think that the use of Part 91 is an 'easy way out' for an operator to put someone on the road way too long at once. I recently flew a trip from Ohio, to Arkansas, to Texas, all in one day in a Caravan. Used all 8 hours of flight, and was on duty around 15 hours. When I got to Texas, I was told, "Hey, the trip home is part 91, doesn't count towards anything, so way don't you just climb back in and come home now?" If I had done that, I would have flown about 16 hours, and been on the road for over 24 hours straight, and it's LEGAL.

I told them to get me a hotel. I believe in rest.

Are we really having a discussion about "we know its not really legal, but golly gee I don't want to make any waves"? I hope this is mostly SICs. For a Captain to make this argument; WOW

Are we really having a discussion about "we know its not really legal, but golly gee I don't want to make any waves"? I hope this is mostly SICs. For a Captain to make this argument; WOW

Back to the question at hand, So why is it legal for 135 and not for 121? do the powers that be think that we have some advantage that the big guys don't?

Are we really having a discussion about "we know its not really legal, but golly gee I don't want to make any waves"? I hope this is mostly SICs. For a Captain to make this argument; WOW
"Hey, I need to pay the bills!"

:rolleyes:

No, but really... ->:rolleyes:

I agree, skybob...it's kinda sad, isn't it?

-mini

86pilot, it is not legal for 135. There is no different definition for rest, duty and on call. The definitions are all the same. Only the hourly regs are different. That is not to say that people don't do it all the time. And yes FSDOs ignore it alot. That doesn't make it legal or safe.
The FAA has been very clear on rest issues. We just choose not to follow the rules.

Every safety enhancement has a cost.

I don't buy the "my owner can't afford to operate legally". Aviation is not cheap. Its kind of like someone choosing to eat at a 5 star restaurant and then saying they can't afford the bill. You should have known that before you ordered.
Aviation is not cheap, never has been cheap, and never willl be cheap. If you want cheap transportation, buy a bus. I don't own an airplane because I can't afford it.
Also, would anyone here be upset if their company went out of business because another operator started a 134 and a half business on your field? You jumped thru the hoops, did the training, and paid the costs to operate a 135 and then someone comes along and operates more cheaply by skipping these costly business expenses. It doesn't mean they are unsafe. This rogue operation has very safe pilots, good mx, and a good safety record. Are you ok with what they are doing?
If you found out that your house was not up to code, even though its a great house, would you be ok with it? I would expect my contractor to build to code at least if not better. I would probably sue if he didn't. Wouldn't you?
There was another thread on this awhile back. If memory serves, there was no evidence that 24/7 on call is even remotely legal. Of course, one can always lie and say I am not really on call. My company gives me the choice to accept the flight or not at any time.
Modern technology will also make this a much easier to monitor and enforce. It won't be long before the FAA figures out they can watch Flight Tracker and watch a Captain fly all over the country all day to see exactly how long the PIC is on duty.
Will that happen, Maybe???? With all of the emphasis on fatigue within the FAA, I would hate to be the example. And it has been settled over and over that your local FSDO is not the final authority. Don't believe it. Ask your POI for a written statement that 24/7 on call is legal. Or just come on here and say which FSDO it is that allows 24/7 on call. I am sure the FAA reads this board. If they agree with you, you will never hear from them. If they disagree, I predict the operators under their watch would hear about it soon.
I have asked POIs about many things in the past. That is part of their job. If you are comfortable with the legality, just ask.
On a side note, does anyone know the difference in accident stats between turbine 121 and turbine 135?

If the NPRM on Duty / Flight time is even close to the final ruling, the new Part 117 spells it out. Anyone can read it...it's located in the last 20 pages of the NPRM. Here it is if your Google finger isn't working (The proposed Part 117 starts on page 124 if you don't want to read the studies)...

http://www.faa.gov/regulations_policies/rulemaking/recently_published/media/FAA_2010_22626.pdf

The definition of rest, which includes the prospective and free from call language, is spelled out as is the definition of Duty. It also clearly states that reserve, either hot standby (1 hour or less) or short call (2-3 hours) is considered duty for the intent of the regulation.

Now granted,this NPRM is aimed at the 121 world for now, but the NPRM itself expains that the FAA does not feel there is a difference between 121 scheduled, Supplemental, Flag, 135, etc, as far as fatigue is concerned and goes on to say that 135 should pay close attention because the final rule for 135 will look very close if not exactly the same as the one for 121. I think this is fairly obvious by the proposed implementation of an entirely new Duty / Rest regualtion in Part 117...this would be all encompassing and Part 121 and 135 would simply refer to 117 when it comes to duty limits.

[QUOTE=V

Now granted,this NPRM is aimed at the 121 world for now, but the NPRM itself expains that the FAA does not feel there is a difference between 121 scheduled, Supplemental, Flag, 135, etc, as far as fatigue is concerned and goes on to say that 135 should pay close attention because the final rule for 135 will look very close if not exactly the same as the one for 121. I think this is fairly obvious by the proposed implementation of an entirely new Duty / Rest regualtion in Part 117...this would be all encompassing and Part 121 and 135 would simply refer to 117 when it comes to duty limits.[/QUOTE]

If it were going to change, and the changes were to be "very close" why wouldn't they deal with it all at once.

Also I have not and will not do a "on call" outside a normal duty day, I was simply making the point that the duty day limits are being shortened for the 121 and not the 135, and while I understand they say it is going to change I for one would rather they do things all at once. How is it that a 121 is too fatigued after 10 but a 135 can go for 15.

If it were going to change, and the changes were to be "very close" why wouldn't they deal with it all at once.

Also I have not and will not do a "on call" outside a normal duty day, I was simply making the point that the duty day limits are being shortened for the 121 and not the 135, and while I understand they say it is going to change I for one would rather they do things all at once. How is it that a 121 is too fatigued after 10 but a 135 can go for 15.

I think they may deal with it all at once. The NPRM proposal is for an all new regulation dealing only with Flight / Rest / Duty time....Part 117. It is easier to create an all encompassing regulation that everyone must adhere to than to rewrite 121 sched., Flag, Supp, and 135. All they need to do is publish Part 117 and then delete all reference to duty time in each of the 121 and 135 sections. Why else would they create the new rules under the title of FAR 117, instead of creating them under the 121 umbrella? They already alluded to the consolidation in the NPRM language.

I posted the link to the NPRM and although lengthy at 145 pages, it is interesting stuff and paints a pretty clear picture of the FAA intent.

Why is it important what they change the rules to? The consensus seems to be that we don't follow them now. Why would creating new rules mean that we would follow them?

Why is it important what they change the rules to? The consensus seems to be that we don't follow them now. Why would creating new rules mean that we would follow them?

Bob, You seem to need to hijack the thread, I wanted to have a meaningful conversation on how the powers that be see us 135 guys differently than the 121 guys. If you would like, I could start another thread about how 135's don't follow rules that the FAA will not enforce, maybe then this conversation could take place without the distraction.

Bob, You seem to need to hijack the thread, I wanted to have a meaningful conversation on how the powers that be see us 135 guys differently than the 121 guys. If you would like, I could start another thread about how 135's don't follow rules that the FAA will not enforce, maybe then this conversation could take place without the distraction.
No, Bob's right. That's not a hijack....it's a valid point. Why does it matter what the rules are when people are going to do what they need to do "to pay the bills" anyway?

Let's pretend they changed it to 8 hours on duty max, 4 hours of flying max and then 36 hours of rest.

...do you REALLY think people would do that, or would they still just pretend to be at rest even though they're tethered to their blackberry waiting for a trip so they can launch within 15 minutes?

Until the FAA grants the pilots immunity for advising them of the operators doing illegal 24/7 on-call and shuts down those operators........the actual rules don't matter to most people. Those of us following the rules will continue to do so and those who don't will continue to not. Nothing changes except I might get 9 hours behind the door rather than 10 hours including a 30 minute cab ride each side, 30 minutes to prep my uniform, 60 minutes for dinner, 30 minutes to unwind and talk to the wife and 6 hours of sleep if I'm lucky, so I can wake up and get myself ready...and skip breakfast. Or I can have 5 hours of sleep, get ready and have time for breakfast. Really, it's a wash. By the end of my 8-day "tour", I'm going to be fatigued...hopefully not enough to compromise safety, just enough to make me skip working out so I can get sleep.

-mini

No, Bob's right. That's not a hijack....it's a valid point. Why does it matter what the rules are when people are going to do what they need to do "to pay the bills" anyway?

Let's pretend they changed it to 8 hours on duty max, 4 hours of flying max and then 36 hours of rest.

...do you REALLY think people would do that, or would they still just pretend to be at rest even though they're tethered to their blackberry waiting for a trip so they can launch within 15 minutes?

Until the FAA grants the pilots immunity for advising them of the operators doing illegal 24/7 on-call and shuts down those operators........the actual rules don't matter to most people. Those of us following the rules will continue to do so and those who don't will continue to not. Nothing changes except I might get 9 hours behind the door rather than 10 hours including a 30 minute cab ride each side, 30 minutes to prep my uniform, 60 minutes for dinner, 30 minutes to unwind and talk to the wife and 6 hours of sleep if I'm lucky, so I can wake up and get myself ready...and skip breakfast. Or I can have 5 hours of sleep, get ready and have time for breakfast. Really, it's a wash. By the end of my 8-day "tour", I'm going to be fatigued...hopefully not enough to compromise safety, just enough to make me skip working out so I can get sleep.

-mini

I agree completely and think that this is the heart of the matter, I am sorry, bob for jumping on you like that, I think that the amnesty is a great idea, however why do this when no one is complaining about not changing the 135 reg the way they did about changing the 121's. I think (I don't know because I have never had the luxury) that knowing my flight schedule ahead of time would be much less stressing than waiting at the airport nine hours after flying four hours to see if I have a trip. I just don't see how 121 is "more" fatiguing, or is it a matter of what is in back?

...I think that the amnesty is a great idea, however why do this when no one is complaining about not changing the 135 reg the way they did about changing the 121's...
Well, yeah. Until the pilots stop doing the illegal stuff so they can have a job (so the company won't get shut down - wah), none of this even matters. I think that's Bob's (good) point.

-mini