Toonces

We had 5 airplanes and maybe 11 pilots (single pilot capable, two pilot preferred - we frequently couldn't bid if we couldn't provide two pilots). It was pretty simple. We were on duty from 8 am - 10 pm every day. If nothing came up, we were released by 3 or 4 or so. If we had a flight known ahead of time that was earlier or later, our rest was adjusted to reflect that (ahead of time). We got 1 hard day off per week, and 1 soft day off. During known busier times (Th,Fr,Sun), we would have an extra crew or two cover a later/earlier period for pop-ups.

TheFly

Rest must be scheduled per the regulations. Anything else is illegal.

Jetlife

I am not sure what you mean. It doesn't matter how many planes or pilots you have. You do it legally... 6 pilots and 3 airplanes poor manning. 2 planes and 6 pilots, you give each pilot 10 days off a month, 2 at a time (assuming the 2 planes are the same, either way, crew it 3 pilots per plane) and you give them predetermined duty and legal rest.

ackattacker

This is the way to do it. Most charters give you at least 10 hours of heads up, so you can put a crew on rest. Most pop up charters for passengers are during daytime hours so you have your crews on duty in the day and resting at night. Freight you might want to do it the other way around. If the business really depends on "pop up" charters at all hours of the day and night (air ambulance for example) then you are going to need more crews and do rotations, no other way around it. If the business can't afford to hire that many pilots then it doesn't have a viable business model and should go under. Safe and legal are the minimum barriers to entry, if you can't do it safe and legal then you don't do it.

Shaft34

Thanks for the responses. Was just curious how others have gone about it besides the standard 12/12 with 2 pilots.

GogglesPisano

Nice work, Ackattacker. Miss your debating skills on the "other" forum.

BuddhaPilot73

Nothing has changed since the legal opinion was issued by FAA General Counsel. POIs are doing this all over the place despite the fact that the FAA General Counsel has published their ruling and reaffirmed it time and again and creating loopholes like mentioned above is in contradiction to that. A POI saying it's ok if you do X, Y, and Z doesn't possess that power. Anytime you accept an assignment when you've had no notice of your 10 hr rest window starting is risking your certificate even if you can say you've had a solid 12 hrs sleep prior to notification. Who knows when the FAA will be sitting on your ramp at the end of a 14 hr day asking for a flight manifest and to explain how long you've been on call prior.

SrfNFly227

This is directly from the chief counsel after I asked if FSDOs had any leeway in enforcing the interpretations. It is not a gray area.

"Legal interpretations issued by AGC-200 are binding interpretations of
existing regulations, although they are somewhat fact specific and may not
be directly on point to a particular situation. They are not simply the
opinions of a particular attorney, but rather represent the official legal
position of the FAA's Office of the Chief Counsel, who is tasked with
interpreting the agency's regulations. As such, FSDOs do not have the
latitude to ignore them. Should you get continued pushback from a
particular FSDO, please ask the manager of the FSDO to reach out to his or
her regional counsel or to my office for clarification.

Rebecca MacPherson
Assistant Chief Counsel for International
Law, Legislation and Regulations
AGC-200
Federal Aviation Administration"

SrfNFly227

Was just going through the recent letters of interpretation and found one from February 2015 that addresses answering your phone while on rest and whether the letters are binding on the FSDOs. Thought it was appropriate to link it to this thread.

http://www.faa.gov/about/office_org/...rpretation.pdf

Here are the two main points:

"To sum up, based on the Kidd interpretation a certificate holder operating under part 135 cannot require a pilot to answer a phone call from the certificate holder during a rest period."

"A legal interpretation issued by the Office of the Chief Counsel is the FAA's official position concerning the meaning of a statute, regulation, or other legal requirement. The FAA has previously stated that "[v]alidly adopted legal interpretations issued by the Regulations Division of the Office of the Chief Counsel are coordinated with relevant program offices at FAA Headquarters and have FAA-wide application." Because a legal interpretation constitutes an official FAA position that has FAA-wide application and because a FSDO is part of the FAA, a legal interpretation issued by the Office of the Chief Counsel is binding on the FSDO."

thedud

Thank you to all who contributed. However, these regs are violated daily by most 135 operators like the one I currently work for. We often fly one leg go to the hotel and some times sit for days. Then in the middle of the night or day we are called for an "ASAP" trip. For said trip we are expected to hustle and get the airport in an unrealistically short ammount of time. All the while having never been notified when we were on or off duty. Oh and by the way if you want a beer you have to call and ask for permission. Guess what the answer always is?
The long into short is: many operators have been pulling this crap for a long time without any consequences. Why is that.?