Originally Posted by
auflyer06
It does absolutely nothing if pilots continue to allow "rolling rest" to occur. There are at least 5 other LOIs addressing this same topic. All this one does is present an avenue for pilots to report their companies to the Feds, basically putting the ball in the pilot's court so to speak.
Legally speaking, how companies actually report and record rest makes it look perfectly valid in most cases. If you were to report to duty at 09:00, how does your company record when your rest started? 23:00 the previous night? Looks fine to me.
It is also up to you to determine if you've gotten the legal rest requirement, meaning if you weren't informed that you are on rest at 23:00 for an 09:00 show, you didn't get 10 hours of legal rest.
Ball is in our court. What are we going to do?
I agree completely.
This topic has been discussed for the past few days under the TMC thread.
Part 135 Companies need to have their rest policies in writing. If they are not, then their GOM is likely not in compliance and the FAA should be bringing it to the company's attention. If the POI has not or will not bring it to the company's attention, there are several options a pilot can pursue, anonymously, if desired.
Just because you are home or hotel and not flying, if you are "required" to answer the phone or email, you are not ON REST. If you can't drink a beer because you don't know how many hours until your duty starts... YOU ARE NOT ON REST
And if the pilot can't document his rest, the pilot & the company can be violated by the FAA.
Just sayin'...