minitour

Well, a few problems.

The first problem is that the POI has zero legal authority to interpret regulations regarding rest, duty or the price of tea in china. He or she may think they do, but they do not. In the end, the POI can write a book to you telling you it's legal to be on call 24/7, but when the judge suspends your certificate he won't care if it was written on gold paper and blessed by the Pope himself.

The second problem is the "jackass"...sorta. Once you're on call, you are not at rest...but you are not on duty necessarily. You can be neither at rest nor on duty. One of those times would be travel (not local in nature).

However, "jackass" may have a valid concern.

Regarding this.

Remember, for 135 on-demand, the FAA doesn't care about, nor do they address "duty" in the regs (For pilots). All they care about is flight time (8 or 10 hours) and rest.

At all times, you must be able to look back 24 hours (from this second) and at some point see 10 consecutive hours of rest. Now, your company seems to do rest the proper way. On-call is not rest. Doing jepps is not rest. Cleaning the plane is not rest. Yadda yadda.

However, if you are required to be available for duty should duty arise (that may be word-for-word out of the legal interpretation) at (for example) 0600 in case a pager goes off, then the last time you may legally perform a duty for the certificate holder is 2000.

24 (hours /day) - 10 (hours rest) = 14 (hours available for a duty). 0600+1400=2000.

If the pager goes off at 1700, you need to be back in rest by 2000 regardless of where the pax are, where you are and what you're trying to accomplish. Late pax/cargo/bla bla, are not excuses for violating your rest regulation.

So, if that's where "jackass"'s concern is coming from, he's right...and so is the POI. The chief counsel (the ones with legal authority to interpret regulations that the judge will use to revoke/suspend your certificate) says so. I think the Whitlow letter covers some of it and there was also a 2009 interpretation that discussed it also.

Here ya go.
"Section 135.267(d) requires that flight crewmembers must have at least 10 consecutive hours of rest during the 24-hour period preceding the planned completion time of an assignment made under § 135.267(b). A rest period must be (1) continuous, (2) determined prospectively (i.e., known in advance), and (3) free from all restraint by the certificate holder, including freedom from work or freedom from present responsibility for work should the occasion arise."

Emphasis mine.

From

http://www.faa.gov/about/office_org/...2009/Berry.pdf

10 hours of rest within 24 hours of the planned completion time of the duty assignment. If you're on the pager, you are not at rest.

-mini