Originally Posted by
86pilot
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.