New Part 135 duty and rest committee ARC
07-07-2019, 07:38 PM
#11
Gets Weekends Off
Joined APC: Nov 2017
Posts: 509
Add in the single pilot aspect. Freight and passenger ops both. Can’t really pull in the 121 stuff with that. Also a good chunk of 135 freight is adhoc for feeder ops based on day to day volume and manufacturing supply chain. Just no way to predict or do scheduled ops.
07-07-2019, 10:37 PM
#12
On Reserve
Joined APC: Oct 2018
Posts: 10
Just make it mandatory 10 hours rest. Keep it simple. The fractionals will not be the only ones fighting change. The UPS and Fedex feeders will all be affected by an extension of rest. We all saw how the 121 cargo carriers got excluded from the 117 rules. My guess is that there will be no changes.
09-14-2019, 10:01 PM
#13
New Hire
Joined APC: Sep 2019
Posts: 1
What will this do for the pilots who are forced to be on call 24/7? They can put out letters of interpretation saying one thing but then turn the blind eye and allow operators to do something different.
Will they finally make it a regulation so that pilots are required to ACTUALLY know when they are on duty every day?
They should put it in the big book of FARs in part 135 that a flight crew member's 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 the present responsibility for work should the occasion arise."
If you’re required to be on call all day for work, they shouldn’t be allowed to call you at midnight to get up and go fly 14 hours. That isn’t safe yet it’s not forbidden under part 135. All 135.267 says is that they,”must provide for at least 10 consecutive hours of rest during the 24-hour period that precedes the planned completion time of the assignment.”
Based on the vague wording, they could call you at 2am and tell you that you weren’t at work for the last 10 hours so you’ve had rest. It doesn’t matter if you we’re just laying down after being awake for 16 hours ready to go waiting for a call.
These operators aren’t going to stop what they’re doing until 135.267 says what all the letters of interpretation say.
Will they finally make it a regulation so that pilots are required to ACTUALLY know when they are on duty every day?
They should put it in the big book of FARs in part 135 that a flight crew member's 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 the present responsibility for work should the occasion arise."
If you’re required to be on call all day for work, they shouldn’t be allowed to call you at midnight to get up and go fly 14 hours. That isn’t safe yet it’s not forbidden under part 135. All 135.267 says is that they,”must provide for at least 10 consecutive hours of rest during the 24-hour period that precedes the planned completion time of the assignment.”
Based on the vague wording, they could call you at 2am and tell you that you weren’t at work for the last 10 hours so you’ve had rest. It doesn’t matter if you we’re just laying down after being awake for 16 hours ready to go waiting for a call.
These operators aren’t going to stop what they’re doing until 135.267 says what all the letters of interpretation say.
09-15-2019, 06:48 AM
#14
Gets Weekends Off
Joined APC: Jul 2013
Posts: 460
Originally Posted by FlyingTired
What will this do for the pilots who are forced to be on call 24/7? They can put out letters of interpretation saying one thing but then turn the blind eye and allow operators to do something different.
Will they finally make it a regulation so that pilots are required to ACTUALLY know when they are on duty every day?
They should put it in the big book of FARs in part 135 that a flight crew member's 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 the present responsibility for work should the occasion arise."
If you’re required to be on call all day for work, they shouldn’t be allowed to call you at midnight to get up and go fly 14 hours. That isn’t safe yet it’s not forbidden under part 135. All 135.267 says is that they,”must provide for at least 10 consecutive hours of rest during the 24-hour period that precedes the planned completion time of the assignment.”
Based on the vague wording, they could call you at 2am and tell you that you weren’t at work for the last 10 hours so you’ve had rest. It doesn’t matter if you we’re just laying down after being awake for 16 hours ready to go waiting for a call.
These operators aren’t going to stop what they’re doing until 135.267 says what all the letters of interpretation say.
Will they finally make it a regulation so that pilots are required to ACTUALLY know when they are on duty every day?
They should put it in the big book of FARs in part 135 that a flight crew member's 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 the present responsibility for work should the occasion arise."
If you’re required to be on call all day for work, they shouldn’t be allowed to call you at midnight to get up and go fly 14 hours. That isn’t safe yet it’s not forbidden under part 135. All 135.267 says is that they,”must provide for at least 10 consecutive hours of rest during the 24-hour period that precedes the planned completion time of the assignment.”
Based on the vague wording, they could call you at 2am and tell you that you weren’t at work for the last 10 hours so you’ve had rest. It doesn’t matter if you we’re just laying down after being awake for 16 hours ready to go waiting for a call.
These operators aren’t going to stop what they’re doing until 135.267 says what all the letters of interpretation say.
09-15-2019, 10:49 AM
#15
Gets Weekends Off
Joined APC: Apr 2007
Posts: 867
Originally Posted by FlyingTired
What will this do for the pilots who are forced to be on call 24/7? They can put out letters of interpretation saying one thing but then turn the blind eye and allow operators to do something different.
Will they finally make it a regulation so that pilots are required to ACTUALLY know when they are on duty every day?
They should put it in the big book of FARs in part 135 that a flight crew member's 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 the present responsibility for work should the occasion arise."
If you’re required to be on call all day for work, they shouldn’t be allowed to call you at midnight to get up and go fly 14 hours. That isn’t safe yet it’s not forbidden under part 135. All 135.267 says is that they,”must provide for at least 10 consecutive hours of rest during the 24-hour period that precedes the planned completion time of the assignment.”
Based on the vague wording, they could call you at 2am and tell you that you weren’t at work for the last 10 hours so you’ve had rest. It doesn’t matter if you we’re just laying down after being awake for 16 hours ready to go waiting for a call.
These operators aren’t going to stop what they’re doing until 135.267 says what all the letters of interpretation say.
Will they finally make it a regulation so that pilots are required to ACTUALLY know when they are on duty every day?
They should put it in the big book of FARs in part 135 that a flight crew member's 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 the present responsibility for work should the occasion arise."
If you’re required to be on call all day for work, they shouldn’t be allowed to call you at midnight to get up and go fly 14 hours. That isn’t safe yet it’s not forbidden under part 135. All 135.267 says is that they,”must provide for at least 10 consecutive hours of rest during the 24-hour period that precedes the planned completion time of the assignment.”
Based on the vague wording, they could call you at 2am and tell you that you weren’t at work for the last 10 hours so you’ve had rest. It doesn’t matter if you we’re just laying down after being awake for 16 hours ready to go waiting for a call.
These operators aren’t going to stop what they’re doing until 135.267 says what all the letters of interpretation say.
Hate to be blunt, but the operator is only half the problem. Pilots who accept such assignments when they know it’s in violation of the regs are the other.
135.263(a) A certificate holder may assign a flight crewmember and a flight crewmember may accept an assignment for flight time only when the applicable requirements of §§135.263 through 135.271 are met.
The federal aviation regulations have the force and effect of law. Certificate holders and flightcrew members operating under part 135 are required to comply with §135.267. Whether a POI should be held accountable for not enforcing a requirement is an internal agency matter and is separate and apart from a certificate holder's duty to comply with the regulations.
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