[QUOTE=V

Now granted,this NPRM is aimed at the 121 world for now, but the NPRM itself expains that the FAA does not feel there is a difference between 121 scheduled, Supplemental, Flag, 135, etc, as far as fatigue is concerned and goes on to say that 135 should pay close attention because the final rule for 135 will look very close if not exactly the same as the one for 121. I think this is fairly obvious by the proposed implementation of an entirely new Duty / Rest regualtion in Part 117...this would be all encompassing and Part 121 and 135 would simply refer to 117 when it comes to duty limits.[/QUOTE]

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.

Why is it important what they change the rules to? The consensus seems to be that we don't follow them now. Why would creating new rules mean that we would follow them?

Bob, You seem to need to hijack the thread, I wanted to have a meaningful conversation on how the powers that be see us 135 guys differently than the 121 guys. If you would like, I could start another thread about how 135's don't follow rules that the FAA will not enforce, maybe then this conversation could take place without the distraction.

No, Bob's right. That's not a hijack....it's a valid point. Why does it matter what the rules are when people are going to do what they need to do "to pay the bills" anyway?

Let's pretend they changed it to 8 hours on duty max, 4 hours of flying max and then 36 hours of rest.

...do you REALLY think people would do that, or would they still just pretend to be at rest even though they're tethered to their blackberry waiting for a trip so they can launch within 15 minutes?

Until the FAA grants the pilots immunity for advising them of the operators doing illegal 24/7 on-call and shuts down those operators........the actual rules don't matter to most people. Those of us following the rules will continue to do so and those who don't will continue to not. Nothing changes except I might get 9 hours behind the door rather than 10 hours including a 30 minute cab ride each side, 30 minutes to prep my uniform, 60 minutes for dinner, 30 minutes to unwind and talk to the wife and 6 hours of sleep if I'm lucky, so I can wake up and get myself ready...and skip breakfast. Or I can have 5 hours of sleep, get ready and have time for breakfast. Really, it's a wash. By the end of my 8-day "tour", I'm going to be fatigued...hopefully not enough to compromise safety, just enough to make me skip working out so I can get sleep.

-mini

I agree completely and think that this is the heart of the matter, I am sorry, bob for jumping on you like that, I think that the amnesty is a great idea, however why do this when no one is complaining about not changing the 135 reg the way they did about changing the 121's. I think (I don't know because I have never had the luxury) that knowing my flight schedule ahead of time would be much less stressing than waiting at the airport nine hours after flying four hours to see if I have a trip. I just don't see how 121 is "more" fatiguing, or is it a matter of what is in back?

Well, yeah. Until the pilots stop doing the illegal stuff so they can have a job (so the company won't get shut down - wah), none of this even matters. I think that's Bob's (good) point.

-mini