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135 duty times... again

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At prior employers, anything over 14 hours we were strongly advised to fill out a NASA form and an occurance report. It depends on your FSDO and your inspector, but pushing the limits is still pushing the limits. Sometimes they push back.

Ronin
 
Our 135 op specs "allow" us to go to over 14 hours up to 16 hours duty, to account for the passengers being late, wx, etc. I am not a big fan of this part of the rule because it is the first 135 company I worked for that had it. Does anybody else have this? Or are we on really good terms with our POI?
 
sounds like they are letting you jump from unscheduled to scheduled 135 duty limits.. does your company fly any scheduled runs?
 
Our 135 op specs "allow" us to go to over 14 hours up to 16 hours duty, to account for the passengers being late, wx, etc. I am not a big fan of this part of the rule because it is the first 135 company I worked for that had it. Does anybody else have this? Or are we on really good terms with our POI?

What was the Ops Spec. number (i.e. A008) that gave you that authority?
 
Our 135 op specs "allow" us to go to over 14 hours up to 16 hours duty, to account for the passengers being late, wx, etc. I am not a big fan of this part of the rule because it is the first 135 company I worked for that had it. Does anybody else have this? Or are we on really good terms with our POI?

Is your POI going to defend you in FAA court if something happens between 14 and 16 hours? I wouldn't bet my career on it! Its just like driving 64 in a 55 MPH zone, yeah, you can do it, we all do it, but if something happens they will nail you to the wall!
 
I knew someone was going to ask me some question that I probably don't have an answer for or even undestand what I am talking about, but here goes. I cut this from our Ops Manual, which I think is approved by POI? I absoultely agree that it is a stupid rule but it seems to have been accepted as OK. I personally think the FAA should stand up and show some balls and make this clear cut, I believe they put some proposals together several years ago to eliminate this type of abuse, but obviously nothing has happened.


It is recognized that proper crew rest and reasonable duty limits are an important factor in operating safely. For this
reason, exceeding any regularly assigned duty period caused by circumstances beyond the control of the certificate
holder or the flight crewmember (i.e.: ATC delays, weather delays, maintenance delays, passengers being late) is
limited to 16 hours for Part 135 flights and 18 hours for Part 91 flights.

Any flight activity in excess of 10 hours flight time or 14 hours duty period requires prior approval from the
Director of Operations or Chief Pilot. If this is not possible or practical (e.g.: being airborne when the exceeding
occurs), the Director of Operations or Chief Pilot must be informed as soon as possible.
 
I knew someone was going to ask me some question that I probably don't have an answer for or even undestand what I am talking about, but here goes. I cut this from our Ops Manual, which I think is approved by POI?

OK - you don't have an Ops Spec that says how much to exceed duty hours by - but you do have a GOM entry that talks about it.

You're right - the GOM is approved by the POI, but it was the JetBlue POI who approved them scheduling pilots over 8 hours as an "experiment" and it turned out they weren't allowed to do that either.

Nevertheless - that GOM entry would rather tend to support the idea that exceeding the 14 hour duty day in unscheduled ops. is permissible under the FARs.
 
GOMs are "accepted" not "approved" by your FSDO. Nothing in a GOM can make you violate an operating rule. You can enhance an operating rule but you can't make it less restrictive unless it is supported by an Operation Specification. Ops Spec and FARs always take precedence.
 
I don't understand why most operators do not elect to comply with 135.265 instead of .267?

From the operators perspective, it gives the ability to run the extra hour, or two, with the reduced rest provision under 135.265 (c). As a pilot it only sucks more however.

But 135.261 (b)(2) opens the door to any operator that wants to use it. Just have to get the op-spec amendment.
 

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