91K and 135 Rest changes are coming..

[ArtVandalay]

http://www.ainonline.com/index.php

GA Responds To Part 135 Crew Duty Proposal

By: Paul Lowe
January 25, 2011
Charter, Regulations
Both NBAA and the National Air Transportation Association have called on the FAA to initiate a full rewrite of the Part 135 flight, duty and rest rules instead of relying on a new interpretation of flight time. NBAA said the FAA’s proposal to require a flight-by-flight determination of remaining duty time is too significant for implementation simply by a notice of proposed interpretation. Under the new interpretation, operators would no longer be permitted to extend a crew duty day for unforeseen circumstances that occur before departure of the final flight segment, such as late-arriving passengers and cargo. The proposed interpretation would clarify whether the crew may take off on the last leg of the flight, knowing in advance that the delays would extend the flight beyond a 14-hour duty day. Although the comment period closed yesterday, NATA noted that the FAA typically accepts and reviews late-filed submissions.

 

[Praetorian]

http://www.ainonline.com/index.php

GA Responds To Part 135 Crew Duty Proposal

By: Paul Lowe
January 25, 2011
Charter, Regulations
Both NBAA and the National Air Transportation Association have called on the FAA to initiate a full rewrite of the Part 135 flight, duty and rest rules instead of relying on a new interpretation of flight time. NBAA said the FAA’s proposal to require a flight-by-flight determination of remaining duty time is too significant for implementation simply by a notice of proposed interpretation. Under the new interpretation, operators would no longer be permitted to extend a crew duty day for unforeseen circumstances that occur before departure of the final flight segment, such as late-arriving passengers and cargo. The proposed interpretation would clarify whether the crew may take off on the last leg of the flight, knowing in advance that the delays would extend the flight beyond a 14-hour duty day. Although the comment period closed yesterday, NATA noted that the FAA typically accepts and reviews late-filed submissions.

Delay tactic!

 

[wolfpackpilot]

So much for flying a Global, BBJ, Gulfstream, Falcon 7X...

At 14 hours duty, you'll still be looking at another 4-5 before you see the hotel.

 

[Dooker]

So much for flying a Global, BBJ, Gulfstream, Falcon 7X...

At 14 hours duty, you'll still be looking at another 4-5 before you see the hotel.

They'll probably have stipulations that take into account augmented crews.

 

[wolfpackpilot]

They'll probably have stipulations that take into account augmented crews.

I'm very interested to see what comes of that. The 550 requires 4 pilots for flights over 12 hours (91k/135). It is ridiculous, the cabin wasn't designed for that and you basically end up stepping over everyone.

My suggestion:

3 crew members... 18 hours rest before show... maximum 2.5 hour showtime before departure... they get one take off, one landing... and they can fly that plane as far as they can take it. When they land... done... 20 hours rest. (maximum of 2 hour shutdown)

 

[ArtVandalay]

It's just funny to me that the 14 hour limit was put in place because it was thought that after 14 hours of work, you were too tired to perform your duties; however, if there was an "unforseen" delay, you may continue to work beyond 14 hours. So, by that logic, "unforeseen" delays do not cause any additional fatigue; therefore, why stop working at all??? Lets have 22 hour day limit and just call it "unforeseen" delay day because, you're not tired. The FAA needs to man up on this issue and put a hard line at 14 unless augmented.

I can't tell you how many times we go over 14 due to "unforeseen" delays and dispatch tells us, "well, it wasn't planned so you can still work". REALLY?? I'm now magically rested because it wasn't planned? I guess the F bomb needs to be used more when necessary and it would fix that problem.

 

[gunfyter]

The unforseen delay is only after you cross the old short line. If you taxi out and get delayed on the way before the hold short. You have to taxi back to the gate if the delay now takes you over 14 hrs.

 

[japhy]

It's just funny to me that the 14 hour limit was put in place because it was thought that after 14 hours of work, you were too tired to perform your duties; however, if there was an "unforseen" delay, you may continue to work beyond 14 hours. So, by that logic, "unforeseen" delays do not cause any additional fatigue; therefore, why stop working at all??? Lets have 22 hour day limit and just call it "unforeseen" delay day because, you're not tired. The FAA needs to man up on this issue and put a hard line at 14 unless augmented.

I can't tell you how many times we go over 14 due to "unforeseen" delays and dispatch tells us, "well, it wasn't planned so you can still work". REALLY?? I'm now magically rested because it wasn't planned? I guess the F bomb needs to be used more when necessary and it would fix that problem.

My thoughts exactly. The old rule doesn't make any sense. I'll be glad when it changes.

 

[Dooker]

It's just funny to me that the 14 hour limit was put in place because it was thought that after 14 hours of work, you were too tired to perform your duties; however, if there was an "unforseen" delay, you may continue to work beyond 14 hours. So, by that logic, "unforeseen" delays do not cause any additional fatigue; therefore, why stop working at all??? Lets have 22 hour day limit and just call it "unforeseen" delay day because, you're not tired. The FAA needs to man up on this issue and put a hard line at 14 unless augmented.

I can't tell you how many times we go over 14 due to "unforeseen" delays and dispatch tells us, "well, it wasn't planned so you can still work". REALLY?? I'm now magically rested because it wasn't planned? I guess the F bomb needs to be used more when necessary and it would fix that problem.

Don't ever expect too much from the FAA. It has a dual and contradictory mandate: "to regulate and promote air commerce." The result is is almost always a compromise that leaves everyone feeling a tad underwhelmed.

 

[StarHustler]

Lonnnnnnngggggg overdue!

 

[gutshotdraw]

To me, the Keep It Simple, Stupid principle is what's long overdue. No rest period shorter than the previous duty period with a minimum rest of 10 hours FROM HOTEL ARRIVAL. And no less than 12 hours rest prior to any planned duty day in excess of 12 hours.

 

[pilotyip]

The ole unintended consequences has not been considered, like more pilots to do the same amount of work, putting more pressure on payrolls, higher prices that customers may not accept, more time away from base in hotels, crew waiting on the road for days without an airplane to cover those trips that may go over 14 hours. A lot of things will change, but not all of them for the good of the pilot. BTW I would feel much safer making the 30 minute flight from MMIO to KLRD after exceding 14 hours, as opposed to a 45 minute cab ride through a dark Mexican city.

 

[Tenspot]

Every safety measure that has been forced on air carriers has been met with the same arguments - increased costs and the flying public will never go for it. Every time those dire predictions have been proven false. This time is no different.

If the changes are applied across the board, then everyone has the same cost structure. Straw men arguments not with standing - this is a needed improvement.

 

[jonjuan]

BTW I would feel much safer making the 30 minute flight from MMIO to KLRD after exceding 14 hours, as opposed to a 45 minute cab ride through a dark Mexican city.

I'm sure your co-pilots don't as they are probably hoping you don't have the "big one" while en route. Give me a mexican cabby over some of the gummers i've seen squeezing through the door any day.

 

[pilotyip]

I'm sure your co-pilots don't as they are probably hoping you don't have the "big one" while en route. Give me a mexican cabby over some of the gummers i've seen squeezing through the door any day.

Are you saying the F/O's don't know how to fly if the CA has the big one?