Changing 135 duty day regs.

[Tackleberry]

A few weeks ago I posted somthing about the "FARs that pissed you off". I chose the 135 duty day reg.
I've never flown under part 135, but 703 (canada similar to 135) so for those of you who have, what are some of your suggestion for changing the duty times? Either more or less hours, rest period etc...

Many thanks

Tacks

 

[mar]

Good question.

But I'm too exhausted right now to give your question much more thought than this:

Right now, under 135, the pilot is subjected to a 14 hour duty day. My understanding is that when the FAA first implemented this rule it was with the understanding that companies would use "humane" scheduling techniques.

That is to say, a human pilot would go to work and work a normal day...about 8 hours. But if, as sometimes happens, the pilot runs into maintenance and/or weather delays then by having a permissable 14 hour duty day, then the pilot would be legal to just wait out the mx and/or wx and complete the day's flying without imposing on the company the cost of finding a new pilot(s).

Now...

...today, the 14 hour duty day is seen by airlines as a given. The companies, and who can blame them, will schedule to get the absolute most work out of the fewest pilots.

The FAA needs to realize (and they probably do, they just don't care because fatigue isn't as sexy an issue as security) that The Company will do whatever it is *allowed* to get away with.

And that's about all I can manage right now, but I'll give this some more thought and see what else I can come up with.

Good luck.

 

[Tackleberry]

Just to throw an idea out there, I was thinking along the lines of a 12 hour flight/duty limit. Extendable to 14 hours (unforseen wx, mx etc..), but with increased rest. 11 hours regular, up to 16 hours if you go to a 14 hour duty day.

Any little bit would help.

Thanks
Tacks.

 

[mar]

Not to put too fine a point on it

Firstly, you mentioned a 12 hour flight/duty limit. Maybe you realize it already, but they're not the same thing.

Right now it's a 14 hour max *duty* day and you are limited by either 8 hours of *flying* with one pilot or 10 hours of *flying* with two pilots within that same 14 hour day.

Now.

The other problem I've got with the FAA/FARs/Management is the use of Part 91 returns. That is to say, you're flying revenue freight/pax all day right up to your max allowed duty and flight times and then *whamo* they throw a Part 91 (empty) re-positioning flight at the end of your day and it's *totally* legal.

You still get paid, you still must comply with every FAR in the book and every paragraph in the GOM, you still must be a professional, but suddenly the entire concept of fatigue (and associated degradation of skill and judgement) is thrown out the window.

That is a real pisser in my book.

I like your idea of extended rest after a certain point.

But I've gotta ask this rhetorical question (admittedly this may extend beyond the scope of your paper): but, whatever happened to "One Level of Safety?"

Before Sept 11, the FAA had a pet project where they wanted to bring air taxis to the same level of safety as 121 airlines.

They wanted to eliminate the dichotomy between freight and passenger and then all of a sudden the WTC is destroyed and no one can carry tweezers anymore.

I guess what I'm suggesting is that rather than trying to reinvent the wheel you can take some guidence from the 121 *domestic* flight and duty times for an example of more realistic scheduling.

I don't want to overwhelm you, this subject is huge and complicated and been a sore spot with many pilots for a long time. It's pretty much what got the unions started.

Good Luck!!!

 

[learflyer]

It's funny this is brought up, because this is my largest pet peeve!! I don't understand why the FAA is so radical on some things and could care less about this issue. For ex. The age 60 rule, stupid route checks, ramp checks, etc. But it's ok to fly 5-7 legs per day 14 hrs per day with 10 hours of rest?

 

[mike1mc]

Do a search on Flight and Duty Regs. There are new 135 regs being proposed and there is a thread on here about it.

 

[atpcliff]

Hi!

Actually, according to some FSDOs, the 14 hour duty day can be extended indefinitely, due to "delays". Freight delay, ATC delay, maintenance delay, etc. lead to pilots having duty days of 25 hours and more. Flight duty times can also be extended beyond 10 hours, but ONLY in a 14 hour duty day. It's the only place the regs specificy a 14 hour duty day.

The new suggested changes to -135 will do a lot, including getting rid of the -91 tail end ferry.

Cliff
YIP

 

[pilotyip]

That new rule posted in another thread, was a rehash of Part subpart K, put into 135 form. There is nothing coming from the FAA yet. I checked with our POI after I saw that thread. Mar putting 135 crews on the present one level of safety like Part 121 crew rest would give management much more flexibility than 135 crew rest.