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Flight time limits

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flint4xx

Well-known member
Joined
Dec 6, 2001
Posts
374
Can you explain the logic here…

FAR 121 and 135 flight time limits the amount of flight hours one can fly while acting as crew. I understand this to be safety related concerns that prompted this regulation so that crews wouldn’t become too tired to fly, and thereby unsafe.

So explain why I can fly myself in my own airplane 3 hours to work and then fly for a 135 or 121 company and my PA28 hours don’t count against me? Or Joe fighter pilot can fly his 2 hour F-16 sortie and get in a 757 and fly 8 hours? I don’t want to hear about how the latter is of National Security interest, it is either safe to fly or it isn’t. You are either fatigued or you aren’t.

The regulation should be consistent. Either all flying is bad, or make it employer specific.
 
flint4xx said:
The regulation should be consistent. Either all flying is bad, or make it employer specific.

The regulation is very specific and quite consistent. It is limited to commercial flying, in which military flying is exempt.

Who do you know that flies an F16 for two hours and then goes to work as a 121/135 pilot in the same day?

If you want part 91 flying to count towards your flight time limits under 121/135, part 91 flying will not be allowed by 121/135 employers.
 
Man, this is one area of the regs that is messed up. It even goes as far for 135 companies that you can fly more than 8 or 10 hours depending on crew size. As always, it depends on the FAA inspector and they all have different answers. But our POI says that it is legal if we fly 2 hours to pick-up pax or freight, that it is not considered commercial flying. Then fly them somewhere 8 hours away, then turn around and fly 6 hours part 91 home. So 16 hours of flying 8 of which are commercial. Yes you would be over duty time, but the regs are not that specific and only require attentional rest if you go over.

Everytime we get a new POI, we ask for his take on the regs. Since he is the one that comes in and does the base inspections. Perhaps it also depends on how your company is set up and what it says you have to do in the manual. But we always get POIs that say no manifest required, then you are 91. If the trip cancels when you get there, then you are really charging a cancellation fee, right? He kind of leads us in the right direction I guess.

Be careful out there. Government BS at its finest.
 
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chperplt said:
The regulation is very specific and quite consistent. It is limited to commercial flying, in which military flying is exempt.

Who do you know that flies an F16 for two hours and then goes to work as a 121/135 pilot in the same day?

If you want part 91 flying to count towards your flight time limits under 121/135, part 91 flying will not be allowed by 121/135 employers.

Specific and consistent? I need to read your version of the regs. Explain what "commercial flying" is.

IF the limitation is for safety reasons, the what difference does it make on whose/what type of flying? An F16 pilot CAN if he wants to...or I could fly 20 hours across the country in a 172, and jump into a 747. But you can't for example fly 121 for 29 hours and go teach at the local flight school for 2 hours in one week.(receive compensation) That is inconsistent.

The spirit of the rule was for one company not to overwork its crews, yet it doesn't consider any other possibilites.

I already have a job, thanks.
 
flint4xx said:
Specific and consistent? I need to read your version of the regs. Explain what "commercial flying" is.

IF the limitation is for safety reasons, the what difference does it make on whose/what type of flying? An F16 pilot CAN if he wants to...or I could fly 20 hours across the country in a 172, and jump into a 747. But you can't for example fly 121 for 29 hours and go teach at the local flight school for 2 hours in one week.(receive compensation) That is inconsistent.

The spirit of the rule was for one company not to overwork its crews, yet it doesn't consider any other possibilites.

I already have a job, thanks.

The regulations are written with safety in mind. In that vein, they have a lot of room for improvement. They are not however inconsistent with their intent. It sounds to me like you want to go fly your 172 for 25 hours each work and then give your employer 5 hours.

The fact is, your company should have specific guidelines on what type of flying you can do outside of work and when you can do it. I think the definition of commercial flying is pretty basic and easy to understand.

If you feel the need to commute to work the day of your trip and are then fatigued, you need to blame yourself and not the regs. If you're fatigued, call in as such.

Sounds like you're an irresponsible person who is looking to big brother to protect you from yourself. Sure, you can fly 24 straight hours in your 172 and then hop into a 747, but what responsible person is going to do that?

The spirit of the regulation wasn't intended to keep people who have no business in front end of a commercial jet from being there. I think they assumed common sense was a given.
 
chperplt said:
If you feel the need to commute to work the day of your trip and are then fatigued, you need to blame yourself and not the regs. If you're fatigued, call in as such.

Sounds like you're an irresponsible person who is looking to big brother to protect you from yourself. Sure, you can fly 24 straight hours in your 172 and then hop into a 747, but what responsible person is going to do that?

The spirit of the regulation wasn't intended to keep people who have no business in front end of a commercial jet from being there. I think they assumed common sense was a given.

Dude, that is a little harsh don't you think? It was a good spirited question and all question about the regs bring up a lot of different views.

I do agree that the regs are inconsistant. Really, I think they are intended for the most part to keep you from killing other people. The feds probably don't care too much if you just come back from an 8 hour flight in 744 with 400 pax and then go jump in your Skyhawk and crash. They will just say that guy lacked good judgement. Then point out how there was a series of events that caused this crash. However, if you fly 4 hours to work and jump in a 744 and crash and kill 400+, then you will likely be the one who has prompted a change in the regs.
 
chperplt said:
The spirit of the regulation wasn't intended to keep people who have no business in front end of a commercial jet from being there. I think they assumed common sense was a given.

Huh? What exactly was it intended for, answer man?

Government regulations and common sense in the same quote. You crack me up.

You assume that some of the examples I mentioned actually apply to me, and then you slam me for it. ...Are you still beating your boyfriend?

Soooooo, somebody tell me why it is bad to fly 2 hours as a cfi/charter/airshow/medevac/eng/etc... before/after 29 hours 121 in the same week. Common sense (your words) says that is not a problem, but the regs say it isn't legal, but the same 2 hours in anything military or personal is OK. ...INCONSISTENT.

Who do you know that flies an F16 for two hours and then goes to work as a 121/135 pilot in the same day?
Apparently you don't know very many airline pilots.
 
flint4xx said:
Huh? What exactly was it intended for, answer man?

Government regulations and common sense in the same quote. You crack me up.

You assume that some of the examples I mentioned actually apply to me, and then you slam me for it. ...Are you still beating your boyfriend?

Soooooo, somebody tell me why it is bad to fly 2 hours as a cfi/charter/airshow/medevac/eng/etc... before/after 29 hours 121 in the same week. Common sense (your words) says that is not a problem, but the regs say it isn't legal, but the same 2 hours in anything military or personal is OK. ...INCONSISTENT.


Apparently you don't know very many airline pilots.

If you want to bang your fists into your chest and fight something, at least take up a worthy cause.. If fatigue is really your concern, put up a stink about rest requirements. Your arguments on this topic don't hold water.

Nice gay comment by the way. I bet you had to watch Broke Back Mountain a few times before you could come up with that one!!
 
Learwannabe,

Clearly you don't understand the regulation...where to begin here?

First, the specific regulation under which one is working needs to be applied, as it determines how the 24 hour period in which commecial flying is contained, is calculated. Second, one needs to look at the time period during which other flying takes place, the nature of the other flying, and most importantly, the safety of the situation.

91.13 always applies.

You're talking too many generalities and your comments show too little understanding to specifically address any issue. Rather than carry on about things you apparently don't understand, why don't you get more specific, and see if your questions can be addressed?
 
I understand the regs completely! They are a vague and anybody who has been around aviation knows that if you ask 3 feds, you will get 3 different answers. Thus, we always ask our POI for clarification, which you will hardly ever get in written form. We know how to exploit every loop hole or at least make sure they don't exploit us.

As far as flight duty time stuff, I will go one step further. I was in ELP one day and happen to be talking to a guy that turned out to be with the ABQ FSDO (never seen feds in jeans before). As this subject came up he pretty much agreed with our and our POIs take on this. He did add, what you can legally do is not always what is safest and that of course you should use good judgement before accepting any flight assignment.

The regs can't make you safe. There is no training for common sense. Cover your butt and be safe.

Once again you have tried to get us off topic AVBUG. Perhaps keep your worthless rants and personal attacks to yourself.
 
Lear Wanna Be said:
I understand the regs completely! They are a vague and anybody who has been around aviation knows that if you ask 3 feds, you will get 3 different answers. Thus, we always ask our POI for clarification, which you will hardly ever get in written form. We know how to exploit every loop hole or at least make sure they don't exploit us.

As far as flight duty time stuff, I will go one step further. I was in ELP one day and happen to be talking to a guy that turned out to be with the ABQ FSDO (never seen feds in jeans before). As this subject came up he pretty much agreed with our and our POIs take on this. He did add, what you can legally do is not always what is safest and that of course you should use good judgement before accepting any flight assignment.

The regs can't make you safe. There is no training for common sense. Cover your butt and be safe.

Once again you have tried to get us off topic AVBUG. Perhaps keep your worthless rants and personal attacks to yourself.

at 7100 hours isn't it time to get that ATP?

loser
 
Lear Wanna Be said:
He did add, what you can legally do is not always what is safest and that of course you should use good judgement before accepting any flight assignment.

The regs can't make you safe. There is no training for common sense. Cover your butt and be safe.


Lear,

The statement made by this FED is completely accurate. Each reg is not designed as an all encompassing rule. When you put the different regs together, they do their best (not always spot on) to keep everyone safe.

You said it... There is no training for common sense. The FARs and company manuals can't account for stupidity. If you have a long haul flight ahead of you, one would think you would take it upon yourself to prepare your body for that flight. If you can't, you just complain that the rules suck and are hard to understand..
 
chperplt said:
Lear,

The statement made by this FED is completely accurate. Each reg is not designed as an all encompassing rule. When you put the different regs together, they do their best (not always spot on) to keep everyone safe.

You said it... There is no training for common sense. The FARs and company manuals can't account for stupidity. If you have a long haul flight ahead of you, one would think you would take it upon yourself to prepare your body for that flight. If you can't, you just complain that the rules suck and are hard to understand..

Just to be clear, I don't think I said that this was a good idea or advocated doing it. If so, that was not my intention. However, on the 135 side, once you get your 10 hours rest...there is no telling when the pager will go off. Turn down a couple trips after you have gone green and you will likely be looking at a pink slip or find yourself at the bottom of the roster.

SADSAK77...you have made that comment else where. Is your ATP what defines you? Sorry that your life is so sad if that is the case. For me, when it becomes necessary to get my ATP, then I will. Until then I am content with my ratings and licenses.
 
Wild guess. The regulation is less about flying too much than employers =forcing you= to fly too much. Take a look at 135.263 through 135.267. Notice that they talk in terms of "no certificate holder shall..."

FAA Legal opinions have not limited the sections to flying activity. According to a 1991 Opinion, the certificate holder can't assign a pilot to such things as maintenance, fueling, or even making a sales call.
 
A couple of things:


Flight time regulations shouldn't count personal recreational flying because that crosses a line and becomes dictating what you can and cannot do on your time off. You have an obligation to report for work adequately rested. How you accomplish that is your responsibility as a professional. Once the FAA begins telling you how you can spend your time away from the job, there's no logical end to the intrusion. Can't fly recreationally. OK, you can't drive for 3 hours in your car either, because that could make you fatigued. Can't go for that 5 mile run you enjoy every morning, because that migh make you fatigued. In the extreme, you'd have a monitor by your bed so that the FAA can verify that you're getting the FAA mandated amount of sleep. Do we want to start down that slope? I certainly don't. So, I think that regulating what and how much duties your employer(s) assign you is a very sensible point to draw the line in the "how far do we go in regulating fatigue" question.


Second, If your employer and POI are interpretating the regulations such that it would be legal fly a 2 hour positioning flight then an 8 hour revenue flight when limited to 8 hours of commercial flying, (or 2 and 10 when limited to 10 hours) then that POI is "interpreting" the regulations contrary to the intent of the regulations and existing official interpretations. Positioning *before* a revenue flight is counted in 135 and 121 flight time limits.

Positioning *after* the flight is not. Hey, I don't like a tail end repo any more than the next guy, but the reasoning is sound. A positioning flight *after* a revenue flight has no safety risks for the fare paying public (assuming adequate rest before further 135 flying, which is required by reg.) That is what the 135 regs (and 121 regs) are about; protecting the fare paying public. not protecting your own life or your employer's airplane. In the context of a tail end repo flight, you as a pilot are expected and priveliged to assess your own fatigue state and accept or reject the risks to yourself, and your employer is expected to make his own decisions about the risks to his own property. The 135 and 121 regulations are not about protecting individual pilots or business owners from risks to thier own lives or thier own property, so if you have concerns, you need to grow a pair and deal with it directly with your employer, rather than expecting a government agency to protect you. If you feel that you are in no condition to safely do any further flying, you need to refuse that flight. That's your responsibility and obligation as a pilot It may involve you having to quit. It $ucks. Life is like that sometimes. Along with the priveliges and freedoms we are given with a pilot certificate are responsibilities. This is one of them.
 
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