New 135 Duty and Rest Requirements

[LJDRVR]

BTW LJDRVR that lost charter revenue is how pilots loose their jobs, when income is reduced, expenses have to be reduced.

Hey pilotyip,

I think you took me out of context, sir. What I said in effect was that some operators tend to ignore the parts of the regulations that adherence to costs them money. Most 135 pilots willingly allow this, and the feds for some reason provide almost no enforcement action or oversight unless there's an accident or it becomes politically correct to make an example out of a specific operator.

Some examples?

• "Good-till/good again" duty time violations under 135.267

• Routine look-back violations on rest

• Pencil-whipping training requirements to avoid the hassle/expense of things like HAZMAT, survival and recurrent INDOC.

In the year 2005, well over half of the 135 operators I come into contact with do not have initial or recurrent CRM training. I'm not talking single pilot Seneca folks either. Large flight departments operating everything up to large cabin international jets. Disgraceful.

Surely you're not saying that we should turn our cheek to any sort of procedural and regulatory adherence just so we can retain employment?
There are a lot of operators out there that abuse their employees, flaunt the rules completely, and abuse the trust of their customers. Those operations should be made to do it right. If they can't afford to business like that, then they shouldn't be in business.

Hope the Michigan winter is treating you well,

Cheers!

 

[TransMach]

New FAR 135 Flight/Rest Rules

Guys,

Before anyone gets their jockeys in a bunch, please keep in mind that the "Draft" posted on the AAMS website is the product of an industry/FAA working group making recommendations to an industry/FAA Operations Committee who, in turn, makes recommendations to an industry/FAA Steering Committee who, in turn, makes recommendations to FAA. FAA then determines what "they" want the rule to say and forwards that to their legal folks to see if some "rule language" can be developed that meets each of their needs.

Then, FAA includes that new "proposed" rule in a "Notice of Proposed Rule Making" (NPRM) to which industry, god, country and anyone else who has an interest gets to respond on the docket and the politicos get into the chain reaction.

Now, since the FAA is trying to re-write ALL of Part 135 and has to go through this mine field over every part of it, it's gonna take quite some time.

Remember, FAA tried to change the Flight Time Limits and Rest Requirements for 121 and 135 back in 1995 and got their ship shot out from under them by industry, the politicians and the unions.

While I hope to see a more clearly defined set of rules that everyone can work in and live with ... I'm not holding my breath.

TransMach

 

[Quebec]

LJDRVR good response

LJDRVR,
Your response is excellent and I am taking off my kimono a bit to admit it, since most of our good / excellent clients (at www.rsvpair.com) are Part 135 operators who moan under the strain / oversight of arbitrary FSDO enforcement.

But let's face the facts and disseminate what you say, which is that for the most part the industry is a joke when compared to "real industries." Low utilization (hurts us economically) and low adherence to standards only adds flames to the media's already warped perception of what air taxi means.

The fact is that any company that cannot afford to run their company professionally (by the so called rules that are designed for the good of all concerned) should get out asap, be turned in, or simply face the music that change is painful, but for the better.

While no Southwest Airlines exists in our industry yet, it is important to recognize what a company like that does. #1 Fly their planes a lot, #2 impeccable adherence to "culture of safety" and #3 Make money - rare combo in any flying world.

Off soapbox for now. But this rant was inspired by a carrier who contacted us since they want us to starta "whistle blowers" page for 134.5 operators and other general horse poo that the 135 industry simply doesn't need.

 

[CherryBomb]

I'd sure like to see these new rules go into effect. At my old pt135 company we only had one fatality. It was mostly due to pilot fatigue. He was getting the old, "sleep durring the day for a few days, now sleep at night for a few days". I dont know about you guys but that type of "flip-flopping" is hell on my body clock...

 

[atpcliff]

Hi!

TransMach:
Here's the latest as I understand it:

The committee that was to submit their reccomended rule changes to the FAA has already been formed, met, submitted their changes to the FAA, and they were disbanded back in Jun/Jul of last year (that was the end of their 2 year period to delete -125 and rewrite -135). They already had the NPRM and took public comments twice during that period.

So, as far as I know (and I don't know the rule changing procedures very well at all), the FAA has the completed proposed rule changes.

Now what is the timeline?

I've searched the faa.gov site a bunch of times, and haven't seen anything on this for almost 1 year.

Cliff
ABY

 

[TransMach]

New Part 135

ATPCliff,

Right you are ... but the FAA doesn't have a time line.

The entire process included an indepth review of all of Part 135 and a complete re-write. The Flight Time Limits and Rest Requirements are one of the "Stickyest Wickets" in the lot. Some of the FAA folks that I delt with simply said "it'll never change ... to much political pressure to keep things as they are" ... the FAA folks in charge of the process told us which portions of the rule "HAD TO CHANGE" ... so you go figure.

I've not seen the NPRM yet, so it's still quite a ways away, my bet.

I've changed jobs since the operating committee met last so I may not always have the latest word.

It does need to change, however.

TransMach