Response Time

[rajflyboy]

The company has decided to run most all of the owner trips as part 135 trips. Only on occasion will Netjets run an owner trip as a 91K trip.

Companies have the option of running Part 91K or 135. Most of Netjets new business is 135 stuff anyway. The Marquis Card program is 135.

The 135 and 91K rules are very similar now. Each has the 60% runway rule. It doesn't benefit the company to use 91K over 135.

 

[gunfyter]

Part 91 subpart K, Fractional operator rules.

Yes and I ask again. Do you really think the FEDS intend to have Part 135 COMMERCIAL flights to be Less Restrictive than part 91 PRIVATE FLIGHTS flights?

The FAR 91 K rules are recently written and the language simply more clear what REST is. In the coming rewrite of 135 they will be just as clear... Not being clear does not relieve one of the responsibility to obey their intent.

There is no refuge or relief by operating 135 vs 91K.

This is simply a demonstration for ALL who doubt what REST actually means.

135.273 says... "REST is when you are free from duty or the immediate obligation for duty. " I am not free from the responsibilty for duty while required to be on a pager.

 

[rajflyboy]

Gunfyter:

Its all up to the Company's POI. Exact words written in the FAR's don't mean that much until we have the POI's interpretation. Thats how the FAA works. The regs are very wordy and can be interpreted in different ways.

As far as 91K. The book is still out on that one. We will have to wait and see how the FAA interprets some of this stuff and see if they do change the 135 regs.

 

[Ace-of-the-Base]

Yes and I ask again. Do you really think the FEDS intend to have Part 135 COMMERCIAL flights to be Less Restrictive than part 91 PRIVATE FLIGHTS flights?

The FAR 91 K rules are recently written and the language simply more clear what REST is. In the coming rewrite of 135 they will be just as clear... Not being clear does not relieve one of the responsibility to obey their intent.

There is no refuge or relief by operating 135 vs 91K.

This is simply a demonstration for ALL who doubt what REST actually means.

135.273 says... "REST is when you are free from duty or the immediate obligation for duty. " I am not free from the responsibilty for duty while required to be on a pager.

I have always felt that part 91 SHOULD be more restrictive than 135. Just think for a moment who is flying in 91 vs. 135. Bill Gates...part 91. Fortune 100 execs...part 91. Guy who can only afford to rent a Lear once a year...part 135. Now don't get me wrong, being less rich should not mean your less entitled to a safe flight, however, why should the really, really rich, who buy their own Gulfstream be entitled to anything less in the safety department.



As for this whole 'pager' discussion, get with the times, no one wears a pager, they just have their cell phone with them at all times. Now what do you suggest, should a pilot be forced to turn off his cell and not get calls from his many girlfriends and admirers just so he can be 'off duty'? And what the heck does 'immediate obligation for duty' mean. I bet you can get several legal interpretations of that one.



Ace

 

[gunfyter]

Ace,

Caller ID. Its a beautiful thing.

You taking us off the point though. If someone really wants to know what the FAA considers being in Rest.. I pointed to the evidence in the FARs.

What some POI lets the operators he is charged with being inspector of get away with is something else.

Where I work the POI does not let the company get away with it on FAR 135 flights.... When the issue came up and a showdown resulted. It took letters to the FAA Chief Counsel's office convince the company and the POI what Rest is and is not.

So they decided to operate part 91. Well part 91 is going away for our operations starting in mid February. Endless time on a pager or in reserve will go away too.

 

[rajflyboy]

gunfyter:

You just answered the question >> Why you need a Union in Corporate Aviation

 

[Ace-of-the-Base]

gunfyter:

You just answered the question >> Why you need a Union in Corporate Aviation

I agree (somewhat) with you on this one. Although Unions can do a lot of damage, in most operations (91 and 135) there is noone protecting the pilots. The Aviation Director and Chief Pilot can do some of that, but they have their own jobs to protect and therefore have a conflict of interest. Unions don't care who they pi$$ off.

Ace

 

[Sunnfun]

Where I work the POI does not let the company get away with it on FAR 135 flights.... When the issue came up and a showdown resulted. It took letters to the FAA Chief Counsel's office convince the company and the POI what Rest is and is not.

Which companies do operate "by the book" though, i.e. observe time on the pager/cellphone as "on duty"? Does Netjets' 135 ops do that?

I fully concur btw with your interpretation of the regs. But as long as "the competition" isn't forced to obey by it, nobody will. You just need to many more pilots.

 

[gunfyter]

Yes Netjets does that and they know they have to.

On part 91 operations they have some limitations (14 hr duty day) due to union contract but there is endless reserve time still. 91 operations will no longer be available after mid February. And the rest rules of 135 and 91K will finally eliminate this problem.

 

[Sunnfun]

And the rest rules of 135 and 91K will finally eliminate this problem.

Any idea when revised 135 rest rules will go into effect? Do you have any "official" links where I can read more about it?