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The horse isnít dead!

The horse isnít dead!  

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Author: Keep kicking!   Date: 4/10/2019 4:09:52 PM  +7/-5  

In regards to the 14 hour duty day, and I will preface by saying that I don’t work for AMC, or any other vendor/community based program. I fly for a hospital that holds their own Air Carrier Certificate.

As long as our Air Carrier Certificate (yes, the actual certificate itself) authorizes us to conduct training flights, ferry flights, and maintenance flights under FAR Part 91, I can end my Part 135 duty day at any time and still conduct those flights under part 91. My uninterrupted rest does not begin until I walk out the door, but I can end my 135 duty time by landing at a receiving hospital at 13:59:59 into my duty day and drop off the med crew, ferry the aircraft back to my base, and have the oncoming pilot pick them up. I can come back on duty after 10 hours of rest. The same way you can drop a line crew off at the substation you picked them up at under the same time constraints, and return to your base, not carrying passengers or cargo for hire. My scheduled 135 duty day still did not exceed 14 hours, and in the 24 hours preceding the end of my scheduled 135 duty day, that same 10 hour rest period is sitting right there.

I saw below someone saying “Why would you ask this of your pilots?” if I was a business owner, why wouldn’t I? I see the need for setting some company guidelines, but if you’re not good to fly 15 or 45 minutes beyond 14, how can you say you were good at 13:45? If not, then why? Not getting enough rest in your off time? Drinking up until the 8 hour rule? Poor physical condition? Plans with the wife that you should have known better than committing to?

Until our Air Carrier Certificate is changed, there is a letter from our our POI or notice from the FAA specifically removing that authorization from our Air Carrier Certificate, or there is a change to our GOM (submitted by our DO and approved by our POI), or the DO or CP say “let’s not do that” that is how we will continue to operate. 

We are employees in a business, not members in a flying club. Just because I’m a Pilot, acting as PIC doesn’t absolve me of having a work ethic. Hell I like getting the overtime. 

By all means, if you’re fatigued, don’t take chances, turn down the flight. But are you, and if so, why? Unless you’re at a program that goes non-stop, or your base conditions are poor, what is the reason? Are you really any more fatigued than getting woke up at 0130 on your third night shift in a row?

Before any of the usual accusations get posted, almost 30 years flying, almost half of that in HAA and several years as a CP (no longer, F that). Before that fire/USFS contract, ENG, tours, CFII, etc. 

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The horse isnít dead! +7/-5 Keep kicking! 4/10/2019 4:09:52 PM