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| Author: According to the FAA's Chief Council... Date: 5/18/2021 7:23:54 PM +2/-3 | ||
Seems someone is having real trouble understanding the term DUTY, and is severely misrepresenting things to their audience. For the purposes of Part 135, the FAA defines duty this way: "Although §135.267 does not contain an explicit duty time limitation, crewmember schedules must fulfill the rest requirements of§ 135.267(d). The FAA has consistently interpreted the term "duty" for purposes of§ 135.267 to mean actual work for an air carrier or present responsibility to work should the occasion arise. Legal Interpretation to Mr. David Bodlak from Donald P. Byrne, Chief Counsel, Regulations and Enforcement Division (Oct. 28, 1991)." Kleiner (2016) But, also note its statement that there is no limitation to duty under Part 135.267(d). You can be, and plan to be, on duty much longer than 14 hours. If you are not planning a Part 135 operation past the rest requirements, you are good to go. There is no requirement ANYWHERE that you must plan to END your duty day, withitn a 14 hour period. You do have to plan to complete the FLIGHT portion prior to 14 hours of duty, because Part 135 requires you show 10 hours of REST in the preceding 14 hours. That is not a requrement for Part 91 operations. So, you can PLAN to operate Part 91 at the completion of the Part 135 operations, where ever that may be. Nothing requires you to return to the "base" in your planning! Absolutely nothing. |
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