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There is no 14 hour DUTY limit to 135.267(d)!





There is no 14 hour DUTY limit to 135.267(d)!  

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Author: None!   Date: 5/21/2021 8:39:29 AM  +0/-0   Show Orig. Msg (this window) Or  In New Window

"Do you have a duty day limit if you don't fly? of course. Without debate. So stop trying to mix the two incorrectly. Your duty period is based on your restraint from the certificate holder and when your rest period starts and ends. Any directive including admin, post flight, etc are directives and is considered part of your duty period by the FAA, so it has to be included in planning. You are so off it's crazy"

If a pilot doesn't fly, he has no duty limit on his duty. He ha no limit on his duty eve if he does fly. He has a REST requirement, not a DUTY requirement.

Your references to duty limitations are all for FAR 135.267(c). That regulation demands that a pilot must limit his duty day to take advantage of the increased allowance in FLIGHT TIME limitations (see Winton-Aviation Law Firm 2014).

There is no rigid 14-hour DUTY DAY schedule requirement under FAR 135.267(d), only under FAR 135.267(c). And virtually NO HAA operators (that I can find) uses FAR 135.267(d) to schedule its pilot's, as just about ALL of them, (including AMC if that's who you are talking about), schedules its pilot's with alternating day/night shift schedules over the course of a 4 week period. (see Moody-SevenBar 2017, and New 2013)


So, there is no magical exemption to the fictitious DUTY requirement you have created, since there is NO DUTY restrictions under FAR 135.267(d).

You are clearly trying to hammer a square peg into a round hole and keep breaking the hammer doing so!
 
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