Original Message

"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)."

 

AMC pilots do work regularly assigned duty periods under 135.267(c) and not a "rolling 24 hour clock" under 135.267(b). An operation is either (b) or (c). AMC has somehow had this loophole of failing to designate in their GOM but it will be fixed soon as the FAA is stepping in to take a closer look. (Since their pilots work regularly assigned shifts, they operate under (c).)