I would like to know from you collegues how your AOC Operator, comply with EU OPS sub-part Q.

I see a BIG PROBLEM for all of us and for all small EU operators due to new minimum rest requirement which is now clear estabilished to be a minimum of 12 hours when on the "home base".

It means that a crew "off duty" at 21:00 shall "start duty" again at 09:00 of the next morning and then depart not before 10:00 !!!

This rule requires a minimum of 3 complete crews for each airplane to allow the Operator to continue to work. (average now is from 1 to 2).

According market requests, customers usually needs to depart in the early morning (07:00) and arrive back at home after 20:00. This is the main air taxi activity and the main reason why they want to rent a plane.

This means that some aspect regarding our pilot style-life could be ruined from undesiderable practices such as : duty rostered on "1 day on- 1 day off " and / or several phone calls for duty when on day off.

Furthermore all of us employed abroad on the classic scheme "1 week on 1 week off" (or 14/14) will be required to relocate and live where the airplane is based.

The best solution for me is to ask ALL TOGHETER an approved specific regulation for Airtaxi Ops with SIMPLE and CLEAR rules based on our needs and experience.

Please give me your situation and opinion !

thanks in advance

FTLs have come to play with your sort of cowboy outfit! Proper rest ensures proper performance from you crews UNDERSTAND? If you want to put your customers safety under threat by being inadequately rested, then you deserve to loose your AOC.
Finish no argument, you are wrong so wind yer neck in and conform.

Hey Merlin,

Take a pill.....

I comply one hundred per cent with FTL's. I am happy to shut down the flight when we cannot comply with them. My company also insist on it. We are not cowboys.

BUT, If I have to take a flight home from my aircraft base once a week, I will end up more fatigued than by sitting in my 4/5 star hotel for 14 days at base and operating from there.

How does that help a PROFESSIONAL operation?

EU-OPS have been designed with one type of operation in mind. Not necessarily a professional operation whereby crews are rested in good hotels, complying 100% with FTL's and where the crews the crews are happy.

FTL's should be designed to maximize the safety of the paying customer, and there are cowboys out there who abuse crew, not only corporate but airline as well.

So, while Gigi will probably wind his neck in and conform, he should not receive your abuse when he asks or suggests that we group together to try to offer a better solution to FTL's than the one size fits all that EU-OPS offers.

So, try to be constructive and we can all benefit from it.

:ok:

Cheers
Fester

Hey Fester, that is just the response I was try to obtain, thank you. I have long been involved in the application of FTLs in air carrier and more importantly here, BIZAV operations. This involvement was not just in the EU zone, but global. I have been active in various BIZAV associations including NBAA & EBAA whereby I have tried to emphasise the situ.

I agree 99% with you, but sometimes the 'get the feck out of here' mind set can take over, is does happen you know that.

What I would like to see is a reasoned application of FTLs along the lines of CAP371, not bringing in any form of FAR influence, this is an AeroMedical/Human Factors application. I've been involved in this industry since the early 60s, so I've seen quite a few things.

Cheers :ok:

I have been active in various BIZAV associations including NBAA & EBAA whereby I have tried to emphasise the situ... I dont see you having much success with FAR91 operators.....

Is it fair to force the JAA operators to comply whilst still allowing non-JAA operators offer their services in Europe?

Mutt

FAR91 :ugh::ugh::ugh::ugh::ugh::ugh::ugh::ugh::ugh::ugh::{:{:{:{:{

Yes my brain still hurts, that's one of the reasons I walked away. Check my previous re the 30+ hrs duty and this by a 121 supplemental who did revert to 91 for ferry flts even after a live flt/flts.

We did get rid of one FL based LR35 operator who was offering Hire & Reward under an Air Ambulance banner. Based the acft in DTTA, we got him via UK CAA, Eurocontrol, DGCA TUN and the Feds in FRA. Also he was named and shamed @<hidden> NBAA Int'l Operators Conference & expelled from the NBAA. He was heavily fined by the Feds. He's still around though, but only in the Americas.

The Big Problem is the way the new EU-Ops is written and to whom.

Pre-this summer we were governed by local state rules and those were partly even more restrictive than the new EU-OPS are. But they were a lot more simpler.

Now, the rules written for the scheduled airline operation's use are applied to Business Aviation. This does not work.

If the customer wants to make an extra stop on the way home, max allowable duty times are suddenly reduced and we are left wondering what to do? Break the limits or continue with the "no more that 33% of the operations can not fall outside of these limits"- kind of deal... or cancel the rest of the trip.

I do agree with the first poster, that this is a very big problem for AOC operators.

Hopefully something is done and fast.

I do not break the duty time limits nor I have ever done it intentionally, but the new rules are making my life much more complicated than before.

Pt91.....Fly till you crash or the boss says go home.........:rolleyes::rolleyes:

IMO this is exactly why this kind of legislation was made. Get rid of the small ones. From day 1 JAROPS had this intend, and the ones that survived up to now are to be slashed with the new Q.
And to a great extend its their own fault: not willing to work together or to have a representation, nor to accept that certain standards have to be set forth AND operated to.
Then the Authorities: wtf do they not fine offenders once and shut them down when it is obvious that they deliberately break the rules time and again. Also I´d like to know why the authorities just rule and don´t ask themselves if their rules can fit to their "clientele".

The idea of JAROPS 1 wasn´t that bad, if we could have get a set for business aviation it would have been great.
I predict that the operators that showed gross neglegt for the rules we already have, will break them also in the future. And I predict that some smaller operators acting to the rules will be gone soon. Because they won´t work together.

I was DO when JAROPS 1 was introduced and stayed it for 5 years and was also DM for a total of 6 years.

I changed to coorperate a year ago, but the big brother is looking around the corner already...they want to legislate coorperate trafic also. And here is at least partly the same problem: they won´t work together.

As a single crew air taxi pilot, I have to say the FTLs are very much needed by the pilots. As you say, most customers want to depart at around 7am and arrive home at around 8pm. Thats a 13 hour day for the pilot and without the FTLs he would probably be sat around with the aircraft waiting all day, getting very borred and when it comes to flying home, having to somehow raise his mental awareness. Not really a problem when its a one off but for this to happen for several days (usually getting up before 5am and not getting home untill after 10pm assuming you do not live at the airport) and this very quickly becomes a dangerous situation. With the FTLs, to do this you would need to take a split duty, with down time at the destination to do whatever you like. Then when you do get home you would have to take at least 13 hours 45mins off duty (assuming TO at 0700 and landing at 2000) which prevents you from doing this two days running.
I dont see how this will effect small operators apart from them not being able to take advantage of the pilots and possibly having to hire another pilot or two.

dear collegue MerlinXX,

I am not a sort of cowboy.......believe me ! I am just a pilot who understand what could happen in the community. I am asking opinion on pprune from expert collegues wordwide.

I use as a reference the studies of the NASA and the Flight Safety Foundations Fatigue Countermisures Task force for business aviation.

Subpart Q is made for Airlines. Application of part Q in Bizav operations will be a nightmare for all of us ! This involves some aspect of the employment situation in EU.

I fully agree on the above FSF studies for the "8 hours sleep" concept that means 10 hours minimum rest regardless it is on homebase or outside base.......there is no difference for human body, it is just required to clear how far the hotel or the home is from the airport.

We can all "offer our neks" and conform the rule as you suggested to me ! We'll have 2 hours more of rest.... but I can demonstrate to you a lot of DANGEROUS practices that will be adopted to "legally" comply this regulation.

You are the expert I was looking for .....please TRY to plan a monthly duty roster for 2 crews employed on a bizav airplane !


Thanks

Aslak. The EBAA & sub orgs such as BBGA, GBAA, IBAA, FBAA etc are all working on this, if you're EU based and not a member of EBAA, I do strongly suggest you either join EBAA or one of the national associations. How else can one gain access to the desk based non aviation numpties in BRU?

Gigi. Yup how can I not agree, but as per my above, the only route we have is via the associations, and the methods of representation they have worked extremely hard to establish. Believe me, it haas taken over 20 years for our segment of the industry to gain this level of representation in the 'Shafters Paradise' (apologies a Brit expression) that is the BRU bureaucracy.

I just hope and wish this is sorted, but as with CAP371 back in the very early 70s, stuff has to be worked with, applied and then adapted, but I still believe CAP371 was the best document of type. I've worked in many regimes, and none can match 371, don't forget, with an AOC you are exactly the same as a airline, you're flying for hire & reward, thus you are in the same catagory. If you're private/Corp, well then a different situation applies. Talk to the folks in the Isle-of-Man.

Safe flying folks, I'm going to say no more, just hope that what I have said has made sense, if it hasn't, well put that down to a misspent youth playing with areoplanes and hostees!:ok::E

The difference between homebase and "on the road" is that at the homebase your rest time starts leaving the airport whereas "on the road" it starts when you reach the hotel. Homebase rest time is 10 hours plus 2 hours travel time which in many cases is actually less than what you might get "on the road", depending how far you live from the airport and how the traffic situation is.

And by the way, subpart q is in many countries amended by national regulations so it is just the smallest number of identical items, there are many many differences between eu nations in regards to FTL still.

This is where it is vital to get harmonisation along the lines of the strongest FTLs, and not the weakest.

Thought you can 'officially' do a 30 minute report....

On Fantasy island maybe!

Merlin, i do agree with you. And from what i know CAP371 is or was actually one of the best out there, at least in europe.

Sadly i never operated according to it but rather german FTLs which were quite a bit worse than CAP371 and in some cases a lot worse than Subpart Q.

Denti, CAP371 in it's original form was taken onboard by NASA and various other research entities worldwide as the premier document which looked at fatigue in a valid scientific manner. Hence the title of 371 "The Avoidance of Fatigue in Air Crews". The title says it all me thinks. It is seen by very, very many as overly restrictive for crew scheduling purposes, but and this is the reason behind the document, it is not a FINANCIAL document, rather an AIR SAFETY document. If you've not seen it, you get it from Civil Aviation Authority Home Page (http://www.caa.co.uk) and search for cap 371, it's there for all to see. Downloadedable in pdf.

Safe flying:ok: