part 135 duty and travel
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Join Date: Aug 2019
Location: New Jersey
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part 135 duty and travel
OK, here's my story. I'm a part 135 pilot for an on demand operator. Recently my owner expanded ops to a second city, that is staffed by flying pilots in on as need basis. My boss will often fly a pilot in the home city for several hours and then use commercial airlines to transport to the second city for flights the following day. These commercial flights are scheduled by my operator, often exceed the 14 hour limit for duty and will result in 15 to 18 hours of work. 10 hours of rest is provided before resuming duties the next day. I guess the basic question is, does the travel from the primary city to the secondary city count as duty time? My boss claims that it is not( of course) and I tend to think it does count due to the "travel not local in nature" statement in the regs.
let me her your thoughts on the situation and any links to official documentation would be helpful.
let me her your thoughts on the situation and any links to official documentation would be helpful.
Way above my pay grade, but assuming you are not working on the travel legs, it is just like an airline pilot "dead-heading" or commuting to his next assignment---not on duty.
If you have to check on this stuff and it is an issue, maybe find another job.
If you have to check on this stuff and it is an issue, maybe find another job.
I'm not an expert by any means but it seems that if you are provided 10 consecutive hours of "rest" before your next duty cycle you are good by pt 135.
Travel time not local in nature does not extend your duty day, but may not be considered "rest". If ten hours of "rest" is provided after you arrive at the second city, it seems to me that there is no problem. If the ten hours of rest includes the commercial flight...you might want to run it by someone a lot smarter than me and not on the internet.
YMMV
Travel time not local in nature does not extend your duty day, but may not be considered "rest". If ten hours of "rest" is provided after you arrive at the second city, it seems to me that there is no problem. If the ten hours of rest includes the commercial flight...you might want to run it by someone a lot smarter than me and not on the internet.
YMMV
If your travel is in the front of the bus, lay the seat down and snooze for the duration.
But it sounds like this boss has put you back in the zoo with the rest of the travelling reptiles.
But it sounds like this boss has put you back in the zoo with the rest of the travelling reptiles.
Expanded ops to a second city is not local in character, so time spent in transportation, required by an operator of a flight crew member, to an airport at which he is to serve as a flight crew member on a flight is not considered part of the rest period. 135.263(c) is very clear on that. However, in the example given, duty on the second day is OK because the required rest period was served free of duty after arrival at the 2nd city. The question is, whether the duty clock keeps ticking on day one after completing flight assignments on that day and then being required to be transported to city 2 (not being the home station). The operative element seems to be about accepting flight time during the duty period, and whilst you're in transport to the 2nd city, obviously you can't accept flight time then. So, I'm inclined to go with the operators interpretation.
Last edited by gulliBell; 10th Aug 2019 at 23:17.
I would side with the Boss....you get your Ten Hours Rest.....accepted no Flight Duties (you are flying as a passenger with no duty imposed).
The only quiestion would be if there is a penalty (extended Rest Period due to the extended Duty Period) prior to the start of your next Duty period.
The key issue is the difference between "Duty Hours" and "Flight Duty".
Read your Part 135 very carefully....and consider every bit of the wording used in the Regulation.
The "nuance" in the language is key.
FAR 135.267 pertains but care must be taken to ensure which part of it covers your particular operation to include also considering what the OpSpecs for your particular operation have to say about the matter.
The only quiestion would be if there is a penalty (extended Rest Period due to the extended Duty Period) prior to the start of your next Duty period.
The key issue is the difference between "Duty Hours" and "Flight Duty".
Read your Part 135 very carefully....and consider every bit of the wording used in the Regulation.
The "nuance" in the language is key.
FAR 135.267 pertains but care must be taken to ensure which part of it covers your particular operation to include also considering what the OpSpecs for your particular operation have to say about the matter.
"Just a pilot"
Yes it is duty time for any 135 flying that follows.
The reg states that you must have had 10 hours uninterrupted rest within any 24 hours in which 135 flight are performed. But your day can be legally longer than that look-back 14 hours if further Part 91 or travel is required. Those are not inclused in the duty time limits. Your next Part 135 day's duty will start later so that tbe required 10 hours of rest can occur.
