Ed Bolen, president and CEO of the National Business Aviation Association (NBAA), recently sent a letter to the U.S. House of Representatives Transportation and Infrastructure Committee addressing FAA rest and duty requirements for Part 135 (charter) pilots. In particular, the letter addressed so-called “tail-end ferry legs,” flights flown at the end of a duty day that are currently filed as Part 91 (private) operations and not subject to stricter Part 135 rest requirements. Pilots could fly a rigorous schedule under Part 135, only to face a long ferry leg at the end of the day to reposition the aircraft for the next day’s schedule.
Bolen said, “Currently, an operator may assign, and a pilot may accept, a Part 91 flight at the conclusion of a Part 135 duty period that would have otherwise exceeded the allowable duty limits for Part 135 had the Part 91 flight been considered part of the Part 135 duty period.” Bolen called attention to the recommendations of the Part 135 Pilot Rest and Duty Aviation Rulemaking Committee (ARC) report presented to the FAA almost two years ago in July 2021. “Preventing and mitigating fatigue remains a universal area of concern,” he wrote.
Bolen also wrote about adding language to FAA recordkeeping requirements for charter operators, who are now only required to record flight time. NBAA asserts that “is insufficient for ensuring flight crews receive prospectively scheduled rest and inadequate as an oversight mechanism for the FAA to effectively monitor and enforce these requirements.”
“Eliminating tail-end ferry flights and enhancing recordkeeping requirements is a crucial step toward improving safety,” Bolen said.
