The Part 135 Pilot Rest and Duty Rules Aviation Rulemaking Committee (ARC) has submitted to the FAA a series of recommendations to overhaul current regulations.
Mandated through the 2018 FAA Reauthorization Act, the 20-member ARC was tasked with reviewing current rest and duty rules for Part 135 and related requirements of Part 121; identifying the effectiveness and/or deficiencies of those rules; developing recommendations for any necessary future rulemaking, including costs and benefits; and reporting on those findings.
“Our goal was to recommend updates to decades-old Part 135 rest and duty regulations to recognize the effects of circadian rhythm and cumulative duty time, among other variables, while considering the complexities of Part 135 on-demand operations,” Kent Jackson, Jetlaw managing partner and ARC chair, told NBAA.
Ashley Smith, NBAA’s representative on the ARC and Jet Logistics president, added that the current rules are too prescriptive and do not account for human factors science. Smith further stated that the ARC was mindful of the differences between Part 121 and 135.
As part of its evaluation in developing recommendations, the ARC leaned on fatigue science experts and conducted a series of risk-management exercises based on Part 135 scenarios, NBAA said, noting the panel considered factors such as numbers of legs to be flown, duty hours and time zones crossed, the impact of circadian rhythms, and duty day start time.
The ARC further took into account different types of existing operations, as well as future business models.
The FAA, which is reviewing the recommendations, will publish them in the Federal Register for comment. NBAA anticipates it may be years before the ARC recommendations are implemented into regulation.