Part 135 Rest Requirements May Have New Recommendations  

Safety Management Systems

Rest requirements for Part 135 pilots may change 

We had just shut down after a long day of doing battle with Florida thunderstorms and demanding Part 135 passengers. Ice cold beer was on our minds as we closed the jet’s door and headed inside. We had the evening all planned out: a nice dinner, a couple of drinks, and then hours and hours of uninterrupted sleep before we headed home empty in the morning. Our spirits were high, then the phone rang.  

The boss needed us to reposition immediately for a 5AM departure the next day. It turns out he was able to find a paying passenger for our flight home. I’m sure the FBO employees could visibly see our physical reaction to the news. Our shoulders slumped, and we exhaled loudly; we were totally defeated as we turned to head back out to the plane to order fuel, file a new flight plan, and fire up and prep the aircraft for yet another leg on an already long and tiresome day.  

The life of an on-demand Part 135 pilot is unpredictable, challenging, and exhausting. But that might change; at least, we are hoping it does. The Part 135 Pilot Rest and Duty Rules Aviation Rulemaking Committee (ARC) submitted a series of recommendations to the FAA. ARC is looking to overhaul current regulations, and, in my opinion, it can’t happen soon enough.   

I didn’t even know there was such a committee, but its 20 members have been tasked with reviewing current rest and duty rules for Part 135 (and related regulations for Part 121 pilots). First, they look at the current regulations and see how effective (or ineffective) they are. Then, if they believe changes are needed, they can make recommendations, which is happening now.   

The problem with rest requirements is the age of the current rules and regulations. They have been around for decades and simply no longer make sense with modern flying. The committee is working on recognizing the effects of circadian rhythms and cumulative duty time, which were factors in my example above.  

The science of fatigue and safety has progressed enough to warrant a change in the rules for pilot rest. To make these changes, the ARC brought in fatigue experts and conducted a series of risk-management exercises based on Part 135 scenarios, considering factors such as:  

  • Number of legs to be flown  
  • Duty hours  
  • Time zones crossed   
  • Impact of circadian rhythms  
  • Duty day start time  

The committee then looked at how companies are currently operating and discussed other possible future business models. Their recommendations are now in the hands of the FAA, which will review the findings and publish them in the Federal Register for comments.   

It may be years before any changes are officially made to the Part 135 rest requirements, but it gives me hope that they are at least looking at it. On-demand charter is a challenging way to make a living, but it doesn’t have to be. Just give us adequate time to recuperate, and we’ll be ready to get back at it well-rested and safe for another day. 

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