submission - Independent Pilots Association

1635 Prrnce Streel Alexandrra Vrrqrnta 22314-2818
January 14, 1999
Dr. H. Clayton Foushee
Vice President-Regulatory Affairs
Northwest Airlines
901 l5'Street. NW. Suite 310
Washineton. DC 20005
Re: ARAC Flighr Crev' Reserve Time Working Group:
HAI Proposalfor a Rule Applicable to Pan 135 On-Demand Air Charter
Dear Clay:
]ri:chm¡f ?
Telephone. (703 I 6E3-4646 Fax (703) 683-4745
On August 5. 1998. F.\A invited Helicopter Association lnternational (HAI) to serve on a working group of the
Aviation Rulemaking Advisory Committee (ARAC) to consider flight crew resen'e time requiremenrs. H,\I
herewith tenders its proposal for the structure and content of a Flight Crew Reserve Time regulation applicable
to on-demand air chaner operations conducted under 14 CFR Part 135.
HAI's proposal reflects many hours of thou-eht. discussion and negotiation focused on optimizing flight safery.
flight crew lifesty'le concerns and operational flexibility in the context of the unique demands of Part 135 air
charter operations. .\s y'ou k¡ow'. HAI fulll supports the proposal for scheduled domestic operarions conducted
under l-l CFR Part lll described elsewhere in your repon. FIAI believes that proposal is an appropriare
balancingofconcernsinPartl2ldomesticscheduledaircarrieroperations. Hou'ever.HAlalsobelievesrhar
the proposed Pan Ill solution will not work in the Part 135 context. in particular because the advance norice
provlsions of the Pan l2l proposal are inconsistent with the ondemand nature of part 135 air charter
operatlons.
HAI also suppons ¡he substance of the "Special Provisions for Air Ambulance Operations" proposed by the
National Air Transponarion Association (NATA) and National Business Aviaúon Association (NBAA).
However. we beliere that the approach outlined there is appropriate for allpan 135 on-dèmand air charter
oPeratlons.
Finally. HAI thanks;-ou and Dr. Don Hudson for your very capable, even-handed. and very patient leadership
of the Working Group. Your efforts as co-chairs have been greatly appreciated.
Sincerely,l
President
Oe'7,cated to the advancement of lhe ctvtl heltc-^cler tnd-slry