AN FAR PART 135 LTT PLT COMPLAINS ABOUT FATIGUE AND THE RESERVE SYS IN GENERAL.

Narrative

I AM A PLT FOR XXX AIRLINES. WHEN I SERVE AS A 'RESERVE' OR 'STANDBY' PLT; MY DUTY PERIOD IS 24 HRS; 6 DAYS. IF I DO NOT HAVE A FLT ASSIGNMENT; MY MGMNT STATES THAT I AM ON A REST PERIOD. I CAN BE CALLED ON AT ANY TIME DURING MY RESERVE OR STANDBY STATUS; AND MUST RESPOND FOR FLT DUTY IN A TIMELY MANNER; USUALLY WITHIN 2 HRS. NO REST PERIOD EXISTS. FARS PROVIDE OUTLINES FOR REST AND FLT TIME LIMITATIONS. ALTHOUGH FLT TIME LIMITATIONS ARE ADHERED TO; THE SAME CANNOT BE SAID FOR REST PERIODS. THE FAA'S CONSISTENT INTERPRETATION OF RESERVE OR STANDBY FALLS WITHIN THE DEFINITION OF DUTY; IN THE CONTEXT OF REST PERIOD REGS. THE FAA HAS DEFINED DUTY AS: 'EITHER ACTUAL WORK FOR AN ACR OR PRESENT RESPONSIBILITY FOR WORK SHOULD THE OCCASION ARISE.' UNDER THIS INTERPRETATION; NO TIME DURING WHICH A PLT IS ON RESERVE OR STANDBY DUTY COULD BE CONSIDERED 'REST.' ADDITIONALLY; AN ASSOCIATE FAA ADMINISTRATOR AND LEGAL COUNSEL ARE AWARE OF THOSE VIOLATIONS EXISTING; BUT HAVE ELECTED NOT TO TAKE ACTION; ONLY TO SURVEY AND EVALUATE THE SIT. FLT MGRS WORKING FOR MY CARRIER ARE AWARE OF THE RULES AND PRESENT INTERPRETATIONS REGARDING REST PERIODS. THEY ARE ALSO AWARE THAT THE FAA IS TAKING NO ACTION. THESE MGRS ARE PROMOTING THE VIOLATIONS OF THE FARS. USUALLY; A RESERVE OR STANDBY STATUS IS AN ASSIGNED PERIOD OF FROM 2 TO 6 CONSECUTIVE DAYS. NORMAL FATIGUE AND STRESS INDUCED FATIGUE DUE TO THIS TYPE OF ASSIGNMENT IS UNSAFE. THE THREAT OF JOB SECURITY AND LOSS OF PAY IS MGMNT'S MOTIVATER. MY JOB IS IN JEOPARDY IF I ELECT NOT TO FLY WHEN FATIGUED AS A RESERVE OR STANDBY PLT. THE PUBLIC'S SAFETY IS BEING IGNORED BY MY CARRIER'S MGRS AND THE FAA. THE BURDEN TO PRESERVE SAFETY RESTS TOTALLY ON ME ALONE. 'HELP.' I WAS NOTIFIED AT XD30 FOR A RPT AT XF51 HRS. REMAIN OVER NIGHT AT TYS. ARR AT XW05; DEP AT XG48. WHAT HAPPENED TO 10 HRS MINIMUM EXCEPT FOR WX?