Date: 201409
Local time of day: 0601-1200
Location: ZZZ.Airport, US
Flight conditions: VMC
Light: Dawn
Aircraft: Cessna Stationair/Turbo Stationair 6
Operator: Corporate
Operating under: Part 91
Flight plan: None
Mission: Photo Shoot / Video
Flight phase: Cruise
Airspace: Class B ZZZ
ATC / advisory: Center ZZZ
Reporter organization: Corporate
Reporter function: Pilot Flying; Single Pilot
Reporter qualification: Flight Crew Flight Instructor; Flight Crew Instrument; Flight Crew Multiengine; Flight Crew Commercial
Human factors: Fatigue
Anomaly: No Specific Anomaly Occurred All Types
Detector: Person Flight Crew
When detected: In-flight; Pre-flight
Result: General None Reported / Taken
Contributing factors: Company Policy; Human Factors
Primary problem: Ambiguous

Narrative: This report does not depict a specific; single event; but rather a set of conditions that I think need to be considered sooner or later. I was hired by an Aerial Survey company as a pilot. I have 1000 hours of previous experience flying Aerial Survey; 1800 total time. I had training of three days of flight training; including an IPC and Flight Review; and I was asked the next day (day four of my employment) if I was willing to get underway and start flying 'the line.' I responded that I was indeed ready. I have flown every day now for four weeks; averaging about six to seven hours per day; including weekends and an intervening holiday. The airplane has undergone two rapid fire 50 hour events; and one 100 hour event. The maintenance is not the issue on this plane; thankfully. At the conclusion of a 7.5 hour flight; part of a 14-hour day; I was told to be at work early the next morning; less than seven hours in the future. I live one hour away. Therefore; the 7 hour rest became 5 hours; including time to eat; shower; get ready; etc. I am already fatigued because I have flown for 27 days straight - every single day; as described. Upon waking up; I was still groggy; sleepy; and still very tired. Clearly this was a case of long-term and now short-term fatigue. I mentioned this to the individual I was working with and he pointed out that because we are a Part 91 Operator; that no rest requirements exist. And further; because I am the 'new guy' I would do better to keep to myself. I have enough time and experience now to know that this is excessive; and that I was operating at less than optimal due to lack of sleep and aggregate fatigue. I know that no time limits other than for flight instruction exist in Part 91; but as an Aerial Survey operator; I feel that this is an oversight on the part of the regulations. I understand that we don't need to add layer on layer of laws and rules; and in the spirit of the IM SAFE checklist; I failed said checklist; but when a company calls the shots; and makes the rules; and the written law doesn't provide protection regarding rest; then for continued employment; I should keep going - operating at less than optimal. I don't mind continuing to work hard for a company and 'paying my dues' as I work toward a better; higher paying job in either a part 135 or 121 company; but this particular day was an abuse of the lack of rules; and an abuse of an employment situation. The bosses aren't pilots and don't understand that concept of fatigue; and being tired while flying and how the effects of it are cumulative. And yet; from my FAA training; I do understand this and certainly my body can feel it. The notion of a 7-hour rest that includes two-hours of freeway driving; plus eating; time to shower and dress and get back in the game; even the CFR's cut that one kinda close. Further; there is no protection under the law that says that in every 7 days; a 24 hour 'golden day' needs to be interjected. I've flown for 28 straight days now; living in hotels; and for the most part; working hard to get enough rest and sleep because I want to keep doing this. But at the same time; this directive of the shortened rest period wasn't issued in the spirit of 'we will give him a day off in the next 24 hours to compensate for the reduced rest period.' The law doesn't call for it; and therefore; we don't enjoy the protection under the law. That said; we still operate in Class B airspace; on long days of hands-on flying; going into and out of airports across the country with big planes; and interacting with controllers; and other pilots and in effect; having just as much at stake if something goes wrong as any other operator. So I am writing this report to raise an issue that I am certain will come up again because there is no law that says it can't come up again; and further; the non-pilot bosses who call the shots get to crawl into their own beds at night and return to an office that sits on the ground where they can come and go from the coffee pot and not endanger anyone if they show signs of fatigue from having worked 28 days straight including weekends and holidays. The bosses are great; and do what they know; but unless it's in the law; there is nothing to assure us that we are operating safely. I am not upset at the bosses in an 'us and them' approach; rather; I want to point out that these guys are not pilots and may not understand all of the elements that we do (as I'm sure I don't understand all the elements of what they go through as well.) This is not the point. Gratefully; nothing untoward occurred and I somehow drove home on the Interstate at the end of another 7.5 hour flying day; with 4 hours of book work included; rolling down my window to keep awake and singing along with the radio; with nothing that says I don't have to do it again the next morning. I just hope this issue of rest for 91 operators starts to receive some attention before someone gets hurt seriously; or killed.




Synopsis: C206 pilot laments the lack of flight time or duty time regulations for Part 91 commercial pilots and offers his recent experience as an example.