Warbelow's Air Ventures, Inc.

We are opposed to the proposed interpretation. This change would be dangerous if applied in Alaska. Nearly all of our scheduled flights operate into communities where there are no facilities at the airport. Many are multi stop flights, where there are opportunities for unplanned delays to occur during the normal course of events. Consider for example a flight from Kaltag to Nulato to Koyukuk to Galena to Fairbanks and return via the same routing. We fly this each day. The scheduled times allow for about one hour of duty time to remain a the end of the flight. If the pilot arrived in Nulato and because of earlier cummulative delays was going to be over duty time by even a few minutes, the proposed interpretation would require him to not depart Nulato. There are no facilities on the Nulato airport of any sort, and in fact no facilities to overnight passengers anywhere in Nulato, short of walking a couple of miles in to town and knocking on a residents door asking for shelter. For most of December 2010 in Interior Alaska the temperature never reached higher than 0 F. For more than a week the temperatures were in the -50F to -60 range in most of the villages we fly to. As you can imagine, these sort of temperatures can create delays, from snomachines that won't start delaying an agent meeting the airplane, to mechanical issues with the aircraft that delay the flight. The safety implications of a pilot not being able to depart for the final 20 minute leg of the flight, and instead spending 10 hours to "rest" while passengers wait in -40F temperatures with no shelter are obvious. If a pilot over flys their duty time, they are required to get 10 hours rest before the next flight. This might require the pilot to depart late the next day, an adequate penalty to prevent operators and pilots from abusing the privelage to complete flights out of duty time when unexpected delays occur. The proposed interpretaton decreases safety.