Clarifying Questions for CFR 117

Definition Clarification:

Physiological night’s rest means 10 hours of rest that encompasses the hours of 0100 and 0700 at the 

flightcrew member’s home base, unless the individual has acclimated to a different theater. If the 

flightcrew member has acclimated to a different theater, the rest must encompass the hours of 0100 and 

0700 at the acclimated location.

If a home base is in Anchorage, and a crewmember is flown to Los Angeles from Anchorage, the 

airline must provide 10 hours rest before a flight that includes the 0100 to 0700 time period, based on 

Anchorage time. What if the home base is Anchorage but a crew member lives in Seattle and was on his 

day off? He is acclimated to west coast time, so would the 0100-0700 rest be based on LAX time or 

Anchorage? Are both these examples correct? 

What if there is a case in which a pilot who lives in the West Coast, but is based in the East Coast. Is 

his “acclimated” time based on his place of residence, or his home base?

Section 117.13 Flight duty period: Un-augmented operations. 

Section 117.13(a) states:

(a) Except as provided for in § 117.15, no certificate holder may assign and no flightcrew member 

may accept an assignment for an unaugmented flight operation if the scheduled flight duty period will 

exceed the limits in Table B of this part.

1) Table B bases the length of a Flight Duty Period (FDP) on the number of segments, if a diversion 

occurs in a non-augmented flight does this now count as a segment towards limitations, thereby possibly 

changing a flightcrew member’s maximum FDP? 

2) If a flightcrew member is scheduled for 3 flights, but after the FDP starts two flights are cancelled, 

do we recalculate duty times? If we add flying we would recalculate FDP limits due to it changing the 

flight segments being scheduled, does removing flights do the same?

3) For section 117.13 and 117.17 duty limits, if a delay is known prior to the report time of the pilot 

(day before or even earlier in the day), can the carrier notify the pilot of the new report time which alters 

the pilot’s duty day to begin at this new time within the chart. For example, the flight was originally 

scheduled to depart LAX at 12:30 pm. The flight is delayed for 5 hours and the crew is notified the day 

prior. Can the carrier reset the duty day to begin at 17:30 the next day? Would this conflict with the 

definition put forth for “scheduled”?

Section 117.15 Flight Duty Period: Split Duty

CFR 117.15 sets forth the conditions necessary in order to take advantage of the flight duty reduction 

provided through the use of the "Split Duty" provisions. Two of the provisions are as follows:

“(c) The rest opportunity is scheduled before the beginning of the flight duty
period in which that rest opportunity is taken.

(d) The rest opportunity that the flightcrew member is actually provided may

not be less than the rest opportunity that was scheduled.”

These provisions seem to incentivize the designation of a "rest" period within the split duty to insure 

schedule reliability. Are certificate holders free to designate which period of time spent on the ground are 

specifically designated as the "rest opportunity?"

Section 117.19 Flight Duty Period Extensions:

CFR 117.19 States:

(2) An extension of the flight duty period under paragraph (b)(1) of this section of more than 30 

minutes may occur only once prior to receiving a rest period described in § 117.25(b).

Paragraph (b)(2) after takeoff extensions, permits one FDP extension over 30 minutes prior to a crew 

receiving the weekly rest requirements in 117.25(b). What happens if a crew already has one 30+ minute 

extension but discovers after takeoff they will need to extend more than 30 minutes? Would a diversion be 

required?

Section 117.21 Reserve Status:

CFR 117.21(b) states that

(b) Before beginning any reserve or flight duty period a flightcrew member must be given at least 30 

consecutive hours free from all duty in any 168 consecutive hour period.

Our operation allows preferences and proffers to be submitted by the crew members for the next day 

assignments. Would this interfere with them checking/confirming their schedules or submitting 

preferences/proffers for trip assignments the next day. We also call to confirm assignments the night 

prior. What implications would that have on our operation?

CFR 117.21(c) states:

“117.23.c.3 For an unaugmented operation, the total number of hours a flightcrew member may 

spend in a flight duty period and a reserve availability period may not exceed the lesser of the maximum 

applicable flight duty period in Table B of this part plus 4 hours, or 16 hours, as measured from the 

beginning of the reserve availability period.” 
Does this mean that a rap must always be associated with the crew member to allow up to 16 hours of 

duty for a reserve? Currently we do not assign a RAP to every day of a sequence, but assume that while 

on duty they are available to the company for reassignment and subject to the needs of the operation as a 

reserve. The reserve availability period is only on the first day. Or does this assume that all reserves can

be scheduled with 16 hours a day up to the cumulative limits.

Section 117.25 Rest Period:

CFR 117.25(c) states:

(c) If a flightcrew member operating in a new theater has received 36 consecutive hours of rest, that 

flightcrew member is acclimated and the rest period meets the requirements of paragraph (b) of this 

section. 

(d) If a flightcrew member travels more than 60° longitude during a flight duty period or a series of 

flight duty periods that require him or her to be away from home base for more than 168 consecutive 

hours, the flightcrew member must be given a minimum of 56 consecutive hours rest upon return to home 

base. This rest must encompass three physiological nights’ rest based on local time.

When has a crew member arrived in a new theater (for purposes of being acclimated)? When a crew 

member arrives in new theater, does the acclimation time clock start upon arrival or when the rest period 

starts?

This deals with flightcrew members being acclimatized in a new theater after 36 hours of rest in the 

new theater. If a flightcrew member based in the Eastern time zone has a 36 hour layover in the Pacific 

Time zone, does that mean that all further applications of CFR 117 will be based on the Pacific time zone 

until the crew member is reacclimated to their home base, or does "base" time still serve as the basis since 

the flightcrew member never went to another "theater" as defined in the definitions of CFR 117. 

We are assuming this provision has to do with 60 degrees of longitude in one direction, so that say 

going 30 degrees east of home base, then 30 degrees west of home base would not trigger this scenario? 

Only travelling either 60 degrees east, or 60 degrees west of home base would trigger this. Also in does 

(d) imply that both need to occur in order for the 56 hours of rest upon return to home base.

CFR 117.25(e) states:

e) No certificate holder may schedule and no flightcrew member may accept an assignment for any 

reserve or flight duty period unless the flightcrew member is given a rest period of at least 10 consecutive 

hours immediately before beginning the reserve or flight duty period measured from the time the 

flightcrew member is released from duty. The 10 hour rest period must provide the flightcrew member 

with a minimum of 8 uninterrupted hours of sleep opportunity. 
The regulation puts forth that a rest period is always considered to be the "10 consecutive hours 

immediately before beginning the reserve or flight duty period", but then states that the period is 

"measured from the time the flightcrew member is released from duty." The first part indicates that the 10 

hours is always the last 10 hours, indicating that a crewmember could not be called in to work earlier than 

planned without interrupting rest, while the second part indicates that rest is given immediately, indicating 

that a crewmember could be called in to work earlier if the layover time were sufficient. Which is it? 

Can certificate holders designate the rest period in these cases?

For example, a crewmember is scheduled to block in at 2200 local base time, and report the next day 

at 1400 giving a 16:00 layover. Actual block in is at 2215, and the certificate holder requests that the 

report actually occurs at 1300 leaving an actual layover of 14:15. Is such a change legal and appropriate 

under CFR 117.25(e)?

Do we still have the 1 phone call rule? Can the carrier require the pilot check his or her schedule, or 

calendar/email to confirm changes to assignments or changes to departure times during the 10 consecutive 

hours or 8 hours of sleep opportunity.

If something besides the company interrupts rest for the crew member/members such as a fire alarm 

at a hotel, would that be an interruption of rest that must be restarted for 8 hours. Also if one crew 

members rest is interrupted, but the others are not, how do we notify them of additional rest, or a new 

departure time due to additional legal rest? Would that be applicable?

CFR 117.25(f) states:

(f) If a flightcrew member determines that a rest period under paragraph (e) of this section will not 

provide eight uninterrupted hours of sleep opportunity, the flightcrew member must notify the certificate 

holder. The flightcrew member cannot report for the assigned flight duty period until he or she receives a 

rest period specified in paragraph (e) of this section. 

Does the flightcrew member have to call the carrier if a required rest period is interrupted or does the 

flightcrew member have discretion? 

Example: Carrier provides a flightcrew member 10 hour opportunity to sleep, which includes 8 hours 

without interruption, the flightcrew member checks into a hotel with 8:15 remaining in the rest period, a 

fire alarm and evacuation occurs for 1 hour before a FDP, must the pilot notify the carrier that he/she did 

not get 8 hours of uninterrupted rest? 

The text in 117.25(b) & (e) and 117.25(f) are inconsistent. Paragraphs (b) and (e) refer to “...any 

reserve or flight duty period...” but paragraph (f) states “The flightcrew member cannot report for the 

assigned duty period...” 

Is this inconsistent language intentional? Could a flightcrew member begin a reserve period even if 

the flightcrew member determined he/she did not receive the rest required by paragraph (e)? 
CFR 117.25(g) states:

(g). If a flightcrew member engaged in deadhead transportation exceeds the applicable flight duty 

period in Table B of this part, the flightcrew member must be given a rest period equal to the length of the 

deadhead transportation but not less than the required rest in paragraph (e) of this section before 

beginning a flight duty period. 

CFR 117.25(g) seems to extend the concept of "flight duty" to deadheading in a particular 

circumstance. What that circumstance is, however, is not entirely clear. Since Table B only applies to 

FDPs, does this regulation apply to non-flight duties after an FDP, or is it referring to duty periods that 

consist of only deadheads? Since deadhead after an FDP is not considered part of the FDP by definition, 

and duties consisting solely of deadhead would also not be part of an FDP, it is difficult to understand 

how to apply this regulation.

Example: A flightcrew member reports for duty at 0400 and operates a single segment that blocks in 

at 0800. At 1000 he begins deadhead transportation to another city to fly the following day, and the 2 

deadhead segments arrive at 1430. A 10:00 FDP was legal according to Table B, and the actual FDP was 

only 4:00 long, but the total duty was 11:00. Of the 11:00 of total duty, only 4:30 were spent in deadhead 

transportation. Does this rest matching deadhead transport time only apply if it is more than normal 10 

hour rest? Is this section meant to allow deadhead transportation to exceed FDP limits to allow 

positioning of crew, but only if given additional rest after the transportation is finished? Is this provision 

used for multiple dead head transportation sequences? Or is it meant for one leg deadhead transport that 

exceeds FDP’s limits? Since in this scenario we would be over FDP limits by 1 hour, would we add 1 

hour to the rest time to compensate because of deadhead transportation, or say the final leg of deadhead 

transportation was 2 hours, would we add 2 hours to the rest time to compensate. 

Please send any correspondence regarding these questions to:

Christopher Tesiny

American Eagle Airlines

Christopher.Tesiny@aa.com

4601 Highway 360, MD 866

Fort Worth, Texas 76155