**Clarifying Questions for CFR 1 17** 

**Definition Clarification:** Physiological night’

s r est means 10 hours of r

est that encompasses the hours of 0100 and 0700 at the flightcr ew member ’s home base, unless the individual has acclimated to a differ ent theater

. If the flightcr ew member has acclimated to a dif fer ent theater

, the r est 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 1 0 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 W est Coast, but is based in the East Coast. Is his “acclimated” time based on his place of residence, or his home base?

**Secti on 1**  **17.13 Flight duty period: Un**
**- augmented operations.**  Section 1 17.13(a) states: (a) Except as pr

ovided for in § 1 17.15, no certificate holder may assign and no flightcr ew member may accept an assignment for an unaugmented flight operation if the schedule d flight duty period will exceed the limits in T

able 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 i t changing the flight segments being scheduled, does removing flights do the same? 3) For section 1 17.13 and 1 17.17 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 p ilot 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? W ould this conflict with the definition put forth for “scheduled”?
**Section 1 17.15 Flight Duty Period: Split Duty**  CFR 1 17.15 sets forth the conditions necessary in order to take advantage of the flight duty reduction provided through the use of the "Split Duty" provisions. T wo of the provisions are as follows: “(c) The r est opportunity is scheduled befor e the beginning of the flight dutyperiod in which that r est opportunity is taken. (d) Th e r est opportunity that the flightcr ew member is actually pr ovided may not be less than the r

est 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 1 17.19 Flight Duty Period Extensions:** 
CFR 1 17.19 S tates: (2) An extension of the flight duty period under pa ragraph (b)(1) of this section of mor e than 30 minutes may occur only once prior to r eceiving a r

est period described in § 1 17.25(b). Paragraph (b)(2) after takeoff extensions, permits one FDP extension over 30 minutes prior to a crew receiving the weekly rest requirements in 1 17.25(b). What happens if a crew already has one 30+ minute extension but discovers after takeof f they will need to extend more than 30 minutes? W ould a diversion be required?

**Section 1 17.21 Reserve S**  **tatus:** CFR 1 17.21(b) states that (b) Befor e beginning any r

eserve or flight duty period a flightcr ew member must be given at least 30 consecutive hours fr

ee fr om all duty in any 168 consecutive hour period. Our operation allows preferences and prof fers to be submitted by the crew me mbers for the next day assignments. Wo uld this interfere with them checking/confirming their schedules or submitting preferences/prof

fers for trip assignments the next day . W e also call to confirm assignments the night prior . What implications would that have on our operation?

CFR 1 17.21(c) states:
“1 17.23.c.3 For an unaugmented operation, the total number of hours a flightcr ew member may spend in a flight duty period and a r eserve availability period may not exceed the lesser of the maximum applicable flight duty period in T able B of this part plus 4 hours, or 16 hours, as measur ed fr om the beginning of the r

eserve 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 d ay 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 1 17.25 Rest Period:** 
CFR 1 17.25(c) states: (c) If a flightcr

ew member operating in a new theater has r eceived 36 consecutive hours of r est, that flightcr ew member is acclimated and the rest period meets the r equir ements of paragraph (b) of this section. (d) If a flightcr

ew member travels mor

e than 60° longitude during a flight duty period or a series of flight duty periods that r

equir e him or her to be away fr om home base for mor

e than 168 consecutive hours, the flightcr

ew member must be given a minimum of 56 consecutive hours r est upon r eturn to home base. This r

est must encompass thr

ee 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
me mber 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 Ti me zone, does that mean that all further applications of CFR 1 17 will be based on the Pacific time zone until the crew member is reacclimated to t heir 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 1 17.

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 o rder for the 56 hours of rest upon return to home base.
CFR 1 17.25(e) states: e) No certificate holder may schedule and no flightcr ew member may accept an assignment for any
reserve or flight duty period unless the flightcr ew member is given a r

est period of at least 10 consecutive hours immediately befor

e beginning the r

eserve or flight duty period measur ed fr om the time the flightcr ew member is r

eleased fr om duty . The 10 hour r

est period must pr

ovide the flightcr

ew member with a minimum of 8 uninterrupte d 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 "m easured from the time th e 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 suf ficient. 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 1 17.25(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
me mbers rest is interrupt ed, but the others are not, how do we notify them of additional rest, or a new departure time due to additional legal rest? Wo uld that be applicable?

CFR 1 17.25(f) states: (f) If a flightcr

ew member determines that a r est period under paragraph (e) of thi s section will not pr ovide eight uninterrupted hours of sleep opportunity , the flightcr

ew member must notify the certificate holder . The flightcr

ew member cannot r

eport for the assigned flight duty period until he or she r eceives 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 uninte rrupted rest? The text in 1 17.25(b) & (e) and 1 17.25(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 1 17.25(g) states:

(g). If a flightcr

ew member engaged in d

eadhead transportation exceeds the applicable flight duty period in Ta ble B of this part, the flightcr ew member must be given a r est period equal to the length of the deadhead transportation but not less than the r equir ed r est in paragraph (e) of this sect ion befor e beginning a flight duty period.
CFR 1 17.25(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 Ta ble B only applies to FDPs, does this r egulation 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 p art of an FDP , it is dif ficult 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 fol lowing day , and the 2 deadhead segments arrive at 1430. A 10:00 FDPwas legal according to Table B, and the actual FDP was only 4:00 long, but the total duty was 1 1:00. Of the 1 1:00 of total duty , only 4:30 were spent in deadhead transportation. Does thi s 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 t ime to compensate because of deadhead transportation, or say the final leg of deadhead tr ansportation was 2 hours, would we add 2 hours to the rest time to compensate.

**Please send any correspondence regarding these questions to:** Christopher Te siny Am eri can Eagle Airlines Christopher .T

esiny@aa.com 4601 Highway 360, MD 866 Fort Wo rth, Te xas 76155