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June 4, 2012 

14 CFR PART 117—FLIGHT AND DUTY LIMITATIONS AND REST REQUIREMENTS: 

FLIGHTCREW MEMBERS 

Final Rule – Clarifying Questions 

1. 117.3—Definitions. 

117.3 states that the “...FDP ends when the aircraft is parked after the last flight and there is no intention 

for further aircraft movement...” 

Question 1a: 

In the definition for flight duty period (FDP), does “further aircraft movement” mean movement for the 

purpose of flight? 

Example: The aircraft is parked at the gate following the last flight and the passengers deplane. If 

subsequent to this the pilot repositions the aircraft on the ground, such as to the hanger, does the FDP 

end when the aircraft is first parked at the gate and the passengers deplaned? 

Question 1b: 

Does a flight have to occur (takeoff and landing) in order for there to be a flight duty period? 

Example: If a pilot is on airport reserve and does not fly, is it correct to assume that none of the duty 

time is considered a FDP? 

Question 1c: 

The FDP limitations are partially based on the number of flight segments. Is a flight segment defined to 

mean a takeoff and landing? 

For example, if a flight returns to the gate and does not takeoff, then it is not considered a flight 

segment. 
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2. 117.5—Fitness for duty. 

A pilot reports fit for an FDP that includes 6 flight segments. After the fourth flight segment the pilot 

notifies the company that he will be too fatigued to fly the sixth flight segment, but will be fit to fly the 

fifth flight segment. 

Question 2a: 

As long as the pilot certifies that he is fit to fly the fifth flight segment in accordance with 14 CFR 

117.5(d), is the company in compliance with 14 CFR 117.5(c)? 

3. 117.15—Flight duty period: Split duty. 

117.15(a) states “The rest opportunity is provided between the hours of 22:00 and 05:00 local time.” 

In addition, please clarify whether the scheduled time of start in Table B refers to a pilot’s base or 

acclimated local time. 

Question 3a: 

Is this base/acclimated local time? 

Example 1 (Split Duty): A split flight duty period begins in the pilot’s base time zone (Pacific Time) and 

overnights at a location in the Mountain Time zone. Is the local time in 14 CFR117.15(a) referring to 

Pacific Local time? 

Example 2 (Table B): A pilot reports for duty at his base at 0500 PST for an 11.5 hour duty day with 5 

flight segments and overnights in a MST zone city. Can the pilot report the next morning at 0500 PST 

(0400 MST) for an 11.5 hour duty day and 5 flight segments? 

117.15 also 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. 
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Question 3b: 

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?" 

4. 117.21—Reserve status 

117.21(a) states: 

“Unless specifically designated as airport/standby or short-call reserve by the certificate holder, 

all reserve is considered long-call reserve.” 

117.21(c) goes on to further state that: 

 “For short call reserve, 

1) The reserve availability period may not exceed 14 hours. 

2) For a flightcrew member who has completed a reserve availability period, no certificate 

holder may schedule and no flightcrew member may accept an assignment of a reserve 

availability period unless the flightcrew member receives the required rest in §§ 117.25(e).” 

Question 4a: 

Does this disallow a short call reserve from being assigned RAP upon completion of a multi-day 

trip, even if he/she has remaining FDP allowable in accordance with Table B or must the pilot be 

released to rest? 

Question 4b: 

Using a similar scenario, a reserve pilot was assigned a 3 day trip. Day 3 he reported at 0700 and 

was scheduled to fly 1 leg bringing his FDP to 2:30. Upon completion of his 1 segment he 

arrives back in base and contacts the carrier at which time he is notified of 3 additional flight 

segments. The revised schedule does not exceed the limitations set forth in Table A, Table B, or 

any cumulative limitation. Is this allowable? 

Completion of RAP (117.21 (c) (2)) 

117.25(c) (2) states, “For a flightcrew member who has completed a reserve availability period, no 

certificate holder may schedule and no flightcrew member may accept an assignment of a reserve 

availability period unless the flightcrew member receives the required rest in §§ 117.25(e).” 
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Question 4c: 

A RAP is assigned from 0300 – 1700. Can an air carrier voluntarily terminate the RAP to provide the 

required rest in §§ 117.25(e) and assign the pilot to FDP immediately afterwards? 

For example, a pilot is given RAP of 0700 to 2100. At 0800 the air carrier contacts the pilot and notifies 

his RAP has ended and he is assigned 10 hours of rest. The air carrier then re-assigns a RAP beginning 

at 1800. Is this legal? 

5. 117.25—Rest period. 

117.25(b) states: 

(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. 

Question 5a: 

The "Before beginning" statement would indicate that a check for 30 hours off in a 168 hour period 

involves a look back during flight duty periods, but the word "any" could be taken to indicate that the 

check for 30 hours free from all duty involves a constant check, forwards and backwards, even during 

days off. Using the latter, broader definition, the following example would not be legal: 

A flightcrew member has a repetitive schedule that begins every Monday at 0500 and ends every Friday 

at 1700 without a 30 hour break between Monday and Friday. The flightcrew member has every 

Saturday and Sunday off. Assuming that the assignments themselves meet all of the other requirements 

of Part 117, is this schedule legal since a look forward from midnight on a Sunday, or backward from 

2259 on a Saturday night would not include a 30 consecutive hour break, even though the flightcrew 

member is in the middle of one? 

The real question is, does a check for 30 hours free from duty in any 168 consecutive hour period have 

to be performed during time free from all duty? 

Question 5b: 

117.25(c) 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 Part 117 will be based on the Pacific time zone 

until the crew member is re-acclimated 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 Part 117? 
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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. 

Question 5c: 

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 117.25(e)? 

Question 5d: 

Do previous regulatory interpretations regarding a “one phone call” provision extend to rest periods 

defined in 14 CFR 117.24? 

Example 1: 

A pilot is on a 10 hour rest period in accordance with 117.24(e) that starts at 2200 hours and extends to 

0800 hours. The pilot begins the rest period at 2200 and has the opportunity to be behind closed doors at 

2300. Prior to the pilot’s 0800 scheduled report time it is learned that the morning flight will be delayed 

by 2 hours. 

Prior to reporting for the FDP can the company make one attempt to contact the pilot during the rest 

period to reschedule their report time to 1000? 

If one phone call is permitted is there a restriction on what time the phone call can be made? 
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Example 2: 

A pilot is on a 14 hour scheduled rest period from 2000 to 1000 that qualifies to be a 10 hour rest period. 

The pilot begins the rest period at 2000 and has the opportunity to be behind closed doors at 2100 

Can the company make one attempt to reschedule the report time to 0600? 

If one phone call is permitted is there a restriction on what time the phone call can be made? 

Question 5e: 

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. 

An example may be helpful: 

A flightcrew member reports for duty at 0430 and operates a single flight that blocks in at 0800. At 

1100 he starts to deadhead to another city to fly the next day, and the series of deadhead flights arrive at 

1530. Table B states that a 10:00 FDP was legal and appropriate and the actual FDP was only 3:30 long, 

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

transportation. How much rest does the flightcrew member need? If the entire assignment consisted of 

deadhead, how much rest would the flightcrew member need? 

Question 5f: 

How is table B used when applying it to a flightcrew member on short call reserve? Is the table plus the 

reserve extension based on the time that the Flight Duty Period begins, or the time that the short call 

reserve period begins? 

6. 117.27— Consecutive nighttime operations. 

Question 6a: 

Can a pilot be schedule for more than 3 consecutive FDPs or Airport Reserve periods that begin at 0530 

and end at 1530? 
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Please send any correspondence regarding these questions to: 

Stacey Bechdolt, Esq. 

Director, Safety & Technical Affairs 

Regional Airline Association 

2025 M Street, NW 

Suite 800 

Washington, DC 20036 

202-367-1252