National Air Carrier Association

Clarifying questions relating to newly issued Part 117 rules January 31, 2012
1) 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

. – I f a airline has a home b ase 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. W hat if the home base is Anchorage but a crew member lives in Seattle and was on his day off? H e is acclimated to west coast time, so would the 0100

-0700 rest be based on LAX time or Anchorage? Are both these examples correct? 2) § 117.25(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. The provision states deadhead time may exceed the hours in Table B , but the crew member must be given a rest equal to the deadhead but not less than required rest. How is that rest calculated if there are multiple deadhead legs that include rest/sleep opportunities during the deadhead segments ? How is rest calculated that is needed after deadhead ing if there are multiple deadhead legs that include rest/sleep opportunities between the deadhead segments? Is there a defined rest period in order to separate deadhead segments? I s it correct to calculate that time from the end of the flight duty period until arrival at destination ? Is it correct to calculate only the flight time of each deadhead leg and not time between legs for the purposes of th e rest calculation ? 3) Acclimated means a condition in which a flightcrew member has been in a theater for 72 hours or has been given at least 36 consecutive hours free from duty. Wh en has a crew member arrived in a new theater (for purposes of being acclimated)? Wh en a crew member arrive s in new theater, does the acclimation time clock start upon arrival or when the rest period starts ? 4) § 117.17 Flight duty period: Augmented flightcrew **- (**  c) No certificate holder may assign and no flightcrew member may accept an assignment under this section unless during the flight duty period: (1) two consecutive hours in the second halfof the flight duty period are available for in

-flight rest for the pilot flying the aircraft

during landing. (2) Ninety consecutive minutes are available for in

-flight rest for the pilot performing monitoring duties during landing

.
a. Augmented crews could be 3 or 4 pilots and this is not taken into account

. Assume a 4

- pilot crew, with a 14 hour FDP; the first leg is 8.5 hours, then 4 hours ground time to off

- load and load troops and cargo, and a final leg of 1.5 hours ; under th e applicable wording , the flight could not be operate d if the pilot landing had 4 hours sleep on the first leg (first half of the FDP) but cannot meet the 2

- hour requirement because the last leg is only 1.5 hours. The aircraft would have to circle for 30 minutes so the landing pilot can have two available hours on the last leg. The rul e should address 4

- p ilot and 3

- pilot cockpits , specifically, instead of just augmented crews, in general, since the re are real practical differences. b. Under the same scenario , above , in a 3

- pilot augmented operation , if the crew member landing slept from hour 6 to hour 8.5 , this would provide 21⁄2 consecutive hours sleep , of which 11⁄2 were in the second half of the FDP and 1 hour was in the first portion of the FDP. Since the majority of the sleep occurred in the second

- half, would that be considered as meeting the intent of the rule? 5) § 117.19 Flight duty period extensions. ( a) For augmented and unaugmented operations, if unforeseen operational circumstances arise prior to takeoff: (1) The pilot in command and the certificate holder may extend the maximum flight duty period permitted in Tables B or C of this part up to 2 hours. (2) An extension in the flight duty period under paragraph (a)(1) of this section of more than 30 minutes may occur only once prior to receiving a rest period described in § 117.25(b). Assume a 3

- pilot crew with a FDP limit of 15 hours, where the first leg is 9.5 hours, then a 2 hour turn , followed by a 3 hour final leg, then a crew change , a 3 hour leg, a 2 hour turn , and a 9.5 hour leg. At the first turn , the 2 hour layover takes 4 hours due to late troops , which puts the crew members 1.5 hours over the FDP limit. The PIC and certificate holder concur and extend. But , crew members taking the next segment are also going to be impacted because they must wait the extra two hours due to the delay, which will place them over their FDP. Do the PIC and certificate holder still have th e option available to them to extend for the return trip? 6) § 117.25 Rest period

- (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 hour s of sleep opportunity.Is it correct to say t his reference to any reserve does not include “long

-call

reserve” because the rule spec ifically states “assignment” for duty and “long call reserve is not assigned? 7) § 117.25 Rest period

- (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. Unlike in (e) above the term “assignment” is not used. It appears, therefore , under (b) , it is necessary to provide 30 consecutive hours free from duty in any 168 consecutive period for “long call reserve” even though “long ca l l reserve” is not fatiguing

. This section needs a technical amendment. W hen non

-scheduled airlines build monthly bid line for flightcrews , the schedule is normally not known in a dvance. To accommodate day

-off requirements , an airline may build the schedule with the first four days off, then twelve days of reserve, six days off, the last eight days reserve. To schedule 30 hours of rest in this bid line is devastating and not the in tent of this section. As flights are scheduled following orders from customers , the airline converts the reserve days to the actual proposed customer flying , applying all the necessary rules. Crews are normally assigned to rest and may, then, start a trip once the schedule is known

. B uild ing a 30

- hour rest requirement into th e schedule before flights are known is counterproductive and does not promote any safety. A clarification is required to describe how the rule would be applied , practically, to non -scheduled operations , or a technical amendment is required to permit current schedul ing practices to continue. Reserve lines are , in reality, just place holders to show what crews are available on which days to allow the proper scheduling , once customers inform an airline of their requirements. It should be confirmed , further, that § 117.25 Rest period (b) is not applicable to l ong call reserve since l ong call reserve is not considered reserve and is not a call for duty . Long call reserve means that, prior to beginning the rest period required by § 117.25, the flightcrew member is notified by the certificate holder to report for a flight duty period following the completion of the rest period. 8) Table B to Part 117 delineates scheduled times of start (acclimated time )

. Consider crew B scheduled to start their flight at 11:30 am, with a scheduled FDP of 13.75 hours

. Crew A, on the previous leg , is delayed 45 minutes . W ill crew B be allowed to operate the original 13.75 hours , considering the 45 minute late departure time? 9) Now consider the s ame scenario as above , but , to prevent crew B sitting around at the terminal , crew schedul ing informs them about the delay via a passive text ,and crew B stays at the hotel , longer

. Has the flight tech nically been

rescheduled , resulting in a 13 FDP?