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. –

If a airline has a home base 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?

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 deadheading 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? Is 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 the 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.

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?

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 half 
of 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 the applicable wording, the flight could not be operated

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 rule should address 4-

pilot and 3-pilot cockpits, specifically, instead of just augmented crews, in 

general, since there 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 the 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 hours of sleep 

opportunity.
Is it correct to say this reference to any reserve does not include “long-call 

reserve” because the rule specifically 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 call reserve” is 

not fatiguing. 

This section needs a technical amendment. When non-scheduled airlines build 

monthly bid line for flightcrews, the schedule is normally not known in advance. 

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

intent 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. Building a 30-hour rest requirement 

into the 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 scheduling 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 

long call reserve since long 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 11:30am, with a scheduled FDP 

of 13.75 hours. Crew A, on the previous leg, is delayed 45 minutes. Will crew B 

be allowed to operate the original 13.75 hours, considering the 45 minute late 

departure time?

9) Now consider the same scenario as above, but, to prevent crew B sitting around 

at the terminal, crew scheduling informs them about the delay via a passive text, 
and crew B stays at the hotel, longer. Has the flight technically been 

rescheduled, resulting in a 13 FDP?