Request for clarification for 117.21.(c).(3)

For determination of the maximum applicable flight duty period in Table B, is a 121 Passenger Air carrier expected to enter the table using the time of the Start of the short call reserve (SC) , or, the time of start of the assigned flight duty period (FDP)

.

117.21 Reserve status. (a) Unless specifically designated as airport/standby or short

- call reserve by the certificate holder, all reserve is considered long

- call reserve. (b) Any reserve that meets the defi nition of airport/standby reserve must be designated as airport/standby reserve. For airport/standby reserve, all time spent in a reserve status is part of the flightcrew member’s flight duty period. (c) 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). (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.**  (4) For an augmented operation, the total number of hours a flightcrew member may spend in a flight duty period and a reserve avail ability period may not exceed the flight duty period in Table C of this part plus 4 hours, as measured from the beginning of the reserve availability period.**Examples #1:**

Start of SC is 0:01. Start of FDP is 04:01. **Method A** If we enter the table using th e start of the SC, Table B will return 9:00, to that we add 4:00 which results in 13:00, compare that value to 16:00 and use the lessor of the result is 13:00, add that to the SC start time results in 13:01. **Method B** If we enter the table using the start of the FDP, Table B will return 10:00, to that we add 4:00 which results in 14:00, compare that value to 16:00 and use the lessor of the result is 14:00, add that to the SC start time results in 14:01. **Examples #2:** Start of SC is 22:01. Start of FDP is 02:0 1. **Method A** If we enter the table using the start of the SC, Table B will return 10:00, to that we add 4:00 which results in 14:00, compare that value to 16:00 and use the lessor of the result is 14:00, add that to the SC start time results in 12:01. **Metho d B**  If we enter the table using the start of the FDP, Table B will return 9:00, to that we add 4:00 which results in 13:00, compare that value to 16:00 and use the lessor of the result is 13:00, add that to the SC start time results in 11:01. Respectfully submitted **Garret Healy** Sr. System Programmer

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