Dear Sir or Madame,

Please consider this letter Horizon Air’s request to the FAA for clarification of the 

Flighcrew Member Duty and Rest Requirements final rule.

Sincerely,

Mark Riely

Manager of Compliance

Horizon Air

Tel. 503-384=4395

Questions concerning flight duty period FDP

In the definition of flight duty period in 14 CFR 117.3 it says the FDP ends when the 

aircraft is parked after the last flight and there is no intention for further aircraft 

movement...”

FDP Question 1:

In the definition 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?

FDP Question 2:

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 am I correct in assuming that 

none of the duty time is consider a FDP.

FDP Question 3:

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 

flight segment.

Question concerning local time
In 14 CFR117.15(a) it states “The rest opportunity is provided between the hours of 

22:00 and 05:00 local time.”

In addition, I would like to clarify that the scheduled time of start in Table B refers to a 

pilot’s base or acclimated local time.

Question:

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?

Questions concerning rest periods

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 14 CFR 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?

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?

Questions concerning consecutive nighttime operations

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

begin at 0530 and end at 1530?

Questions concerning 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 they will be too fatigued to fly the sixth flight 

segment, but will be fit to fly the fifth flight segment.

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).