AD OPT, a Kronos Division FDT Final Rule Clarifying Questions May 4, 2012

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## FDT Final Rule Clarifying Questions

Section 117.3 Definitions

Theater:

Theater means a geographical area where local time at the flightcrew member’s flight duty period departure point and arrival point differ by more than 60 degrees longitude.

1. Could you pl ease confirm that the term “local time” in the definition is unintended ? We believe that this is just a remnant from the fo rmer NPRM definition of theater. Will this be corrected?

2. Does the above definition actually refer to “ duty period ” , as opposed to f light duty period (FDP) , where “duty period” extends from the beginning of sign

- in (report) to end of sign

- off (release) ? Our reasoning is that a flight duty period does not include deadheads after the last operating flight. These deadheads can take cre wmembers outside of a theater or bring crewmembers back into a theater before the end of a duty period (e.g., ORD

- JFK followed by deadhead from JFK to LHR, or HNL

- JFK fol lowed by a deadhead from JFK to LAX ). Accordingly, it seems to us that these deadhead s must be taken into account when determining the crew’s acclimation state at the end of a duty period

.
3. What station should be used as the reference point for determining the extent of a theater

– the departure station of a duty period or the station where the flight crew were last acclimated? Our interpretation of the above definition is that flight crew members remain in a “theater” as long as the difference in longitudes between the first station and the last station in a duty period is less than or eq ual to 60 degrees.
Moreover, the 60

- degree geographical area can shift from one duty period to the next, instead of being anchored at a location where the flight crew members are either acclimated or trying to gain acclimation. This is because the extent of the theater is calculated as the difference between the “departure” and “arrival” stations of each duty period, rather than the difference between the “departure” station and the station where the flight crew members are acclimated (or attempting to ga in acclimation).

For instance:

 Crew members can depart from New York (JFK) on Day 1 acclimated to JFK and travel to Los Angeles (LAX) while maintaining their acclimation, since the difference in longitudes between the departure and arrival stations is les s than 60 degrees. For this duty, the theater extends from JFK to LAX.

 On Day 2, the same crew can operate a flight from LAX to Honolulu (HNL) while remaining within a 60

- degree geographical area that extends from LAX to HNL . The crewAD OPT, a Kronos Division FDT Final Rule Clarifying Questions May 4, 2012

Page 2 of 5 would not lose accl imation, since their net movement during the second duty remained within one theater

– even though they are now more than 60 degrees away from their home base (JFK) . The crew would enter the FDP table based on JFK local time on Day 2, since the crew never lost acclimation when travelling to LAX on Day 1

. For this duty, the theater extends from LAX to HNL.

 Using the same logic, the crew could then continue on to Fiji (SUV) on Day 3 and still remain “ acclimated ” , since the longitude difference between the d uty period departure point (HNL) and arrival point (SUV) is less than 60 degrees. For this third duty, the theater extends from HNL to SUV and the crew would still be acclimated to JFK.

 In summary, a s long as the crew’s net movement during a duty does not extend beyond the 60

- degree

- wide geographical area anchored at the point of departure, the crew could keep on moving in this fashion (theoretically, around the globe) without ever losing acclimation. W as this the or iginal intent of the theater/acclim ation definitions? Could you please clarify how the ruling works for this type of situation ?
Another example:

 Crew members can depart from Los Angeles (LAX) on Day 1 acclimated to LAX and travel to Honolulu (HNL) while maintaining their acclimation, since the difference in longitudes between the departure and arrival stations is less than 60 degrees.

 On Day 2, the same crew operates a flight from Honolulu (HNL) to New York (JFK). According to the definition in the final ruling, the flight crew would lose acclimation upon arrival at JFK, since the difference in longitudes between the departure and arrival stations exceeds 60 degrees. However, the flight crew departed from HNL acclimated to LAX, which is less than 60 degrees longitude away from JFK. Shoul d the flight crew members really lose acclimation to LAX in this situation?AD OPT, a Kronos Division FDT Final Rule Clarifying Questions May 4, 2012

Page 3 of 5 Acclimated:

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.

1. For the pur pose of determining the maximum FDP limit in Table B, should the acclimation reference station ever change for acclimated crew operating within a theater?

a. Case 1: After 36 consecutive hours free from duty . For instance, consider LAX

- based flight crew memb ers who operate to JFK and then get a 36

- hour layover at JFK. Our understanding of the final ruling is that LAX local time would apply to Table B for the next duty out of JFK, since flight crew members remained in the same theater when operating from LAX to JFK. In other words, the acclimation reference would not change.
Now, consider LAX

- based flight crew members who operate to LHR and then get a 36

- hour layover at LHR . Our understanding of the final ruling is that LHR local time would apply to Table B for the next duty out of LHR , since flight crew members were given sufficient rest at LHR to acclimate to the new theater

. While this change in acclimation reference from LAX to LHR does not seem unreasonable, we are wondering why 36 hours rest would be sufficient for LAX

- based crew to acclimate to London (LHR) local time, while LAX

- based crew flying out of JFK after the same amount of rest would not be considered acclimated to JFK?

b. Case 2 : After 36 consecutive hours free from duty (successive “small” h ops)

. I f the theater interpretation allows flight crew to maintain acclimation by travelling in less

than

- 60

- degree hops, would the acclimation reference station for Table B not change even if the flight crew members were very far away from their home ba se? For instance, consider JFK

- based crew who travel westward in successive less

- than

- 60

- degree hops (i.e., JF K

- LAX

- HNL

- SUV) and then get a 36

- hour layover in Fiji (SUV).AD OPT, a Kronos Division FDT Final Rule Clarifying Questions May 4, 2012

Page 4 of 5 c. Case 3 : After operating in the same theater for 72 hours . We would expect the ans wer to be “no” in this case, mainly because it would be very tricky to manage. However, if the theater interpretation allows flight crew to maintain acclimation by travelling in less

than

- 60

- degree hops (please refer to our Theater question above), the qu estion begs to be answered. For instance, consider JFK

- based crew who travel westward in successive less

- than

- 60

- degree hops around the globe. Would the reference station for Table B always be JFK, even if they find themselves in Asia and have been away from their home base for, say, one week?

2. When flight crew members lose acclimation, at what station do they regain acclimation?

a. Case 1: After 36 consecutive hours free from duty

. According to the definition, flight crew members would regain acclimation at a station where an opportunity for 36 consecutive hours rest has been provided. For instance, JFK

- based flight crew who lost acclimation after a flight from JFK to CDG would regain acclimation at CDG following a rest at CDG of 36 consecutive hours or long er. But, what would happen if the crew did not get 36 consecutive hours of rest before operating to London (LHR) and the 36 hours rest was given at LHR

– would the crew members be acclimated to CDG or to LHR?

b. Case 2: Flight crew enter a new theater and continuously work in that same theatre for 72 hours

. Consider a situation where a flight crew based in JFK operates a flight to LHR (new theater) and then continues to operate flights in Western Europe (say, France, Spain, and Italy) over the followi ng 72 hours.

i. At which specific station does the flight crew regain acclimation, for the purpose of entering FDP Table B? Is it the first station where the flight crew lands upon entering the new theater (in this case, LHR)? Is it the first station where the flight crew members have a rest around the 72

- hour mark?AD OPT, a Kronos Division FDT Final Rule Clarifying Questions May 4, 2012

Page 5 of 5 ii. What happens if the flight crew moves successively eastward in less

- than

- 60

- degree hops per duty period during the 72 hours, after having lost acclimation at LHR? Suppose, for instance, that t he flight crew performs the following sequence of duties: JFK

- LHR

- PRG

- MOW

- ALA

At which specific station does the flight crew regain acclimation , if 36 consecutive hours of rest are never achieved? Please note that the difference in longitude between Lo ndon (LHR) and Almaty (ALA) is approximately 76 degrees.
Thank you in advance for your assistance with our questions.
Philip Ifrah , M. Eng., MBA Product Manager, AD

- OPT Division Kronos t: +1 514 764 8295 f: +1 514 345 0422 philip.ifrah@kronos.com

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