Originally Posted by
1234
I am not following you. How do you get that commuting will get more interesting from that reference.
I hope I'm wrong, but the way I read it is this:
Prior to duty, a crewmember must have a rest period as defined by 117.25(e):
(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.
This defines a rest period as 10 consecutive hours free of duty, of which, 8 must consist of an uninterrupted sleep opportunity. A ride on a jumpseat is not likely to be considered an uninterrupted sleep opportunity. Remember: this 117.25(e) rest period must take place
immediately before beginning the reserve or flight duty period. Pilots tend to forget that rest requirements are to take place prior to duty, not after duty. The reference
measured from the time the flightcrew member is released from duty means that the ten hours prior to duty can not consist of any duty time, not just flight time (in our case, 30 minutes after block in).
Stated more simply: When you go off-duty, you must be able to look back and identify a ten-hour rest period, eight of which must be an uninterrupted sleep opportunity, that took place immediately prior to signing in for duty.
And on top of that, we have to report if we don't get it (117.25(f)):
(f) If a flightcrew member determines that a rest period under paragraph (e) of this section will not provide eight uninterrupted hours of sleep opportunity, the flightcrew member must notify the certificate holder. The flightcrew member cannot report for the assigned flight duty period until he or she receives a rest period specified in paragraph (e) of this section.
Add to that 117.5(d):
(d) As part of the dispatch or flight release, as applicable, each flightcrew member must affirmatively state he or she is fit for duty prior to commencing flight.
I sincerely hope that this get interpreted by the FAA to apply only to layovers, but there is nothing in this language to suggest that this is the case.
One thing is for certain: It will take a while to find out how the various players interpret these new regulations, and there's going to be some battles.
We live in interesting times.
