Thread: FAR 117 Effect
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Old 09-01-2013 | 08:06 AM
  #51  
ShyGuy
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Originally Posted by Sniper
SFO's longitude is 122° 22' 43" W
JFK's longitude is 73° 46' 56" W

A difference of less than 60° longitude.

ALPA's interpretation:


ALPA does say 'the continental USA is all one geographic area and we're always acclimated' (Q-01). ALPA also does say there is a specific situation where 'SFO based pilots could use SFO time when reporting out of JFK' (Q-03), though, normally, you would use JFK time (Q-02).

What 'case' does Virgin America management, or you, see that a pilot in JFK is not acclimated to the same theater as a pilot in SFO, or that a company cannot apply a specific time zone to an entire trip that remains in one 'theater'? Please cite your reference.

ALPA had multiple reps on the FT/DT rule making committee (they helped make this rule), and has an established record as an authority on this subject (the reason ALPA was founded was due to fatigue, hence the ALPA motto, 'Schedule with Safety'). If you have information that contradicts such an authority, I'm interested to hear it.
The point that a west coast based SFO pilot would use a local time in JFK for report time is the issue of contention. You are acclimated, true, but there are two ways to go about it. One, is to go by duty time/limitations based on starting a series of FDPs. A series of FDPs are all FDPs within a 30 hr rest period. Or, they can choose a home base option and have all FDPs be based on the local time of the your home base. This second option is the one that virtually all airlines have chosen. ALPA's point on this would be correct that a SFO pilot could use JFK time for report only if there was a 30 hr rest and therefore restarting the series of FDP now at JFK.

"The rest of the story deals with different time zones within a theater. Even in our single-theater operation we still work across five time zones, and the FAA says we must consider those time zones when determining flight duty period (FDP) and daily flight time limitations."

"even though we are acclimated, we still have to account for a pilot's internal clock across different time zones. Thus for each series of FDPs we have to use the local time where that series of FDPs began to determine limits for each duty period in the series. Keep in mind that a 'series of FDPs' is not the same as a trip, a series of FDPs is all FDPs within a 30 hr rest period. This gets to be problematic if, for instance, you have a long layover in a time zone other than where you started a trip."

"Suppose an LAX-based pilot starts a trip on the west coast after having three days off. In this case he would use Pacific Time to define his limits for the first FDP in the trip. He then has a 31 hour layover in Newark. That long EWR layover automatically marks the beginning of a new series of FDPs, and his FDP clock has now reset to Eastern Time, which he then has to apply to every FDP going forward until he
has another >30 hour break. We can see that trips would have to be planned and built using different time zones to determine start times from day to day. This is undesirable because it opens the door for questions like:

What if that 31 hour layover turns into a 29:45 layover because they were late into EWR? Now, the trip that was planned using limits for a local Eastern Time FDP start after the EWR layover has to continue to use Pacific Time instead, and might be illegal before they ever get started on day two. All sorts of other complications could crop up, because the FDP series reset is automatic and mandatory. Using the FDP series start time quickly becomes a complex problem with lots of
variables, so the FAA has offered another way for airlines to determine the applicable time zone for FDP starts. They are calling it the home base option. Under the home base rule, for all FDPs that start within the same theater each crew member applies the local time at his or her home base for all calculations."


So ALPA wasn't entirely correct in their FAQ about a SFO pilot could use JFK time to report on the east coast. True, if he received rest greater than 30 hrs and now marked the start of a new series of FDP. But as mentioned, most airlines are going with the home basing option, and all FDPs are looked at with home base time for calculations.
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