Thread: FAR 117 Effect
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Old 09-05-2013 | 12:22 AM
  #54  
ShyGuy
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Originally Posted by Sniper
So some airline operations person is complaining that they will have a hard time building domestic US trips based on local time, because delays might force a scheduled 30+ hours of rest to be reduced below 30 (true, but this is the case if you used 'home base' time too), and the show time of the trip could be modified into a different part of ‘Table B’ (duty period limits for an unaugmented crew), rendering the previously legal trip illegal (which is incorrect, b/c the show time of the EWR flight didn't change, only the arrival time from LAX, and thus the amount of rest in EWR going from 31 hours to 29:45). Almost a page of writing to say . . . nothing.

If you need 30+ hours of rest in EWR, either:
  1. delay the EWR flight, which could make a previously legal trip illegal b/c the amount of duty is now too much with the new show time (which is time zone dependent, and thus variable based on your company choosing to use 'home base' or 'local' time rules)
  2. don't delay the EWR flight, and you no longer get 30 hours of rest, so you might be illegal now b/c of that.
With option 1, if you use local time for the whole trip vs. home base time, the airline could either get lucky or unlucky. Perhaps the modification of the show time could put the pilot into a new, lower, FT or DT bracket, one that the pilot wouldn't have been in had the company used the other method, one that would make a previously legal trip illegal. Say you had a trip that had an 11:55 EST show for a 2 leg, 8:55 flight time, 13:55 duty day (08:55 PST show for the same trip). If you delay the show 15 mins to keep the 30+ hour layover, you'd now have a 12:10 EST show (09:10 PST). With EST, this takes you into a max 13 hour duty day, so the trip (13:55 duty scheduled) is illegal. With PST, you'd still be good to go. So, you either get lucky (in this case, use 'home base time') or you don't. Of course, the opposite example can also occur (where the local time keeps you legal, but the home base time doesn't).

With option 2, don't delay the flight, if that 30+ hour layover in EWR was necessary to keep your schedule legal, then you're going to have to get that rest sometime, so, either a RSV crew will have to be burned, or your schedule will have to be modified. Depending on how long ago you last got a 30+ hour rest, option 2 might not even be available.

The option the example seems to stress - don't delay the flight, but the EST vs. PST creates an issue - that's impossible, b/c the 30 hours is not dependent on time zone, only the show time, and the show time didn't change.

Since we agree that a LAX crew is both 'acclimated' and has not changed 'theater' in EWR , lets look at our disagreement:

Yeah, that 30 hour rest thing and the start of a new FDP. Let’s look at that. From your un-cited reference:

That bolded part is the source of my confusion.

That is the only mention in FAR 117 of a 30 hour rest period, and, in fact, the only use of the number "30" in FAR 117. While a new FDP does indeed start after a 30 hour rest, whether you are starting a ‘new’ FDP or continuing a current one is immaterial to what time zone you are required to use when determining FDP limits in Table B (duty period limits, based on show time, for an unaugmented crew). It merely requires a ‘look-back’ of 30 hours of rest in 168 hours, just like the current ‘look-back’ of 24 hours of rest in 7 calendar days. Once you get the 30 hour rest, you are good to go for another 138 consecutive hours (168-30) without a 30 hour rest period (just like now you are good to go for another 6 calendar days without a 24 hour break).Whether you use LAX time or EWR time, 29:45 of rest is still 29:45 of rest, no matter how many time zones you’ve crossed prior to beginning it. Whether you are starting a new FDP or continuing a current one is irrelevant. It does not give relief to compliance with Table 2, just like today, whether you are coming off 24 hours of rest or 8 hours of rest and no matter what time zone you are in, your FAR max duty day is still 16 hours.

So, just like ALPA says (and FAR § 117.13(b)(2) . . . and B.2. on page 3 of the FAA’s response to A4A), an airline can use ‘Local time’ for the entire trip, or can use ‘home base time’ for the entire trip. The airline does not have to use local time, but would then be required to use ‘home base time’ for the entire trip. This would be true whether the pilot gets a 31 hour rest, a 29:45 rest, or a 10 hour rest – the minimum allowed.

I can't find any support for your '30 hour rest = new FDP = implications for Table B (for an unaugmented pilot that operates within 'the lower 48'). If you have one:
You're confusing separate issues. One of things clarified was what a series of FDP is. It is not a trip. You need to understand what a series of FDP is and how that applies. If a flight crew member remains acclimated, a series of FDPs consists of FDPs that take place between the 30 hrs of rest.

Airlines have two options for domestic unaugmented crews:

* Use local time at the location where the FDP series began

OR

* Local time at the flight crew member's homebase if the flight crewmember is acclimated to a theatre that encompasses the home base.


That FAA document you cited is what the airlines have used after the FAA clarified up the two options available. The EWR example cited above assumes that the airline chooses to use option #1. Use local time at the location where the series of FDP began.

Look at the example in the FAA document, that is what the airlines have used.

Source: FAA document you linked, top paragraph page 4........


"For example, an acclimated flight crew beginning an FDP series in the Eastern time zone has 36 hrs of rest in the Pacific time zone. Because this crewmember would receive over 30 hours of rest, the next FDP, which would be out of the Pacific timezone, would commence a new FDP series. Thus, this crewmember would enter Table B and C based on either Pacific time or home base time"


What that means............................................. ..


You would use Table B based on Pacific time if the airline had gone with option 1, which is use local time at location where a new FDP series began.

--- OR ---

You would use Table B based on home base time if the airline had gone with option 2, which is local home base time since it's in the same theatre. In this case, EWR home base time.

You need to understand that and it makes a huge difference.

By choosing to schedule by option 1, the airline would need to have 30 hrs of rest scheduled to start a NEW series of FDPs. Once you have that 30 hrs of rest and start a new series of FDPs, you would then use the local time at that location for the FDP. The EWR example my airline provided, and the FAA example provided linked above are examples of this.

By choosing to schedule by option 2, you take out all the hard work and use home base local time for ALL rest calculations within the theatre. East or West coast, you enter table B and C based on local time at home base. This option does not consider series of FDP changes.


All the major airlines met with FAA officials, and every single airline (that's what we've heard) has chosen to use "home based local time" for the 48-state single theatre operation.

What airline do you work for? Ask your crew planning department, they'll tell you the same thing. This has been finalized and this interpretation is what the airlines are using, and the driving force for VX to create a EWR/JFK base. All other major airlines have used the same (home base option).

I hope that clarifies everything.
Last edited by ShyGuy; 09-05-2013 at 12:39 AM.
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