Originally Posted by
Sunvox
Based on my current understanding I do not believe that interpretation is correct. When you show up for the first leg of a trip you must determine which set of rules will apply to you: 1)un-augmented 2)augmented 3)split duty. In the case of EWR-BOM-EWR or EWR-GRU-EWR the length of the first leg dictates that you will be flying under Augmented Flight rules and therefore the limits outlined in the table above will apply. When you land at your destination you do not "re-acclimate" until after 36 hours of rest at a minimum so any additional flying you do prior to that is considered part of your original Flight Duty Period. In other words EWR-GRU-EWR or EWR-BOM-EWR as is currently scheduled is a SINGLE FDP (Flight Duty Period) and is therefore limited to the total duty limitations in the table above. The only way to "re-acclimate" is to rest for 36 hours.
I have been wrong before and I could be wrong here and in fact I hope I am, but I've contacted numerous ALPA reps and I'm waiting to get back a definitive answer.
I'm working on a company project related to this.......your answer isn't correct, both legs are single FDPs with limits based on your acclimated time. Without acclimation you will always use your base time (ie layovers less than 36 hours), and in the case of GRU it doesn't matter because going deep south you don't enter into a new theater (60 degrees longitude) which is the only time acclimation comes into play. The company is looking at each new theater flight individually to see how the reg affects them. In some cases departure times may be adjusted, others will have the 36 hours to take advantage of an acclimated FDP limit, while others will gain extra augmentation even though it is not required to take advantage of the longer FDP limits. Each one is on a case-by-case basis as no one solution fits all.