Originally Posted by
9Etransplant
Per the regs:
“Rest period means a continuous period determined prospectively during which the flightcrew member is free from all restraint by the certificate holder, including freedom from present responsibility for work should the occasion arise.”
The carrier is not restraining a crewmember during a commute since it is not scheduled by the carrier.
Question and answer 74 here also provide additional clarification.
http://www3.alpa.org/portals/alpa/co...015.pdf#page25
Commuting isn’t rest. You can’t pick which sections you want to comply with and ignore the others. The air carrier is not always the cause of a legality, in the case of commuting it’s the pilot causing the legality. Both have a responsibility for compliance.
Go read the interpretations.
Read the bottom of page 1
http://www3.alpa.org/portals/alpa/co...owney-2014.pdf
Did you read your own publication? Read the question right before the one your referencing. Read #73 Answer part 2.
Question #75 specifically addresses what happens when travel time prevents an 8 hour sleep opportunity in the preceding 10 hours.
In the case of a commuter, the company has provided more than 10 hours free from duty on day 1. The pilot has decided to commute to base during that 10 hours. If the commute is longer than 2 hours the pilot no longer had an 8 hour sleep opportunity in the preceding 10 hours and per the interpretation is required to notify the certificate holder.
The requirement of 10 & 8 prior to beginning any FDP applies to all FDP’s.... not just the ones after you report on day one.