Originally Posted by
Flymeaway
I think you’re ignoring a key part of that sentence in 117.25. The minimum 10 hour rest requirement ends immediately preceding the FDP, but begins immediately following the previous duty assigned by the certificate holder. There’s no 10 hour look back in the text of 117.25. You look back to the previous duty period. That rest period, which includes commuting, either by car, hotel van, or airplane, must have an 8 hour sleep opportunity in it somewhere, but it doesn’t state that it must be within the last 10 hours of that rest period, only that at least one was available during the rest period at some point.
Additionally, the flight crew member must be fit for duty, which includes many factors, to include when in that rest period, which could be a week or more, his most recent 8 hour sleep opportunity occurred. It is up to the flight crew member to consider all factors and determine his fitness for duty.
No, read it again. It’s saying rest can’t begin until duty ends, otherwise the company would do 10 hours from when you set the brake. The FDP ends when you set the brake. The rest period can’t begin until you are off duty. There is a difference, and for once it’s in our favor. This is their way of saying minimum time between duty periods is 10 hours. During that 10 hours you must have had an 8 hour sleep opportunity. Doesn’t mean you slept, just that you had the opportunity. You can be in rest for an unlimited number of hours. It just can’t be less than 10 since you need 10/8 immediately prior to reporting for duty.
Commuting over 2 hours before sign in precludes having had the 8 portion of the 10. So, you then read the next section which says, notify the certificate holder when you don’t get the required 10/8.... which is exactly what you do on days 2,3 and 4.... so, where’s the exemption for day 1?