Originally Posted by
sailingfun
We have commuting protection that applies to DH deviations. Your assertion that it’s a tiny number who benefit in the other situation is false. DH’s the day prior are very common on international trips. It’s rampant on 330 NYC flying. A pilot based in DTW I can assure you does not commute in the day prior from FL for his 6PM JFK departure just as he does not go in the day prior if the first flying leg was 6 PM from his base in DTW.
As far as the FAA I would talk to your reps. It’s a area of concern. A DH starts your duty clock.
I realize that the few categories that have tons of front end DH's will take advantage of this. That's great, I'm in favor of that, and don't think it'll be in jeopardy the way you are really reaching to attempt to claim it will.
But the large majority of DH deviations are same day pilots.
So worst case, those categories would have to come in the day before, as they were originally scheduled, but could still PS Dev from anywhere in the system. All other DH Devs would have one flight protections, no questions asked. You can put that to a pilot group vote any day.
Now, that said, you're still wrong IMO about the potential, theoretical FAA issue. We already get PS on our backup flight for commuting per the flt ops memo. Those flights are earlier than the original report 100% of the time, and by definition that isn't even the first flight the commuter was required to try and get on. Where's the reg change for that? There isn't one.
A DH Dev is voluntary. It doesn't even have to involve flying at all. Guaranteeing a seat doesn't mean its a mandatory assignment any more than if you used your One Great Team pass to commute in. What if we got a PS for every IROP and/or every reroute we could use whenever? Would the FAA then try to lock those in as duty? They could give us unlimited PS on any flight any time for any reason if they wanted to (theoretically) so would that mean we'd need to block all our vacation flights as duty blocks just to comply with 117? Of course not.
If they made a DH Dev an S2 priority, would that trigger a reg change? How about if it was S1? Above S1 but below revenue? It being PS doesn't mean you were ever scheduled for that flight so its not relevant.