Originally Posted by
sailingfun
She is certainly deadset against commuters getting PS to work and feels it’s a huge safety issue. She also believes it counts as duty time under FAR117 and Delta is in violation of FAR117 when PS is granted.
It's a reasonable argument. (But for lawyers, not line pilots, to make. Big difference)
A big fear when the Part 117 rules were being hashed out was that commuting to work was going to be counted as effectively "on duty." It was initially proposed, but retracted due to the virtual elimination of pilots being able to commute to work on their own time. Pilots would pretty much have to live in base....a huge can of worms for so many reasons.
Fatigue was cited as a contributing factor in the Colgan Air crash that spurred the Part 117 rules. The copilot had been (legally) commuting for long hours into position before reporting for duty.
The flying public would be appalled to know that it's perfectly legal for pilots to commute all night, sleep a couple hours in a crew room, slam back some coffee, then fly a 13 hour scheduled day. As long as they state, "Why no, I'm not fatigued. Not at all."