Originally Posted by
kronan
Hmmm, 25 posts since June of 2007. Wonder why that could be?
Yep decided hanging out on these forums and some its trolls was not productive. That's why I did something instead of trolling about it. Read the website. Don't agree? Don't sign it. I'm out for another 12 years.
When your head is buried in the sand there's a high likelihood of activity you may not enjoy near your rear end.
Here's one excerpt from
http://saynoto117.com:
The 1/14/2020 Fastread strikes a similar bullet from the same sheet of talking points: "One hazard of supporting broad science-based flight time duty time regulations is the reality that those rules may not support behavior that you, the Company, and/or ALPA deem safe."
Translation: The MEC knows and you know week-on/week-off night hub turns are safer than doing a maximum of three hub turns (the limit in Part 117) and having more frequent circadian rhythm shifts. They also know that those week-on/week-off night hub turn lines won't be allowed under Part 117.
The update goes on, : "Importantly, there is the possibility built into Part 117 that an Alternate Means of Compliance (AMOC) can be obtained to deviate from the rule. The AMOC allows data collection to prove that operating outside the limits of Part 117 are demonstrably as safe or safer within the context of an individual operation, thus nullifying the one size cannot fit all arguments."
Nope. The possibility of AMOC doesn't nullify those arguments one bit. Not unless you know going in what AMOC would be approved and how long it would take to get it approved. Unbelievably, in the next sentence, they admit they have no clue about AMOC going in: "Since we cannot know which AMOCs will be sought or accepted, absolute forecasting of the effects of 117 are impossible."
Again, this approach is a huge a gamble. AMOC's can take years to get approval and given the heightened scrutiny on the FAA after the 737 Super Max debacle, don't expect the FAA to be bending over backwards to grant waivers to the rules. Buying a "fixer upper" is not a good move if you don't know fixing up is even possible or how much it'll cost.