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Old 03-21-2020, 10:26 AM
  #64  
FXLAX
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Joined APC: Nov 2017
Posts: 2,099
Default Cargo Under Part 117 Effort Accelerating

Originally Posted by Tuck View Post
ug you're killing me. Listing the process is not pointing out a specific AMOC. Feel free to call any MEC members and ask th em about it - there are no examples. They have an idea of what it may take (largely from FAA documents) to get one - they have no practical idea if these are things that can even be done or have been done. Although there undoubtedly are some AMOCs out there we really have no idea how they got them, whether ALPA was involved in getting them or how long/difficult the process was.

You said, specifically, to show evidence of AMOCs. I pointed you to the evidence you were asking for by listing three actual real life examples that came from the MEC itself. The MEC communication listed those as current AMOCs in use, not as examples of ones that management can peruse. So you saying there are no examples and asking the MEC about it are not true. Then you said that the MEC has no idea what it takes to get an AMOC (and I don’t think the MEC said they know how to get one). You moved the goal post.

I don’t care about AMOCs. My position is pro-117 as written. If an airline can use data obtained through the 117 FRMS (collaboration between management and ALPA), and convince the FAA an equivalent level of safety with specific mitigations, then I’m fine with that as well. It’s data driven. It’s not something that can be copied and pasted from another airline. It’s not a matter of knowing how to do it. It’s a matter of seeing the operation’s specific system form data and seeing if there is a “better” way of accomplishing the flight(s) with the same level of safety. It’s a case by case basis, not something that you can just copy from another airline or even from a different aspect of your airline. In other words, there is nothing to “know” ahead of time. The actual processes are spelled out in the FRMS. The data and mitigations come from the specific operation. It’s not rocket science. It’s something that the FAA has done for years. If there were any questions, the FAA people are there to help.

Personally, I feel it’s not a good argument for the MEC to make. Either they are for 117 as written or not. AMOCs are just tools that management may try to use to modify a specific rule. It’s not something they would do unless it benefits the operation, which isn’t always in line with the pilots’ benefits.
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