Originally Posted by
FXLAX
Actually, they did in fact point out the three specific examples in a document that was attached to one of their blast mails. Here is an excerpt of it:
“The AMOC would need to meet or exceed the safety standards set forth by the prescriptive limitations.
Existing carriers operating under FAR 117 have applied the FRMS approach and have received AMOCs to exceed the flight time and flight duty period (FDP) limits to operate ultra-long range (ULR) flights, modify the requirements for a Class 1 rest facility, as well as, modify the placement of prescriptive rest on augmented flights. In each of these cases the carrier proposes to the FAA an AMOC and data collection plan to show the desired operation under the AMOC can be flown as safe or safer than the current prescriptive limitations of FAR 117. This is achieved by adding mitigations to address fatigue such as increasing the required rest prior to, during, and after a pairing sequence, requiring 2 captains on augmented flights and having more stringent fit for duty (FFD) verifications prior to each flight under the AMOC.”
There are more than mere examples. And they aren’t necessarily wishes as these don’t seem to even address the company’s biggest concern, more than 3 consecutive night hub turns. They were clearly mentioned to show that AMOCs are not a unicorn. And of course no one could event promise an AMOC. That wasn’t the point of me mentioning it. I merely answered the question that was asked. Sure, ALPA doesn’t apply for AMOCs. That process is part of 117s specific FRMS requirements that ALPA does have been a part of. AMOCs are driven by actual data. That data is proprietary and would only apply to that specific airline. But knowledge of other airlines’ having AMOCs for certain things is not proprietary.
I’ve read it before and now I just read it again.
I stand by what I said, 110%. No one can compel either pilot to extend beyond 30 minutes. I worked under 117 for many years. They cannot ever force you to go beyond the 30 minute extension. But of course they may want to know the circumstances. That doesn’t change in 117 versus 121.
This is getting absurdly frustrating. Last post on this subject. You keep coming back to the three specific exact AMOCs the MEC listed and then you listed above. YOU DID NOT DO THAT - NOR DID THE MEC. There are none - zero examples of an AMOC. An example is not "this is how we think you apply for one" - an example is "carrier xx got approval to regularly go beyond scheduled limits on weekends flying out of xx airport because of xx" - that's the example. They have no example - that's why they say "existing carrier have...." and can't produce one. It's what they THINK could work from reading the FAA short one page guidance on how to apply - that's it. What we don't have are any examples of whether they actually work. There's a law passed that says oxygen mask regulation shall be changed by the FAA no later than October 2019. We're 6 months passed that and it hasn't happened - there's an example for you of how you think things should work, but actually don't. Go back and re-read what you have posted, re-read the MEC's communications and then list for me an exact example from a carrier (carrier name would even be better). If you can't do that then you have no examples - you just have an idea of how it may work (like the oxygen mask story - we think we know how things might work but then they actually don't work that way in real life).