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Old 02-18-2026 | 08:15 AM
  #4759  
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notEnuf
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Joined: Mar 2015
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From: N60.4858 W149.9327
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Originally Posted by tennisguru
From page 185 of the SRH (bold added by me):

FAR Part 117 includes four rest requirements:
1. “30-in-168” Before beginning any reserve availability period (RAP) or FDP, a pilot must have received at least 30 consecutive hours free of duty within the 168 consecutive hours (seven 24-hour periods) immediately preceding the start of the RAP or FDP.
2. “10 before beginning” Before beginning any RAP or FDP, a pilot must have received at least ten hours of rest with a minimum of eight uninterrupted hours of sleep opportunity. A sleep opportunity generally commences once the pilot is at a location where he can reasonably be expected to go to sleep and not have that sleep interrupted, such as a hotel.

Note that in the SRH and FAR 117 they both explicitly say "before beginning..." There is no carve out for "not intending" to begin. If you know you have an assignment upcoming for which you do not have legal rest then you are required to notify the company prior to the start time that you are not legal. Allowing the start time to pass means you started a SC RAP, regardless of your so-called intentions. The fact that you then received a SCC for sitting the SC (again, how can you get credit for sitting SC if you had no inention of sitting it?) means that per the FAA you sat at least a few minutes of SC without legal prospective rest.
I did the right thing and was rewarded for it. I can’t control a schedulers actions. I was probably on hold for an hour. I don’t recall all the details but I know it happened. Technically I was not on a RAP because I knew I was not eligible for any assignment. They were happy I caught it and thanked me. I appreciate your vigilance but I don’t care what your opinion is. If/when the FAA comes to investigate I’ll get more PTO as ALPA defends my actions.
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