As I understand the story, Whitlow is a guy who caused a BIG ruckus.

Back in the bad old days, reserve didn't count towards your duty day. You could literally sit reserve 24/7, and the duty clock didn't start until you checked in for a trip.

Obviously, this was bad.

A captain for AMR who was on the flight/duty time committee for the APA, decided that he had had enough, and looked through the rules again. He noticed that if you read the regs word for word, you could interpret "reserve" as a "immediate duty to be available", which obviously isn't "rest."

So he tried to see if he could get a letter from the feds asking to interpret it in this fashion.

Lo and behold, a guy in the FAA Chief Council's office named "Whitlow" agreed, and put out a "letter of interpretation" for exactly that. While the letter didn't specifically deal with duty time, it DID deal with looking back to find a rest period.

Uh oh, now people can't sit 24 hours of reserve anymore (thus the genesis of RAP periods in 2000, or there abouts). Now the airlines would need to actually HIRE pilots. Needless to say, this caused the various airline managements a fair amount of angst.

Well, the airlines didn't take this well, and complained to the FAA, something to the effect of "you can't start enforcing your rules this way". The FAA not only disagreed with this, but they also said "no only is it going to be this way, but you got 6 months to make it right"

The various managements, via the ATA and RAA, objected strenously, to the point where they ran it all the way up to the DC Circuit Court of Appeals.

The Court said (unanimously, BTW), in essence, "Tough luck, the FAA can interpret the rules anyway they like, because, um, they're the FAA"

You can read about the whole thing here:
FindLaw | Cases and Codes

While ALPA intervened on the appeal to the Circuit Court, it's well worth noting that it was the APA who got off the pot and got us off 24 reserve periods. Kudos to them.

Nu