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View Full Version : Part 117 time.


BigDukeSix
07-20-2018, 11:08 PM
I was jumpseating on a Skywest flight and heard your company plays fast and loose with part 117 duty time. Someone educate the Skywest leadership. http://www3.alpa.org/portals/alpa/committees/ftdt/A-Johnson-2016.pdf


Bravix
07-21-2018, 12:21 AM
I was jumpseating on a Skywest flight and heard your company plays fast and loose with part 117 duty time. Someone educate the Skywest leadership. http://www3.alpa.org/portals/alpa/committees/ftdt/A-Johnson-2016.pdf

As far as I'm aware, that's what company uses. They don't start the clock until the plane starts moving.

I've heard of instances where the 117 time stopped too early and didn't get reset on new brake release/set later on. That isn't an intended feature, as far as I'm aware.

joepilot
07-21-2018, 02:26 AM
The flight time clock starts when the A/C starts moving, but the duty time clock starts when you are required to report. The question was about duty time.

Joe


rickair7777
07-21-2018, 03:09 PM
What they do is creative, but 100% legal with no grey area. In fact it's more legal than the way most of us have logged time in the past...

117 block time (aka FAA "Flight Time") starts when the AC moves under it's own power for the purpose of flight.

So the company is subtracting out the time between push and brake release for powered taxi from each pilot's cumulative flight time. Block for pay purposes is still gate-to-gate as always.

Probably not great for most pilots, who mostly don't want to work that much, but there are probably some guys who like the opportunity to work even more.

Also creates a problem for logging time... while we have always kind of just given ourselves logbook credit for that period between push and taxi, it would be easy to get in trouble doing that if the company is actually generating the technically correct data.

flydiamond
07-21-2018, 05:21 PM
Also creates a problem for logging time... while we have always kind of just given ourselves logbook credit for that period between push and taxi, it would be easy to get in trouble doing that if the company is actually generating the technically correct data.

Endeavor had the 117 tracking changes as well but specifically told the pilots to continue logging block time (door close parking break drop to door open) in logbooks rather than the flight time, and the full block time counts for items such as consolidation of knowledge, getting off high mins, upgrade etc. I was concerned at first as well, but looking in the regs 117 specifies “flight time” while 121 regs reference “time,” so there’s a difference.

word302
07-22-2018, 04:33 PM
What they do is creative, but 100% legal with no grey area. In fact it's more legal than the way most of us have logged time in the past...

117 block time (aka FAA "Flight Time") starts when the AC moves under it's own power for the purpose of flight.

So the company is subtracting out the time between push and brake release for powered taxi from each pilot's cumulative flight time. Block for pay purposes is still gate-to-gate as always.

Probably not great for most pilots, who mostly don't want to work that much, but there are probably some guys who like the opportunity to work even more.

Also creates a problem for logging time... while we have always kind of just given ourselves logbook credit for that period between push and taxi, it would be easy to get in trouble doing that if the company is actually generating the technically correct data.

What you are saying is completely legal, what they are actually trying to do is not.

FollowMe
07-22-2018, 04:38 PM
What you are saying is completely legal, what they are actually trying to do is not.

Can you elaborate? What one company gets away with another will surely emulate, it would help us all if we knew what any are doing to try and bend regulations.

HuskerAv8tor
07-22-2018, 05:55 PM
An aircraft pushes back and an unspecified delay keeps the aircraft in place for 1 1/2 hours. Crew has 8 hours more flying time scheduled. You’re telling me that 1 1/2 hours on the ground while said crew is in charge of all aspects of the aircraft shouldn’t count that as flight time? Give me a break. This is why Skywest needs a union. This is bending the spirit of the rule.

Blackhawk
07-22-2018, 06:16 PM
An aircraft pushes back and an unspecified delay keeps the aircraft in place for 1 1/2 hours. Crew has 8 hours more flying time scheduled. You’re telling me that 1 1/2 hours on the ground while said crew is in charge of all aspects of the aircraft shouldn’t count that as flight time? Give me a break. This is why Skywest needs a union. This is bending the spirit of the rule.

Unfortunately, that is the FAA Chief Counsel legal interpretation.

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2000/blythe%20-%20(2000)%20legal%20interpretation.pdf

Perhaps it is time for a pilot to write the chief counsel's office and ask about this as the Chief Counsel has also written: "In a 2004 interpretation issued to Randall C. Kania, the FAA explained that once flight time commences, it continues to accrue as long as the pilot is required to remain onboard the aircraft."

Of course, a way around this is to release the brakes and move 1".

Another point. I've heard pilots state that they don't log time prior to de-icing as flight time. This is incorrect.

trip
07-22-2018, 08:29 PM
What about the taxi in part? The first time the aircraft comes to a stop is now the end of 117?
What a fantastic mess.

Blackhawk
07-22-2018, 08:46 PM
What about the taxi in part? The first time the aircraft comes to a stop is now the end of 117?
What a fantastic mess.

No. Read the lead interpretations.

Gone Flying
07-23-2018, 05:22 AM
i have found numerous errors in their calculations, just use block time until they are provide transparency on how they calculate time. on my last several flights block time might be 1:50, first wheel move under own power to last brake set before door opens will be 1:40, but their calculations will say 1:34 for example. last time i called i was told it is still in testing. i know at one point it seemed to register last wheel stop prior to off time to first wheel stop after on time. I think this has stopped due to obvious legal ramifications.

rickair7777
07-23-2018, 08:20 AM
An aircraft pushes back and an unspecified delay keeps the aircraft in place for 1 1/2 hours. Crew has 8 hours more flying time scheduled. You’re telling me that 1 1/2 hours on the ground while said crew is in charge of all aspects of the aircraft shouldn’t count that as flight time? Give me a break. This is why Skywest needs a union. This is bending the spirit of the rule.

Actually, no. It's bending the status quo for sure, but the rules are written pretty clearly and you cannot fault FAA legal for a strict verbatim read of the rule... that's how the law works. It's up to the rule makers to write the rules in an airtight manner which accomplishes their intent (FAA has always been relatively weak in that regard).

BigDukeSix
07-23-2018, 11:30 AM
Actually, no. It's bending the status quo for sure, but the rules are written pretty clearly and you cannot fault FAA legal for a strict verbatim read of the rule... that's how the law works. It's up to the rule makers to write the rules in an airtight manner which accomplishes their intent (FAA has always been relatively weak in that regard).
It is bending the spirit of the rule in the 121 world. We’re not talking about cessnas and cropdusters.

rickair7777
07-23-2018, 11:52 AM
It is bending the spirit of the rule in the 121 world. We’re not talking about cessnas and cropdusters.

It might be bending some assumptions folks had about how time is logged when 117 was developed. But how the FAA defines time logging is in black and white, and hasn't changed.