Query about the new FAR 117 - 30 in 168 rule
 

One of our clients recently told us that the FAA has revised the 30 in 168 rest rule. Unlike the Old 24 in 7 rule, which was measured from the expected arrive time of the operating flight, the lookback is at the start of the FDP. In other words, "Legal to start ... Legal to Go". The extension of the FDP will only be constrained by the conditions in 117.19. Theoretically this means a Flightcrew member could operate over portions of 8 calendar days without even as much as a 24 hour rest period.

On 16-May-2012 the rules was changed to read as:
117.25 Rest period.

(b) Before beginning any reserve or flight duty period a flightcrew member must be given at least 30 consecutive hours free from all

duty within the past 168 consecutive hour period.


The original rule as published on 04-Jan-2012:

117.25 Rest period.

(b) Before beginning any reserve or flight duty period a flightcrew member must be given at least 30 consecutive hours free from all

duty in any 168 consecutive hour period.

Has anyone heard of such an approved interpretation?

Here is the data that supports my argument
 

30:00 rest from 12:00 Day 1 to 18:00 Day 2

FDP FDP FDP Rest
start end time after
18:00 Day 2 01:00 Day 3 7:00 15:00
16:00 Day 3 23:00 Day 3 7:00 15:00
14:00 Day 4 21:00 Day 4 7:00 15:00
12:00 Day 5 19:00 Day 5 7:00 17:00
12:00 Day 6 19:00 Day 6 7:00 17:00
12:00 Day 7 19:00 Day 7 7:00 17:00
12:00 Day 8 22:00 Day 8 10:00

52:00 Scheduled accumulated FDP in 168:00
57:00 Actual accumulated FDP in 168:00

FDP on day 8 may be extended to 03:00 on day 9 (15:00)

You have to love the Federal Register, you can share stuff on twitter but I can't get text to copy on an iPad.

Anyhow, you have to think like a lawyer. The text was changed to require that the 30 hour rest be found in the 168 hour look back before the current duty period. Under the earlier verbiage you could argue the pilot had a 30 hour rest in January and was therefore covered for any duty period for the rest of their career.