IPA Comments to FAA Regarding Part 117
02-13-2013, 09:57 AM
#21
Organizational Learning
Joined APC: Nov 2005
Position: Directly behind the combiner
Posts: 4,948
Originally Posted by CactusCrew
As I recall, up until the last few days, cargo pilots WERE included in the regulations. By inserting PASSENGER airline pilots into the language where applicable, the carve-out was created.
SUBPART Q.
§ 121.470 Applicability.
This subpart prescribes flight time limitations and rest requirements for domestic all-cargo operations, ...
SUBPART R.
§ 121.480 Applicability.
§ 121.480 Applicability.
This subpart prescribes flight time limitations and rest requirements for flag allcargo operations, ...
SUBPART S.
§ 121.500 Applicability.
§ 121.500 Applicability.
This subpart prescribes flight time limitations and rest requirements for supplemental all-cargo operations, ...
And the new one:
§ 117.1 Applicability.
§ 117.1 Applicability.
(a) This part prescribes flight and duty limitations and rest requirements for all flightcrew members and certificate holders conducting passenger operations under part 121 of this chapter.
...
(d) Notwithstanding paragraphs (a), (b) and (c) of this section, a certificate holder may conduct under part 117 its part 121 operations pursuant to 121.470, 121.480, or 121.500.
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02-13-2013, 10:05 AM
#22
Organizational Learning
Joined APC: Nov 2005
Position: Directly behind the combiner
Posts: 4,948
Originally Posted by Naven
They were even changed from the original NPRM so UPS and FedEX pilots could do 5 night a week trips up from the proposed 3 night a week limit.
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02-13-2013, 11:31 AM
#23
Gets Weekends Off
Joined APC: Jun 2006
Position: Frm. DHLAirways. Blue & White Boeing's Now. YEA!!
Posts: 610
Originally Posted by TonyC
Nowhere in there can you find a guarantee that the court will or even might cause the FAA to change a portion of the Final Rule. They've already allowed the FAA to "do over" the benefit-cost analysis that led to their carve-out of all-cargo airlines. When that process is complete, what will happen if they reach the same conclusion, and the carve-out stands? What is the next step in the court's review of the final rule?
While they've said it's not the goal, the only remedy left is to vacate the final rule and leave the FAA to start over from scratch. Mind you, the FAA can't just decide to forget about it and leave the current rules as they are. The FAA was required by Federal Law to develop new flight and duty time restrictions and rest requirements. That may not be what they want, but that's what the courts can do.
What you want, what you fight for, what you think is right, and what the courts will do are often far different things.
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While they've said it's not the goal, the only remedy left is to vacate the final rule and leave the FAA to start over from scratch. Mind you, the FAA can't just decide to forget about it and leave the current rules as they are. The FAA was required by Federal Law to develop new flight and duty time restrictions and rest requirements. That may not be what they want, but that's what the courts can do.
What you want, what you fight for, what you think is right, and what the courts will do are often far different things.
.
Tony, you and I want the same thing (even though I'm furloughed from a Supplemental Carrier and hosed either way). We only disagree on how we get there. Based on my own personal history on how screwed up politically ALPA is, I'm just not as confident as you are when it comes down to ALPA tactics (or goals) in this fight.
Like I eluded to in an earlier post, the Elephants greatly out number the Freightdogs in this fight.
02-13-2013, 11:40 AM
#24
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Joined APC: Nov 2005
Position: Directly behind the combiner
Posts: 4,948
Originally Posted by FlyAstarJets
Using this same logic, you can not predict how the FAA will respond either.
Tony, you and I want the same thing (even though I'm furloughed from a Supplemental Carrier and hosed either way). We only disagree on how we get there. Based on my own personal history on how screwed up politically ALPA is, I'm just not as confident as you are when it comes down to ALPA tactics (or goals) in this fight.
Like I eluded to in an earlier post, the Elephants greatly out number the Freightdogs in this fight.
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02-13-2013, 01:29 PM
#25
Gets Weekends Off
Thread Starter
Joined APC: Apr 2007
Posts: 222
Originally Posted by TonyC
No, but there is a provision to use FRMS (Fatigue Risk Management System) to prove that 5 consecutive night hub turns is as safe as a limit of 3 so that the rule could allow them, and a 2-year implementation period to allow the time to perform the studies and provide the proof.
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Hub-Turns and FAR Part 117
May 10, 2012
May 10, 2012
There is a popular misconception that FAR Part 117 rules for Flight and Duty times will destroy week on/week off flying. That’s just not true. Let’s consider the MEM A300 June 2012 Schedule:
1) FAR 117 allows up to 5 consecutive nights as long as the crews receive 2 hours in a suitable accommodation (sleep room or recliner room. Click here to view FAR 117).
2) That means a total hub-turn time of at least 3+30 (30 minute postflight+2 hour rest+1hour flight planning).
3) For the June 2012 MEM A300 schedule that equates to 82% of the sort facility hub-turns would meet the requirement for 5 consecutive nights.
4) The cities that did not are the likes of MEM-YYC, MEM-BUR, OAK-AFW and ORD-AFW, all of which are much higher block and some of which are only built for 3 consecutive nights now.
02-14-2013, 10:49 AM
#27
Gets Weekends Off
Joined APC: Oct 2006
Position: MD11 CPT
Posts: 1,077
But ALPA has a really cool magazine, controversial lanyards and has really looked out for their furloughees. Well at least one of those statements MIGHT be true.
Last edited by Sideshow Bob; 02-14-2013 at 11:14 AM.
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