For this scenario, let's assume you were not used in your first 4-day block, and never properly notified.

Are the 'legalities' in the middle of my post correct?

 

ALPA stance (as stated numeroud times by outed Sched Chair SK on the widget sched page) is that legal to start RAP, legal to finish. So in your scenario, you could except a FDP (non DH only) between 1800-2100 of the SC).

I would be interested to hear what an actual ALPA 117 Rep says

 

I still question this stance and would also LOVE to hear an official ALPA stance about it. It seems pretty black and white to me in FAR 117...

Quotes from FAR 117:

FAR 117.3 Definitions
Reserve availability period (RAP) means a duty period during which a certificate holder requires a flightcrew member on short call reserve to be available to receive an assignment for a flight duty period
Flight duty period (FDP) means a period that begins when a flightcrew member is required to report for duty with the intention of conducting a flight...


FAR 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.


To me, the "OR" in 117.25 is critical. As in, the same sentence can be read through as a result of the "OR", as in:

Before beginning any reserve period a flightcrew member must be given at least 30 consecutive hours free from all duty within the past 168 consecutive hour period.

Before beginning any 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.


To me, they are seperate unique requirements, and being legal for one does not make one legal for the other. ALPA please?

 

I'd love to hear an ALPA 117 guru chime in as well.

This is why I differentiated between what I could accept before and after 1800: the "OR". I could defend legal to start (and complete) a RAP, and legal to start (and complete) a FDP that REPORTS prior to 1800, but not after.

After 1800 I cannot look back 168 hours and see a 30-hour prospective rest period, thus I don't believe I'm legal to start a FDP (even out of a RAP) after 1800.

Since a DH-only duty period has been determined to NOT be a FDP, and that means that I could accept that right up to the end of the RAP.

Again, an ALPA 117 guru, please chime in.

 

I sent DART to DALPA FTDT and this is their response.

“Great quesiton! The inteprretation is that if a pilot is legal to start a RAP then they are also legal for an FDP that reports within that RAP - even if the FDP report time would otherwise not have the 30/168 lookback.”

 

Lol wut, is this serious? Is that an interpretation from someone in the FAA, or otherwise in a capacity that carries the same weight?

 

It’s from Delta ALPA FTDT committee…the people we pay dues to be the SME on 117 issues. I didn’t ask them to provide the source at the FAA that allowed them to come to that interpretation.

And the interpretation matches what ex Sched Chair SK has stated on the widget scheduling page numerous times.

My understanding is the interpretation changed a few years back to where a FDP that reports within the RAP is considered part of the RAP, therefore legal to start, legal to finish.

 

Would be nice if they provided the reference letter of interpretation written by FAA council.

 

Send them a dart and ask for more info…my dart was answered same day and it was even after business hours.

 

Very odd. The closest document I could find from ALPA that references this issue is Scheduling Alert 23-08. It states:

"It’s entirely legal for you to be a long call pilot for greater than seven consecutive days; however, you cannot legally begin a RAP or report for an FDP without first receiving an additional 30 hours of rest."

Again... OR report for an FDP. Can't Start a RAP, can't report for an FDP, without 30 in 168. Would love to see another scheduling alert that clarifies this.

EDIT: I'll throw in another reference that seems even more un-ambiguous:

SRH Pg 147

"Rest Required Prior to Reserve
-30 consecutive hours of rest (free of duty) in the 168 hours immediately preceding the start of ANY FDP, RAP, or airport standby reserve"