I'm not arguing with you, just posting an interpretation still on the FAA site. The Hryniw interpretation says that "The RAP ends when a flightcrew member is either released from the RAP by the certificate holder or assigned to an FDP." So you aren't on both a RAP and FDP at the same time. And the FDP starts only when the RAP ends.

 

Thanks for the update and researching this. Honestly, this is now how I viewed it at all based on the the post below. If what is posted below is true, then I'm not sure why our committee would interpret it the way you were told unless they had something from the FAA giving that interpretation. It's talked about in sched alert 19-11 as well.

 

There is also this, which seems to read even more clearly than the other references I posted.

SRH Pg 147 (a vetted document)

"Rest Required Prior to Reserve
FAR Part 117 requires two basic rest periods for reserve pilots:
-A minimum of ten hours of rest immediately prior to the start of an FDP or RAP. The ten hours of rest must provide a minimum of eight hours of uninterrupted sleepopportunity.Note: The ten hours of rest prior to the start of an FDP is not required for an FDP that begins during a RAP.
-30 consecutive hours of rest (free of duty) in the 168 hours immediately preceding the start of ANY FDP, RAP, or airport standby reserve"

There is no note or exception anywhere I can find saying that the start of a RAP would remove the 30 in 168 requirement for an FDP. There is the note about 10 hours rest not being required prior to FDP if it begins during a RAP, but no such note for 30 in 168. I feel like the omission of such a note, in the presence of the other note, speaks pretty loudly that 30 in 168 is required for ANY FDP.

 

I'm sending a followup DART bringing the FAR defintions and SRH sections as well as the Hryniw interpretation mentioned to see if they can provide the what source document they are using to back up their interpretation.

I'll report back when I hear back from them.

 

Thank You!

What's a Hryniw? edit: nevermind, it was the guy's name in the FAA letter.

 

Here is the paraphrase of the response I got back.

1) this has been talked aboud industry wide for years

2) the purpose of RAP is to be able to assign a FDP without having to first give an intervening rest period. Said another way, assign an FDP without giving the notice as required under the definition of LC reserve.

3) Why include "reserve" in the requirements of 117.25(b)? If 117.25(b) could preclude the assignment of an FDP during an otherwise legal SC RAP, then requiring 30/168 before starting the RAP becomes redundant.

4) The Hryniw letter doesn't provide any clarificaiton outside the exisit text of the regulation. No other legal interpretations (they he knows of) have been released since the Hyrniw letter. A few years back the FAA stated they were no longer in the 117 "interpretation business" and that while they would potentially respond to individual questions, they were no longer going to publish answers for the industry as a whole.

5) He did say he would forward my question to ALPA National FT/DT Chair to see if they have any additioanl info from that level.

If I hear back with any additional info from the National Commitee, I'll post here.

 

Interesting, but still ambiguous reponse. I take particular issue with #3. There is a perfectly good (well, not good for pilots) reason to assign a legal RAP that is not useful for an FDP.... that would be for a DH-only duty period into 30 hours rest.

Thanks again for chasing this. I'm still wondering if I should follow up the STS response I got when I was assigned a reserve trip because they skipped the pilot ahead of me on account of this exact issue. They were legal for the RAP but (according to 2 schedulers and my first STS response) not legal for the FDP due to 30/168.

 

Every one of those RAPs pays me an hour. CS can F up stuff as much as they like, it usually results in more $ for me.

 

[QUOTE=Klondike Bear;3873340]I had this exact situation last week. I sent an STS inquiry about it. ALPA said I was due money and to fill out an STS report about it. I would suggest doing the same. If it costs them money they will quit doing it.

There is a SC log on Icrew you can look at to see if others yellow slipped them. I didn’t know about that log so I think others might not as well.[/
QUOTE]

I did not know this either - where is this?

Thanks Scoop

 

[QUOTE=Scoop;3876242]Schedules - open time menu - display short call assignment history