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Change My View - Part 117

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Old 01-17-2020, 12:05 AM
  #101  
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Originally Posted by Sluggo_63 View Post

Bavk then the rallying cry was "Science based work rules!"


Then the FAA came up with science based work rules. And we were cut out at the last minute. The NTSB was against the cut out because of the cargo accidents they investigated. But your magnanimous and gracious employer spent big bucks along with their cohorts to get us cut out. Remember how upset the crew force was at the cut out? Remember writing letters to Congressmen? Remember feeling jaded and "less than" our brothers at the passenger carriers?
A couple of points Sluggo - First, plenty of us here have been vocally wary of 117 from the start. I never bought into the knee-jerk indignation to the cargo cut-out and I never wrote a letter to any politician.


We wanted the Ender's report to use in order to support negotiating effective, fatigue fighting measures into our CBA. There's a big difference between that and taking a one size fits all FAR change and fixing one tiny portion of that CBA at the expense of several others thanks to unintended consequences resulting in an overall QOL reduction.


Originally Posted by Sluggo_63 View Post
Can you imagine a world with no more Operational Emercencies taking you to FAR limits? Can you imagine ending the "legal to start, legal to finish"?


So now that we have a chance to actually get science based backstops to protect us all I hear is "bUt My CoMmUtE..."
I think it would be a HUGE mistake to adopt 117 just to have those two specific issues addressed at the expense of many other FedEx unique QOL aspects we currently enjoy (many of which have fatigue mitigating benefits of their own). How many of our pilots deal with going to FAR limits or legal to start/legal to finish on a regular basis? Sure it happens, but not enough to support the potential negatives and unknowns. Since our CBA is already very 117 compliant, there's just not that much it's going to do for us. Risking unintended consequences to our QOL over two infrequently encountered scenarios that can be addressed with a fatigue call doesn't seem too smart to me.
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Old 01-17-2020, 03:37 AM
  #102  
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Originally Posted by Noworkallplay View Post
What would your career look like at FDX if ALPA wasn't on property? Do you think you would still have a pension? What do you think your schedule would look like? What do you think your hourly rate would look like? Comments like yours are ill educated. Which side has fought for you and your career and which side has tried to take?
A collective negotiating body has helped. But we’d still have a pension. A pension was part of our very first contract. Other airlines lost that through bankruptcy. It doesn’t matter what union, its only as strong as its membership. We’ve been sold out by our union leadership for over 25yrs. We will get the status qou. And our union will sell us on a pension give away. Veba, I keep paying that.
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Old 01-17-2020, 05:03 AM
  #103  
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Originally Posted by magic rat View Post
This is going to cost the company money, period. That’s why they don’t want it.

When end an ice storm hits EWR, flights get cancelled, people get stuck. Pax carriers recover their ‘freight’ the next day. When it hits MEM, operational emergency card get played, and it’s a long day. 117 kills the option for them to play that card. Our freight won’t get delivered, that’s lost revenue. They’re going to have to stand up more reserves to cover the pilots timing out.

Everything the company does is done with money in mind. Simple.
We currently have plenty of reserves we just never use them because we just extend and reroute line holders. 117 would force the company to use reserves properly.
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Old 01-17-2020, 12:04 PM
  #104  
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Originally Posted by Noworkallplay View Post
If you have a maintenance or weather delay that cuts into your rest opportunity they do not have to delay your departure to give you the two hours. The company must “build” the pairing that way only. This question was answered in a clarification letter from FAA legal on Nov 5, 2014

https://www.faa.gov/about/office_org...rpretation.pdf

Doesn't actually answer the question.
Question is I'm scheduled for 4 consecutive DP's that infringe upon the WOCL, in order to do that, all of those FDPs must have a 2 hour rest period during Each of those FDPs.

Example that you provided had WOCL's on FD 1,2 and 4, with no WOCL infringement on FDP3. No 2 hour rest period provided on FDPs 1,2&4. Due to a delay, FDP3 infringed on the WOCL, would Pilot still be legal for 4.
Answer provided was a Yes, but maybe No if FDP3 wasn't scheduled realistically.

This is the verbiage from FAR 117.27
A certificate holder may schedule and a flightcrew member may accept up to five consecutive flight duty periods that infringe on the window of circadian low if the certificate holder provides the flightcrew member with an opportunity to rest in a suitable accommodation during each of the consecutive nighttime flight duty periods. The rest opportunity must be at least 2 hours, measured from the time that the flightcrew member reaches the suitable accommodation, and must comply with the conditions specified in § 117.15(a), (c), (d), and (e). Otherwise, no certificate holder may schedule and no flightcrew member may accept more than three consecutive flight duty periods that infringe on the window of circadian low.

Nothing in that leads me to believe the 2 hour rest is simply a Scheduled time, or waivable.
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Old 01-17-2020, 12:06 PM
  #105  
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Originally Posted by Noworkallplay View Post
We currently have plenty of reserves we just never use them because we just extend and reroute line holders. 117 would force the company to use reserves properly.
Interesting perspective.
Think we have plenty of reserves right now because we've hired a lot of people, and reduced flying hours.

Think base replacements would be a lot more likely than FedEx simply going to a Reserve pilot when there's a delay pushing a pilot to Operational Limits
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Old 01-17-2020, 02:18 PM
  #106  
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Originally Posted by kronan View Post
Doesn't actually answer the question.
Question is I'm scheduled for 4 consecutive DP's that infringe upon the WOCL, in order to do that, all of those FDPs must have a 2 hour rest period during Each of those FDPs.

Example that you provided had WOCL's on FD 1,2 and 4, with no WOCL infringement on FDP3. No 2 hour rest period provided on FDPs 1,2&4. Due to a delay, FDP3 infringed on the WOCL, would Pilot still be legal for 4.
Answer provided was a Yes, but maybe No if FDP3 wasn't scheduled realistically.

This is the verbiage from FAR 117.27
A certificate holder may schedule and a flightcrew member may accept up to five consecutive flight duty periods that infringe on the window of circadian low if the certificate holder provides the flightcrew member with an opportunity to rest in a suitable accommodation during each of the consecutive nighttime flight duty periods. The rest opportunity must be at least 2 hours, measured from the time that the flightcrew member reaches the suitable accommodation, and must comply with the conditions specified in § 117.15(a), (c), (d), and (e). Otherwise, no certificate holder may schedule and no flightcrew member may accept more than three consecutive flight duty periods that infringe on the window of circadian low.

Nothing in that leads me to believe the 2 hour rest is simply a Scheduled time, or waivable.

Read the last paragraph on page one. Its very clear. Its scheduled.... So as long as its built that way its ok if an irop cuts into it as long as it was built within reason.
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Old 01-17-2020, 02:19 PM
  #107  
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Originally Posted by kronan View Post
Interesting perspective.
Think we have plenty of reserves right now because we've hired a lot of people, and reduced flying hours.

Think base replacements would be a lot more likely than FedEx simply going to a Reserve pilot when there's a delay pushing a pilot to Operational Limits
And once again that pure speculation. It would not make sense to do it that way nor have any other airlines done it that way.
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Old 01-17-2020, 03:20 PM
  #108  
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Originally Posted by Noworkallplay View Post
Read the last paragraph on page one. Its very clear. Its scheduled.... So as long as its built that way its ok if an irop cuts into it as long as it was built within reason.
Nope that is not correct. You seem to be using the old legal to start, legal to finish idea that 117 got rid of. If it infringes upon that extra WOCL you will be illegal for a 4th. That is clear.

Furthermore it appears that scheduled rest during the WOCL period in order to go beyond 3 nights, can not be reduced - that's right. So if the company wants to build a 3 hour behind the door (4:30 turn) and you get a late departure, you must extend your next departure to keep the 4:30 turn....or more likely, you get revised into a different pairing and some guy that was only a single night flight for example has to take your pairing to keep it all legal and productive. There will be a lot more revisions and as Adledriver said earlier, a LOT less flexibility with your schedule as you will only be able to swap into trips that have that 3:30 turn.

Used to getting some layovers you don't like and trying to swap them with trips in OT? It's going to be a lot harder now - and the company won't care at all about that.
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Old 01-17-2020, 03:21 PM
  #109  
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Originally Posted by Noworkallplay View Post
We currently have plenty of reserves we just never use them because we just extend and reroute line holders. 117 would force the company to use reserves properly.
Also wrong. Look, you said you flew under partial 117 before coming here so that means you've only been here a short amount of time. We used to have a ton more reserves and now we have a lot less - you can read all SIG notes to find out the ratio.

That's not a reason to be against 117 I just want to make that clear. OBTW I don't think you "remember" the PiBS notes either as they were before your time.
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Old 01-17-2020, 03:30 PM
  #110  
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Originally Posted by Noworkallplay View Post
And once again that pure speculation. It would not make sense to do it that way nor have any other airlines done it that way.
There are a lot of considerations here that should be factored in. Frankly it may be too late but it adds to the understanding.

1. SIG reviews of the percentage that are legal are several years old - at least 4 - not a single recent bid pack has been looked at yet.
2. Flexibility will decrease - the 56 hours in domicile following most intl trips was mentioned before ANY follow on duty - that's anything - training after a BEDH, a single day of ASBY - anything. Ability to swap trips if you're on a greater than 3 night WOCL line will be greatly reduced. Expect more revisions for everyone - one of the biggest complaints guys have now - expect more.
3. I'm all for reducing duty time extensions but I would like to see some data on how often guys get extended to limits. Anyone have any? I've asked but received no answers.
4. Here's a big one - many night hub turn weeks start with a Jumpseat into base - that first night is still a WOCL incursion and you must have 2 hours of uninterrupted rest prior to that first event. So currently you jumpseat in with say 2 hours between landing an show time? Won't be enough - you'll likely have to land 2:30 prior and have a sleep room available - will the company make more sleep rooms available to jumpseaters? What's their incentive when they can just require you come in on the afternoon flight and sleep on your own.
5. AMOCs - Company can apply for any AMOC they want - so we like the limits on duty extensions, nothing stopping them from applying for an AMOC with the argument that the current FRMS is good enough.

Of course the Company doesn't care about us and they are going to do what's best for them. But don't think that this is some obvious win. It could in fact be safer (the entire science idea is a bit squishy though - ask your rep about that when you get a chance) but may end up forcing you to work more days for the same pay and decrease flexibility in how you work. Would that be a win for pilots? I think the most likely thing, without early AMOCs benefiting the Company, is that you would never see any more than a 3 night WOCL incursion - if weekend layovers or 36 hours off in between, or the notorious flip flops work, then those are possible too but protecting the freight will always be their number one goal.

So right now a lot of the well rested part is on you - commuting in, deviating with enough rest, resting during a hub turn or not, getting ready for your week of hub turns in advance, etc - now it will be hard scheduled with no ability to waive the requirements. I'm not advocating either way but the idea from a few guys that this is some sort of obvious win for the pilots is short sighted and not effectively researched.
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