Cargo Under Part 117 Effort Accelerating
 

Bingo! This is a feature of 117. No one is required to extend beyond 30 minutes.


According to fedex’s response to the 117 NPRM, their biggest issue was the inability to do more than 3 consecutive night hub turns without providing at least 2 hours of rest. They didn’t mention anything about extensions.

Also, I’m not sure you understand the extension limitations. If you do decide to extend beyond 30 minutes, you can continue with regular rest (minimum 10 hours) after each duty period until you reach your 30 in 7 limit. Then you require 30 hours anyway. So unless there are operational emergencies for two or more consecutive nights, it’s not an issue. And even in those situations, you can extend 30 minutes on each duty period.

One level of safety, PERIOD. FDX will work out our schedules just fine.

I flew under 117 for years. I understand how it works.

What I see is guys getting removed for a trip because there is ample reserve instead of being asked to take an extension. they get extra time in mem.

I see guys who took an extension getting removed from subsequent flights for 30 hrs rest. They can either commute home and induce more fatigue with a round trip commute, or they also get to stay in Memphis.

I see more apt stbys on days with less than perfect weather.

When I’m hub turning during an oe I’m asleep for a large portion of that extension. For guys, like me, who sleep I don’t see a huge issue. For the vampires who don’t, I see longer sits on a regular basis to accommodate that rest opportunity, which they’ve said they don’t want.

I’ve got the stones to speak up when tired. I just don’t see near the gains to make up for the possible consequences.

Exactly. We should not be defending a scheduling B-scale. Being in a different safety tier also opens us up to being carved-out of future safety changes as well, not just scheduling.

By cargo being cutout of Part 117, we could be made to lead in reduction of ULR RFO pilots required - among the many situations that I can personally imagine.

One Level of Safety.

What evidence do you have of any other carrier deviations? Remember, the FAA hasn't even approved removing the oxygen mask restriction even though it is a LAW. Add the 737MAX problems and I think they'll be a bit cautious and against the idea of pilots and company requesting a deviation from "science based rules". Speaking of that, how in the world can you say that we would be able to request something that is as safe as "science based"? That's not possible - science is science. So either it's safe and scientific or it's not. Changing things for convenience isn't going to be allowed. So we are going to say that we believe all of the rest of 117 is "science" but we have some data that shows we don't appear ot have more accidents on a 4 night WOCL inclusion? That makes zero sense.

If you've got some examples of other industry deviations please post them.

Yes it would. You would no longer be faced with the daily ops emergency to limits. But how often does that happen? you should ask you reps to see the data - they have it all. And then ask if it's a worthy trade off for what you lose. You always retain the ability to call in fatigued and most guys that are fatigued are not out of duty limits - in fact most disputed pairings on the FRMS track would still be legal in a 117 world - doesn't mean they aren't fatiguing. Got a bad night of rest on a 24 hour rest period followed by a 12 hour day? You'll still have to call in fatigued. It's a gamble - guys who think you won't lose anything or just ignorant - there's a lot of hard data out there as to what you will lose and the biggest thing being the incredible flexibility we currently have.

This is the big strategic gamble - I think you could be correct about carve outs but keep in mind we are carved out of far more things than 117 - security, airport requirements are a few that come to mind. How's that secondary barrier working out for you? What about the animal handlers in the cockpit? Airports with poor AFFF requirements - so the FAA doesn't seem to have a problem carving us out of that so I see no reason why carve outs won't continue...even to the drones, remote operated, etc. If industry wants it, it's very hard to fight it without something like the Colgan crash.

Good points. I think there's no question hub turn sits will extend - that's good for some but that also means longer duty periods in the WOCL - bad for many. That's a guarantee - you won't be able to bid around that. All the other things you mentioned are highly likely and would be largely detrimental to many in the crew force here.

Be careful what you wish for. Ask your reps sometime how many Fedex pilots participated in the 117 call to action - and that should give you an idea about how strong the support here is (it was incredibly low).

The fact is you not anyone doesn’t know thats what scheduling would do. It doesn’t make any sense at all to put a reserve on a trip if one is not required. If the pilot isn’t willing to extend beyond 30 minutes, then they have no choice than to replace that pilot. The whole point is to PREVENT a pilot from operating fatigued. That’s the whole point of shorter duty periods. And like was already explained, no one is required to extend beyond 30 minutes, which is the only time the 30 hour rest provision before the pilot can extend beyond 30 minutes again. So no one would be required to have to possibly contend with that if they don’t want. What is the down side to that?

Plus, even if you are removed, you still get paid. And we should still get a hotel if one was going to be provided anyway. I do agree that there will probably be more airport standby. That’s to protect for the instance when the science based regulation predicts the pilot would be fatigued. And that’s the whole point of the regulation, to prevent fatigue BEFORE it happens.

As for pilots not being able to sleep during hub turns, I get it. Some pilots can’t sleep well during daylight hours, some can’t AM out and backs, some only do day flying. I’ve don’t all these types and prepare differently for each. Same will stall happen under 117 except for that less pilots will find themselves operating fatigued than compared to now.

Cargo Under Part 117 Effort Accelerating
 

If you read the documents that the MEC put out, you would have read the examples they gave: exceeding FDP limits for ultra long range flights, modification of the requirements for class 1 rest facility, as well as modification of placement of prescriptive rest on augmented flights. It’s all data driven through the 117 FRMS. It has nothing to do with oxygen regulation promulgation or the MAX. It’s approved through FDX’s FAA management district office, not FAA National.



The whole point of 117 is to prevent fatigue before it happens. Because it’s known to be insidious, impair judgement, and come with tons of human factor issues dealing with outside pressure. Under 117, you still retain the ability to call in fatigue and you can do it in a proscriptive manner as well as that is explicitly the reason for the regulation. In other words, you can call in fatigue even if you aren’t currently fatigued but feel like you may be fatigued before the flight is complete.

I do think that there will be “losses” and less flexibility. I’m ok with trading that for the added safety of 117.



This is true. Should we just capitulate? How many of those things are good for pilots? All those carve outs were paid for by cargo airline management lobbying. And that includes the current push for 117. That’s because cargo airline management paid millions to carve us out. None of that money is spent for the pilots’ benefit. So it’s not the FAA carving us out of all these things. It comes from way above the FAA. At some point we need to make a stand. ALPA has decided to do that now on the dawn of single pilot operations. If not now to prevent that, then it might as well be never.