Unknown Rider

What was painful about it?

FXLAX

Actually, they did in fact point out the three specific examples in a document that was attached to one of their blast mails. Here is an excerpt of it:

“The AMOC would need to meet or exceed the safety standards set forth by the prescriptive limitations.
Existing carriers operating under FAR 117 have applied the FRMS approach and have received AMOCs to exceed the flight time and flight duty period (FDP) limits to operate ultra-long range (ULR) flights, modify the requirements for a Class 1 rest facility, as well as, modify the placement of prescriptive rest on augmented flights. In each of these cases the carrier proposes to the FAA an AMOC and data collection plan to show the desired operation under the AMOC can be flown as safe or safer than the current prescriptive limitations of FAR 117. This is achieved by adding mitigations to address fatigue such as increasing the required rest prior to, during, and after a pairing sequence, requiring 2 captains on augmented flights and having more stringent fit for duty (FFD) verifications prior to each flight under the AMOC.”

There are more than mere examples. And they aren’t necessarily wishes as these don’t seem to even address the company’s biggest concern, more than 3 consecutive night hub turns. They were clearly mentioned to show that AMOCs are not a unicorn. And of course no one could event promise an AMOC. That wasn’t the point of me mentioning it. I merely answered the question that was asked. Sure, ALPA doesn’t apply for AMOCs. That process is part of 117s specific FRMS requirements that ALPA does have been a part of. AMOCs are driven by actual data. That data is proprietary and would only apply to that specific airline. But knowledge of other airlines’ having AMOCs for certain things is not proprietary.

I’ve read it before and now I just read it again.
I stand by what I said, 110%. No one can compel either pilot to extend beyond 30 minutes. I worked under 117 for many years. They cannot ever force you to go beyond the 30 minute extension. But of course they may want to know the circumstances. That doesn’t change in 117 versus 121.

Tuck

ug you're killing me. Listing the process is not pointing out a specific AMOC. Feel free to call any MEC members and ask th em about it - there are no examples. They have an idea of what it may take (largely from FAA documents) to get one - they have no practical idea if these are things that can even be done or have been done. Although there undoubtedly are some AMOCs out there we really have no idea how they got them, whether ALPA was involved in getting them or how long/difficult the process was.

FXLAX

You said, specifically, to show evidence of AMOCs. I pointed you to the evidence you were asking for by listing three actual real life examples that came from the MEC itself. The MEC communication listed those as current AMOCs in use, not as examples of ones that management can peruse. So you saying there are no examples and asking the MEC about it are not true. Then you said that the MEC has no idea what it takes to get an AMOC (and I don’t think the MEC said they know how to get one). You moved the goal post.

I don’t care about AMOCs. My position is pro-117 as written. If an airline can use data obtained through the 117 FRMS (collaboration between management and ALPA), and convince the FAA an equivalent level of safety with specific mitigations, then I’m fine with that as well. It’s data driven. It’s not something that can be copied and pasted from another airline. It’s not a matter of knowing how to do it. It’s a matter of seeing the operation’s specific system form data and seeing if there is a “better” way of accomplishing the flight(s) with the same level of safety. It’s a case by case basis, not something that you can just copy from another airline or even from a different aspect of your airline. In other words, there is nothing to “know” ahead of time. The actual processes are spelled out in the FRMS. The data and mitigations come from the specific operation. It’s not rocket science. It’s something that the FAA has done for years. If there were any questions, the FAA people are there to help.

Personally, I feel it’s not a good argument for the MEC to make. Either they are for 117 as written or not. AMOCs are just tools that management may try to use to modify a specific rule. It’s not something they would do unless it benefits the operation, which isn’t always in line with the pilots’ benefits.

Tuck

This is getting absurdly frustrating. Last post on this subject. You keep coming back to the three specific exact AMOCs the MEC listed and then you listed above. YOU DID NOT DO THAT - NOR DID THE MEC. There are none - zero examples of an AMOC. An example is not "this is how we think you apply for one" - an example is "carrier xx got approval to regularly go beyond scheduled limits on weekends flying out of xx airport because of xx" - that's the example. They have no example - that's why they say "existing carrier have...." and can't produce one. It's what they THINK could work from reading the FAA short one page guidance on how to apply - that's it. What we don't have are any examples of whether they actually work. There's a law passed that says oxygen mask regulation shall be changed by the FAA no later than October 2019. We're 6 months passed that and it hasn't happened - there's an example for you of how you think things should work, but actually don't. Go back and re-read what you have posted, re-read the MEC's communications and then list for me an exact example from a carrier (carrier name would even be better). If you can't do that then you have no examples - you just have an idea of how it may work (like the oxygen mask story - we think we know how things might work but then they actually don't work that way in real life).

FXLAX

I re-read the MEC blast mail and the document they provided. I stand by what I’ve said.

The MEC gave three specific actual examples of real AMOCs granted to real existing airlines by the FAA. Like I said, you keep moving goal posts by now asking for “carrier xx got approval to regularly go beyond scheduled limits on weekends flying out of xx airport because of xx.” Go ahead and choose to look the other way just because the real life example was not given out in the specific amount of detail you now want. If you believe there are no AMOCs issued to any airline for deviations to 117, then I don’t know what to tell you.

And again, the FAA national office not promulgating regulations has no correlation with a specific regional FAA office assigned to a carrier (and associated inspectors) issuing a deviation in accordance with the FRMS.


Edit: I remembered reading something from ALPA years ago about Delta being issued a 117 AMOC, so I googled and found this. Read the parts that say FRMS versus non-FMRS. The FMRS sections are the rules of their two AMOCs, which happen to coincide with two of the examples given by our MEC in the communication I referenced for you. The non-FMRS are 117 compliant, meaning a deviation per their FRMS is not used.


https://www.alpa.org/-/media/DAL/Doc...de-FAR-117.pdf

FXLAX

And if that isn’t good enough, with more internet searching, I found this for you, about a couple dozen exemptions to 117 granted by the FAA:


https://aes.faa.gov/?Regulations=117...=3&AscDesc=asc