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

 

This is preposterous. You need 8 hours sleep opportunity, you don't need to sleep for 8 hours. The actual language of this part of 117 does not have the reach you are affording it.

Further, you can have your 8 hours sleep opportunity before you start your commute. Commuting isn't rest, but it isn't duty.

 

It is actually considered part of your rest period.

 

You're right, I meant it's not considered sleep opportunity.

 

Yes, it is preposterous. Everybody commuting over 2 hours on day one means they couldn't have had an 8 hour rest opportunity in the 10 hours immediately preceding the FDP. The FAA knows it, the airlines know it, and the unions know it. They all ignore it, and then point to 117.25 section (f) saying that if YOU didn't get the required 10/8, YOU are supposed to notify the certificate holder so your schedule can be adjusted....

Don't ask; Don't tell.....

 

You have gone off your rocker.

10 hours is the minimum required rest period, not a rolling amount of time that you look back to see if you've gotten 8 hours of sleep within it.

You need 8 hours of sleep opportunity somewhere during your rest period, which can be no less than 10 hours. It can be before your commute to the airport.

By your logic, if you have an 1600 report time for one flight segment, and you wake up at 0900, do some chores around the house, go out to lunch with friends, then drive to the airport, you are violating 117, even if your commute is less than 2 hours. What you are saying is insane and untrue.

By the way, accusing every single pilot who lives more than two hours from their base of violating 117 on a regular basis is a very, very serious accusation. You should stop stirring up drama.

 

You can be given 100's of hours free from duty as measured from when you are released. You must have at least 10 hours rest period with an 8 hour sleep opportunity immediately prior to the FDP. Yes, you can have a rest period longer than 10 hours. The rest period must be immediately before the FDP. This portion of the rest period that is immediately before the FDP must be at least 10 hours in length, and it must contain an 8 hour sleep opportunity. That doesn't mean you actually slept. It simply means the opportunity to do so was present. The last sentence in section E says:
The 10 hour rest period must provide the flightcrew member with a minimum of 8 uninterrupted hours of sleep opportunity.


https://www.ecfr.gov/cgi-bin/text-id...7_125&rgn=div8
§117.25 Rest period.

(a) No certificate holder may assign and no flightcrew member may accept assignment to any reserve or duty with the certificate holder during any required 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.

(c) If a flightcrew member operating in a new theater has received 36 consecutive hours of rest, that flightcrew member is acclimated and the rest period meets the requirements of paragraph (b) of this section.

(d) A flightcrew member must be given a minimum of 56 consecutive hours rest upon return to home base if the flightcrew member: (1) Travels more than 60° longitude during a flight duty period or a series of flight duty period, and (2) is away from home base for more than 168 consecutive hours during this travel. The 56 hours of rest specified in this section must encompass three physiological nights' rest based on local time.

(e) No certificate holder may schedule and no flightcrew member may accept an assignment for any reserve or flight duty period unless the flightcrew member is given a rest period of at least 10 consecutive hours immediately before beginning the reserve or flight duty period measured from the time the flightcrew member is released from duty. The 10 hour rest period must provide the flightcrew member with a minimum of 8 uninterrupted hours of sleep opportunity.

(f) If a flightcrew member determines that a rest period under paragraph (e) of this section will not provide eight uninterrupted hours of sleep opportunity, the flightcrew member must notify the certificate holder. The flightcrew member cannot report for the assigned flight duty period until he or she receives a rest period specified in paragraph (e) of this section.

(g) If a flightcrew member engaged in deadhead transportation exceeds the applicable flight duty period in Table B of this part, the flightcrew member must be given a rest period equal to the length of the deadhead transportation but not less than the required rest in paragraph (e) of this section before beginning a flight duty period.

[Doc. No. FAA-2009-1093, 77 FR 398, Jan. 4, 2012; Amdt. 117-1A, 77 FR 28764, May 16, 2012; Amdt. 117-1, 78 FR 8362, Feb. 6, 2013]

 

No, in your example, you had the opportunity to sleep for 8 uninterrupted hours in the 10 preceding the FDP. You decided not to use it. Nothing wrong there as long as you can sign under 117.5 that you're fit for duty.

If somebody is commuting more than 2 hours, then they have not had 8 uninterrupted hours of sleep opportunity in the 10 hours preceding the FDP.

Example, if you went off duty on a 10 hour overnight, and the van broke down on the way to the hotel, and due to delays you were not going to get 8 hours of uninterrupted sleep opportunity you would notify the carrier and have the report time adjusted.

Show me anywhere in the exact same rest rule that says you don't need the exact same 8 hour sleep opportunity in the 10 hours preceding the duty period on day one.

The unions need to fix this. Don't ask, don't tell puts all the liability on us.

 

You are completely incorrect.

This is the part you are getting confused about: "The 10 hour rest period". It means your rest period, which must be at least 10 hours, NOT the preceding 10 hours. This part of the reg does not mean that the 8 hours of sleep opportunity must be within the preceding 10 hours, it means that your 8 hours sleep opportunity must be within the rest period, which must be no less than 10 hours.

It says which you think means the preceding 10 hours, but it says that because its referring to this part mentioned above:

Which is only saying it must be no less than 10 hours.

 

Absolutely not, lunch at a restaurant is NOT sleep opportunity. Your whole argument is that you can't have 8 hours of sleep opportunity during a commute, well you don't have 8 hours of sleep opportunity at a restaurant. Why is commuting different? Its something you voluntarily do just like going out to lunch.

This isn't the way laws work. Something is legal when there is no law that prohibits it, not the other way around. No where in Part 117 does it say that the 8 hours of sleep opportunity must be within the preceding 10 hours. It says your rest must be at least 10 hours, and within that rest period, you must have 8 hours sleep opportunity.

This is the part you are confused about. You are confusing "preceding 10 hours" with the preceding rest period, which must be at least 10 hours. The 8 hours of sleep opportunity does not have to be in the preceding 10 hours of rest.