Cujo665

You are misunderstanding, as most do.

Commuting yourself isn’t Duty, but it also isn’t rest. You are free from duty, but haven’t had an 8 hour rest opportunity if you commuted in from home and it took more than 2 hours to get there. You need 10 free from duty, and an 8 hour rest opportunity immediately prior to starting the FDP. Jumpseating (even in a cabin seat) is not rest. Read the FAA interpretations.

Cujo665

That is incorrect. You have a dual obligation with the company to ensure legal rest prior to beginning an FDP. That requirement is 10 hours free from duty, with an 8 hour rest opportunity prior to beginning the new FDP.

On day one, you have been provided with plenty of time free from duty since you’ve been on days off. it’s up to you to ensure you had an 8 hour rest opportunity in the 10 hours immediately preceding the start of the FDP. You can’t do a look back and find that if your commute was over 2 hours. Do you have to actually sleep/rest 8 hours.... no, but you must have the 8 hours of rest time available to show.... and commuting yourself to work jumpseating is not rest.
Look it up

117.25
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.


So.....
Per (f) if your commute was over 2 hours, you didn’t get the required 8 hours sleep opportunity in the 10 hours immediately preceding the FDP and are not legal to begin.

9Etransplant

Per the regs:

“Rest period means a continuous period determined prospectively during which the flightcrew member is free from all restraint by the certificate holder, including freedom from present responsibility for work should the occasion arise.”

The carrier is not restraining a crewmember during a commute since it is not scheduled by the carrier.

Question and answer 74 here also provide additional clarification.
http://www3.alpa.org/portals/alpa/committees/ftdt/FTDTGuidePart117_May2015.pdf#page25

Cujo665

Commuting isn’t rest. You can’t pick which sections you want to comply with and ignore the others. The air carrier is not always the cause of a legality, in the case of commuting it’s the pilot causing the legality. Both have a responsibility for compliance.
Go read the interpretations.

Read the bottom of page 1
http://www3.alpa.org/portals/alpa/co...owney-2014.pdf

Did you read your own publication? Read the question right before the one your referencing. Read #73 Answer part 2.

Question #75 specifically addresses what happens when travel time prevents an 8 hour sleep opportunity in the preceding 10 hours.

In the case of a commuter, the company has provided more than 10 hours free from duty on day 1. The pilot has decided to commute to base during that 10 hours. If the commute is longer than 2 hours the pilot no longer had an 8 hour sleep opportunity in the preceding 10 hours and per the interpretation is required to notify the certificate holder.

The requirement of 10 & 8 prior to beginning any FDP applies to all FDP’s.... not just the ones after you report on day one.

rickair7777

It is if you need it to be. Forcing pilots to sleep for eight hours immediately prior to duty is not legally enforceable under the current construct. You're reading things into it that aren't there.

If you screw up and fatigue can be inferred because of unreasonable behavior on your part, that is enforceable.

9Etransplant

Commuting isn’t duty.

“Duty means any task that a flightcrew member performs as required by the certificate holder, including but not limited to flight duty period, flight duty, pre- and post-flight duties, administrative work, training, deadhead transportation, aircraft positioning on the ground, aircraft loading, and aircraft servicing.”

Lvlng4Spd

If commuting were in conflict, then my own carrier and many others would be implicated in the event of a mishap. I can't tell you how many times I have received a positive space commute to cover flying. This, after being at the airport already for 3-5 hours so I could make my first attempt. Contracts are now ratified including positive space for the second attempt. Where should the blame lie then? Sure, there are commuter hotels offered too, but many don't use their quota. No way I'm coming the night prior for my 1pm show.

Cujo665

[QUOTE=Lvlng4Spd;2500750]If commuting were in conflict, then my own carrier and many others would be implicated in the event of a mishap. I can't tell you how many times I have received a positive space commute to cover flying. This, after being at the airport%

Cujo665

Read the rest rules. Show us anywhere where it says the required 10/8 doesn’t apply on day 1.

If you’re commuting over 2 hours, by definition you didn’t get the 8 in the 10. Then read the rest rules again about required notification to the certificate holder when you didn’t get the 10/8.

rickair7777

"Rest opportunity" is what the company must provide to you.

Nothing in the regs specifies when or how you make use of it. When on an overnight you are not on "lockdown" in your hotel room for eight hours prior to show. Many of us were very concerned when 117 was being developed that the rules might be applied to commuting but that did not happen. The airlines were behind that, they didn't want to pay junior pilots enough to live near JFK, IAD, SFO, LAX, etc.

Also, practically speaking, a pilot coming off of days off can be sufficiently well rested to do a moderately long commute and still work a long day. But the pilot has control over that.