FAR 117 Effect
#12
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From: B757/767
One of the guys working on this at our company interprets the reg like the OP. He feels that while not specifically prohibiting same day commuting, if the commute takes longer than 2hrs, then you aren't in compliance based on the 8 hrs of uninterrupted sleep opportunity. It's really open to how you see it, but being that the company and the pilot now share responsibility for rest it wouldn't surprise me to see something like "must be in domicile 10-12 hrs prior to FDP start" being written into company manuals. And if you commute via air, then CASS becomes the tattle tale. Hopefully this doesn't happen.
#13
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From: CL-65
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.
Suitable accommodation not middle seat in the back.
From a company standpoint your 3 days off is a 72 hour rest period. I think pilots will have to be in base 10 hours prior to show. I have not been through the company training program so I wonder how our POI and training department will interpret FAR Part 117.
#14
One of the guys working on this at our company interprets the reg like the OP. He feels that while not specifically prohibiting same day commuting, if the commute takes longer than 2hrs, then you aren't in compliance based on the 8 hrs of uninterrupted sleep opportunity. It's really open to how you see it, but being that the company and the pilot now share responsibility for rest it wouldn't surprise me to see something like "must be in domicile 10-12 hrs prior to FDP start" being written into company manuals. And if you commute via air, then CASS becomes the tattle tale. Hopefully this doesn't happen.
#15
The 10 hour rest period must provide the flightcrew member with a minimum of 8 uninterrupted hours of sleep opportunity.
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.
Suitable accommodation not middle seat in the back.
From a company standpoint your 3 days off is a 72 hour rest period. I think pilots will have to be in base 10 hours prior to show. I have not been through the company training program so I wonder how our POI and training department will interpret FAR Part 117.
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.
Suitable accommodation not middle seat in the back.
From a company standpoint your 3 days off is a 72 hour rest period. I think pilots will have to be in base 10 hours prior to show. I have not been through the company training program so I wonder how our POI and training department will interpret FAR Part 117.
#17
Currently the FARs put the task of being rested mainly on the crew member. With 117 the company and pilot share the responsibility equally. With 117 crew members will be required to sign the release every leg stating they are fit for duty. I haven't read the entire reg cover to cover, but from talking with the guys working on it here, it's going to be a mess.
And regarding commuting, if your show is 8pm the company must make sure you got the required time for rest...it's up to you to make use of it. The memo that went out to our pilot group a couple of months back introducing some 117 concepts had a section on commuting. It basically said that while the regs don't prohibit it, that pilots should review their base/seat preference bids and take the new regs into account and bid according. The way the company wrote it got my attention.
And regarding commuting, if your show is 8pm the company must make sure you got the required time for rest...it's up to you to make use of it. The memo that went out to our pilot group a couple of months back introducing some 117 concepts had a section on commuting. It basically said that while the regs don't prohibit it, that pilots should review their base/seat preference bids and take the new regs into account and bid according. The way the company wrote it got my attention.
#18
Notice the use of "opportunity". Anyone who commutes will have the opportunity to get the stipulated sleep. It however does not say what the crewmember does with that said opportunity. Once again it comes down to personal responsibility. Just don't call in fatigued after commuting same day, 117 will get thrown back in your face!
#20
You guys are over thinking this.
Commuting has nothing to do with rest time. You are still "off" until you sign in.
To put it another way: these rest rules apply when you are signed in for a sequence and receiving per diem.
When signing in on day one you still have to look back 10 hours and find no duty time. Those are your days off. What you do on your days off is your business and does not interfere with 117 rest rules.
Regardless if you spent your days off golfing, commuting, sleeping, or watching porn you were still at "rest". Once you sign in its a different story.
Commuting has nothing to do with rest time. You are still "off" until you sign in.
To put it another way: these rest rules apply when you are signed in for a sequence and receiving per diem.
When signing in on day one you still have to look back 10 hours and find no duty time. Those are your days off. What you do on your days off is your business and does not interfere with 117 rest rules.
Regardless if you spent your days off golfing, commuting, sleeping, or watching porn you were still at "rest". Once you sign in its a different story.
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