FAR 117 Effect
#51
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SFO's longitude is 122° 22' 43" W
JFK's longitude is 73° 46' 56" W
A difference of less than 60° longitude.
ALPA's interpretation:
ALPA does say 'the continental USA is all one geographic area and we're always acclimated' (Q-01). ALPA also does say there is a specific situation where 'SFO based pilots could use SFO time when reporting out of JFK' (Q-03), though, normally, you would use JFK time (Q-02).
What 'case' does Virgin America management, or you, see that a pilot in JFK is not acclimated to the same theater as a pilot in SFO, or that a company cannot apply a specific time zone to an entire trip that remains in one 'theater'? Please cite your reference.
ALPA had multiple reps on the FT/DT rule making committee (they helped make this rule), and has an established record as an authority on this subject (the reason ALPA was founded was due to fatigue, hence the ALPA motto, 'Schedule with Safety'). If you have information that contradicts such an authority, I'm interested to hear it.
JFK's longitude is 73° 46' 56" W
A difference of less than 60° longitude.
ALPA's interpretation:
ALPA does say 'the continental USA is all one geographic area and we're always acclimated' (Q-01). ALPA also does say there is a specific situation where 'SFO based pilots could use SFO time when reporting out of JFK' (Q-03), though, normally, you would use JFK time (Q-02).
What 'case' does Virgin America management, or you, see that a pilot in JFK is not acclimated to the same theater as a pilot in SFO, or that a company cannot apply a specific time zone to an entire trip that remains in one 'theater'? Please cite your reference.
ALPA had multiple reps on the FT/DT rule making committee (they helped make this rule), and has an established record as an authority on this subject (the reason ALPA was founded was due to fatigue, hence the ALPA motto, 'Schedule with Safety'). If you have information that contradicts such an authority, I'm interested to hear it.
"The rest of the story deals with different time zones within a theater. Even in our single-theater operation we still work across five time zones, and the FAA says we must consider those time zones when determining flight duty period (FDP) and daily flight time limitations."
"even though we are acclimated, we still have to account for a pilot's internal clock across different time zones. Thus for each series of FDPs we have to use the local time where that series of FDPs began to determine limits for each duty period in the series. Keep in mind that a 'series of FDPs' is not the same as a trip, a series of FDPs is all FDPs within a 30 hr rest period. This gets to be problematic if, for instance, you have a long layover in a time zone other than where you started a trip."
"Suppose an LAX-based pilot starts a trip on the west coast after having three days off. In this case he would use Pacific Time to define his limits for the first FDP in the trip. He then has a 31 hour layover in Newark. That long EWR layover automatically marks the beginning of a new series of FDPs, and his FDP clock has now reset to Eastern Time, which he then has to apply to every FDP going forward until he
has another >30 hour break. We can see that trips would have to be planned and built using different time zones to determine start times from day to day. This is undesirable because it opens the door for questions like:
What if that 31 hour layover turns into a 29:45 layover because they were late into EWR? Now, the trip that was planned using limits for a local Eastern Time FDP start after the EWR layover has to continue to use Pacific Time instead, and might be illegal before they ever get started on day two. All sorts of other complications could crop up, because the FDP series reset is automatic and mandatory. Using the FDP series start time quickly becomes a complex problem with lots of
variables, so the FAA has offered another way for airlines to determine the applicable time zone for FDP starts. They are calling it the home base option. Under the home base rule, for all FDPs that start within the same theater each crew member applies the local time at his or her home base for all calculations."
So ALPA wasn't entirely correct in their FAQ about a SFO pilot could use JFK time to report on the east coast. True, if he received rest greater than 30 hrs and now marked the start of a new series of FDP. But as mentioned, most airlines are going with the home basing option, and all FDPs are looked at with home base time for calculations.
#52
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From: CL-65
Documents Associated with 14 CFR Part 117
A link from ALPA.
I should have done more research before starting this thread. My interpretation of 117 was incorrect.
A link from ALPA.
I should have done more research before starting this thread. My interpretation of 117 was incorrect.
#53
So some airline operations person is complaining that they will have a hard time building domestic US trips based on local time, because delays might force a scheduled 30+ hours of rest to be reduced below 30 (true, but this is the case if you used 'home base' time too), and the show time of the trip could be modified into a different part of ‘Table B’ (duty period limits for an unaugmented crew), rendering the previously legal trip illegal (which is incorrect, b/c the show time of the EWR flight didn't change, only the arrival time from LAX, and thus the amount of rest in EWR going from 31 hours to 29:45). Almost a page of writing to say . . . nothing.
If you need 30+ hours of rest in EWR, either:
With option 2, don't delay the flight, if that 30+ hour layover in EWR was necessary to keep your schedule legal, then you're going to have to get that rest sometime, so, either a RSV crew will have to be burned, or your schedule will have to be modified. Depending on how long ago you last got a 30+ hour rest, option 2 might not even be available.
The option the example seems to stress - don't delay the flight, but the EST vs. PST creates an issue - that's impossible, b/c the 30 hours is not dependent on time zone, only the show time, and the show time didn't change.
Since we agree that a LAX crew is both 'acclimated' and has not changed 'theater' in EWR , lets look at our disagreement:
Yeah, that 30 hour rest thing and the start of a new FDP. Let’s look at that. From your un-cited reference:
That bolded part is the source of my confusion.
That is the only mention in FAR 117 of a 30 hour rest period, and, in fact, the only use of the number "30" in FAR 117. While a new FDP does indeed start after a 30 hour rest, whether you are starting a ‘new’ FDP or continuing a current one is immaterial to what time zone you are required to use when determining FDP limits in Table B (duty period limits, based on show time, for an unaugmented crew). It merely requires a ‘look-back’ of 30 hours of rest in 168 hours, just like the current ‘look-back’ of 24 hours of rest in 7 calendar days. Once you get the 30 hour rest, you are good to go for another 138 consecutive hours (168-30) without a 30 hour rest period (just like now you are good to go for another 6 calendar days without a 24 hour break).Whether you use LAX time or EWR time, 29:45 of rest is still 29:45 of rest, no matter how many time zones you’ve crossed prior to beginning it. Whether you are starting a new FDP or continuing a current one is irrelevant. It does not give relief to compliance with Table 2, just like today, whether you are coming off 24 hours of rest or 8 hours of rest and no matter what time zone you are in, your FAR max duty day is still 16 hours.
So, just like ALPA says (and FAR § 117.13(b)(2) . . . and B.2. on page 3 of the FAA’s response to A4A), an airline can use ‘Local time’ for the entire trip, or can use ‘home base time’ for the entire trip. The airline does not have to use local time, but would then be required to use ‘home base time’ for the entire trip. This would be true whether the pilot gets a 31 hour rest, a 29:45 rest, or a 10 hour rest – the minimum allowed.
I can't find any support for your '30 hour rest = new FDP = implications for Table B (for an unaugmented pilot that operates within 'the lower 48'). If you have one:
If you need 30+ hours of rest in EWR, either:
- delay the EWR flight, which could make a previously legal trip illegal b/c the amount of duty is now too much with the new show time (which is time zone dependent, and thus variable based on your company choosing to use 'home base' or 'local' time rules)
- don't delay the EWR flight, and you no longer get 30 hours of rest, so you might be illegal now b/c of that.
With option 2, don't delay the flight, if that 30+ hour layover in EWR was necessary to keep your schedule legal, then you're going to have to get that rest sometime, so, either a RSV crew will have to be burned, or your schedule will have to be modified. Depending on how long ago you last got a 30+ hour rest, option 2 might not even be available.
The option the example seems to stress - don't delay the flight, but the EST vs. PST creates an issue - that's impossible, b/c the 30 hours is not dependent on time zone, only the show time, and the show time didn't change.
Since we agree that a LAX crew is both 'acclimated' and has not changed 'theater' in EWR , lets look at our disagreement:
So ALPA wasn't entirely correct in their FAQ about a SFO pilot could use JFK time to report on the east coast. True, if he received rest greater than 30 hrs and now marked the start of a new series of FDP. But as mentioned, most airlines are going with the home basing option, and all FDPs are looked at with home base time for calculations.
. . . he would use Pacific Time to define his limits for the first FDP in the trip That long EWR layover automatically marks the beginning of a new series of FDPs, and his FDP clock has now reset to Eastern Time, which he then has to apply to every FDP going forward until he has another >30 hour break.
§ 117.25 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.
(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.
So, just like ALPA says (and FAR § 117.13(b)(2) . . . and B.2. on page 3 of the FAA’s response to A4A), an airline can use ‘Local time’ for the entire trip, or can use ‘home base time’ for the entire trip. The airline does not have to use local time, but would then be required to use ‘home base time’ for the entire trip. This would be true whether the pilot gets a 31 hour rest, a 29:45 rest, or a 10 hour rest – the minimum allowed.
I can't find any support for your '30 hour rest = new FDP = implications for Table B (for an unaugmented pilot that operates within 'the lower 48'). If you have one:
#54
Gets Weekends Off
Joined: Dec 2005
Posts: 9,305
Likes: 249
So some airline operations person is complaining that they will have a hard time building domestic US trips based on local time, because delays might force a scheduled 30+ hours of rest to be reduced below 30 (true, but this is the case if you used 'home base' time too), and the show time of the trip could be modified into a different part of ‘Table B’ (duty period limits for an unaugmented crew), rendering the previously legal trip illegal (which is incorrect, b/c the show time of the EWR flight didn't change, only the arrival time from LAX, and thus the amount of rest in EWR going from 31 hours to 29:45). Almost a page of writing to say . . . nothing.
If you need 30+ hours of rest in EWR, either:
With option 2, don't delay the flight, if that 30+ hour layover in EWR was necessary to keep your schedule legal, then you're going to have to get that rest sometime, so, either a RSV crew will have to be burned, or your schedule will have to be modified. Depending on how long ago you last got a 30+ hour rest, option 2 might not even be available.
The option the example seems to stress - don't delay the flight, but the EST vs. PST creates an issue - that's impossible, b/c the 30 hours is not dependent on time zone, only the show time, and the show time didn't change.
Since we agree that a LAX crew is both 'acclimated' and has not changed 'theater' in EWR , lets look at our disagreement:
Yeah, that 30 hour rest thing and the start of a new FDP. Let’s look at that. From your un-cited reference:
That bolded part is the source of my confusion.
That is the only mention in FAR 117 of a 30 hour rest period, and, in fact, the only use of the number "30" in FAR 117. While a new FDP does indeed start after a 30 hour rest, whether you are starting a ‘new’ FDP or continuing a current one is immaterial to what time zone you are required to use when determining FDP limits in Table B (duty period limits, based on show time, for an unaugmented crew). It merely requires a ‘look-back’ of 30 hours of rest in 168 hours, just like the current ‘look-back’ of 24 hours of rest in 7 calendar days. Once you get the 30 hour rest, you are good to go for another 138 consecutive hours (168-30) without a 30 hour rest period (just like now you are good to go for another 6 calendar days without a 24 hour break).Whether you use LAX time or EWR time, 29:45 of rest is still 29:45 of rest, no matter how many time zones you’ve crossed prior to beginning it. Whether you are starting a new FDP or continuing a current one is irrelevant. It does not give relief to compliance with Table 2, just like today, whether you are coming off 24 hours of rest or 8 hours of rest and no matter what time zone you are in, your FAR max duty day is still 16 hours.
So, just like ALPA says (and FAR § 117.13(b)(2) . . . and B.2. on page 3 of the FAA’s response to A4A), an airline can use ‘Local time’ for the entire trip, or can use ‘home base time’ for the entire trip. The airline does not have to use local time, but would then be required to use ‘home base time’ for the entire trip. This would be true whether the pilot gets a 31 hour rest, a 29:45 rest, or a 10 hour rest – the minimum allowed.
I can't find any support for your '30 hour rest = new FDP = implications for Table B (for an unaugmented pilot that operates within 'the lower 48'). If you have one:
If you need 30+ hours of rest in EWR, either:
- delay the EWR flight, which could make a previously legal trip illegal b/c the amount of duty is now too much with the new show time (which is time zone dependent, and thus variable based on your company choosing to use 'home base' or 'local' time rules)
- don't delay the EWR flight, and you no longer get 30 hours of rest, so you might be illegal now b/c of that.
With option 2, don't delay the flight, if that 30+ hour layover in EWR was necessary to keep your schedule legal, then you're going to have to get that rest sometime, so, either a RSV crew will have to be burned, or your schedule will have to be modified. Depending on how long ago you last got a 30+ hour rest, option 2 might not even be available.
The option the example seems to stress - don't delay the flight, but the EST vs. PST creates an issue - that's impossible, b/c the 30 hours is not dependent on time zone, only the show time, and the show time didn't change.
Since we agree that a LAX crew is both 'acclimated' and has not changed 'theater' in EWR , lets look at our disagreement:
Yeah, that 30 hour rest thing and the start of a new FDP. Let’s look at that. From your un-cited reference:
That bolded part is the source of my confusion.
That is the only mention in FAR 117 of a 30 hour rest period, and, in fact, the only use of the number "30" in FAR 117. While a new FDP does indeed start after a 30 hour rest, whether you are starting a ‘new’ FDP or continuing a current one is immaterial to what time zone you are required to use when determining FDP limits in Table B (duty period limits, based on show time, for an unaugmented crew). It merely requires a ‘look-back’ of 30 hours of rest in 168 hours, just like the current ‘look-back’ of 24 hours of rest in 7 calendar days. Once you get the 30 hour rest, you are good to go for another 138 consecutive hours (168-30) without a 30 hour rest period (just like now you are good to go for another 6 calendar days without a 24 hour break).Whether you use LAX time or EWR time, 29:45 of rest is still 29:45 of rest, no matter how many time zones you’ve crossed prior to beginning it. Whether you are starting a new FDP or continuing a current one is irrelevant. It does not give relief to compliance with Table 2, just like today, whether you are coming off 24 hours of rest or 8 hours of rest and no matter what time zone you are in, your FAR max duty day is still 16 hours.
So, just like ALPA says (and FAR § 117.13(b)(2) . . . and B.2. on page 3 of the FAA’s response to A4A), an airline can use ‘Local time’ for the entire trip, or can use ‘home base time’ for the entire trip. The airline does not have to use local time, but would then be required to use ‘home base time’ for the entire trip. This would be true whether the pilot gets a 31 hour rest, a 29:45 rest, or a 10 hour rest – the minimum allowed.
I can't find any support for your '30 hour rest = new FDP = implications for Table B (for an unaugmented pilot that operates within 'the lower 48'). If you have one:
Airlines have two options for domestic unaugmented crews:
* Use local time at the location where the FDP series began
OR
* Local time at the flight crew member's homebase if the flight crewmember is acclimated to a theatre that encompasses the home base.
That FAA document you cited is what the airlines have used after the FAA clarified up the two options available. The EWR example cited above assumes that the airline chooses to use option #1. Use local time at the location where the series of FDP began.
Look at the example in the FAA document, that is what the airlines have used.
Source: FAA document you linked, top paragraph page 4........
"For example, an acclimated flight crew beginning an FDP series in the Eastern time zone has 36 hrs of rest in the Pacific time zone. Because this crewmember would receive over 30 hours of rest, the next FDP, which would be out of the Pacific timezone, would commence a new FDP series. Thus, this crewmember would enter Table B and C based on either Pacific time or home base time"
What that means............................................. ..
You would use Table B based on Pacific time if the airline had gone with option 1, which is use local time at location where a new FDP series began.
--- OR ---
You would use Table B based on home base time if the airline had gone with option 2, which is local home base time since it's in the same theatre. In this case, EWR home base time.
You need to understand that and it makes a huge difference.
By choosing to schedule by option 1, the airline would need to have 30 hrs of rest scheduled to start a NEW series of FDPs. Once you have that 30 hrs of rest and start a new series of FDPs, you would then use the local time at that location for the FDP. The EWR example my airline provided, and the FAA example provided linked above are examples of this.
By choosing to schedule by option 2, you take out all the hard work and use home base local time for ALL rest calculations within the theatre. East or West coast, you enter table B and C based on local time at home base. This option does not consider series of FDP changes.
All the major airlines met with FAA officials, and every single airline (that's what we've heard) has chosen to use "home based local time" for the 48-state single theatre operation.
What airline do you work for? Ask your crew planning department, they'll tell you the same thing. This has been finalized and this interpretation is what the airlines are using, and the driving force for VX to create a EWR/JFK base. All other major airlines have used the same (home base option).
I hope that clarifies everything.
Last edited by ShyGuy; 09-05-2013 at 12:39 AM.
#55
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With option 1, if you use local time for the whole trip vs. home base time
So one 4-day "trip" can actually be 4 FDPs, one each day. And if you have a layover greater than 30 hrs somewhere else, it could actually be a start of a NEW series of FDP, within that same 4-day "trip."
If you are using local time option #1 then you use the time of where the SERIES of the FDP began. If you get a 30 hr (or more) layover on the west coast, you have reset yourself to a new series of FDP which are now based on west coast time.
Suppose you takeoff at EWR at 9am and land at LAX at 12 noon. That was one FDP.
Now you have a 32 hr layover.
Then you takeoff 8pm LAX the following day going back to EWR. This is another FDP, and a new SERIES of FDP.
IF you are under option 1, then starting this trip, you use local time at EWR for table B for limitations. At LAX, beyond a 30 hr layover you started a new series of FDP so on the way back you use local LAX time to enter table B for limitations.
IF under option 2, home base time for same theatre (all 48 states)....... Then for the ENTIRE FDPs throughout your schedule, you always use your homebase local time (EWR) for table B limitations.
#57
DH home after completing your last leg of the day is not counted toward your FDP.
#58
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Thank you,
How about this. Tomorrow I report at 6am pacific, I will have been on rest on pacific time for 31 hrs. Im based ord, so the way I see it im still acclimated to central, but if it was 36 hrs, I would have been acclimated to the west coast? I know this is the argument above but im wondering.
How about this. Tomorrow I report at 6am pacific, I will have been on rest on pacific time for 31 hrs. Im based ord, so the way I see it im still acclimated to central, but if it was 36 hrs, I would have been acclimated to the west coast? I know this is the argument above but im wondering.
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