Understanding FAR part 117

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FAA Clarifications – 09-Aug-2016

The FAA issued 3 clarifications that have an impact on FAR 117.

Johnson – (2016) Legal Interpretation FAR 1.1 “Definition of Flight Time and Diversions”
Amaya – (2016) Legal Interpretation FAR 117.25 (b) “FDP extensions and 117.25(b) Required rest in 168 hours”
Anderson – (2016) Legal Interpretation FAR 117.5 “Fitness for Duty with respect to a rescheduled FDP”

The first clarification cited, FAR 1.1 “Definition of Flight Time and Diversions”, will seem to have the biggest impact when validation of:

  • 117.11-Flight time limitations and
  • 117.23(a)-Cumlative flight time limitations needs to be considered.

The next two, re-affirm previously stated interpretations given by the FAA.

Welcome to KCASR 6.Q FTDP

A site dedicated to share information concerning the Flight Time Limitations as established by the DGCA (Kuwait). The regulations are very similar to the CAA-UK CAP371 FTL, but users should underst…

Source: Welcome to KCASR 6.Q FTDP

FAR 117 – and Commuting.

The following comment came to this blog recently:

FAR 117 wasn’t written to accommodate commuters. Living outside your base is totally optional, it was written to work with FCM that work where they live.


While I agree that FAR 117 does not provide any firm statutory requirements as how Airlines and Flightcrew Members need to deal specifically with “Commuting”, some Airlines do have policies for “commuters”.

In the end the FCM is responsible to adhere to 117.5 Fitness for duty, where the Joint responsibility is placed upon both the Airline and FCM.

The FAA has provided “best practices” guidance in the form of an AC.

AC 117-3 (link provided)

I suggest that All crew members read the entire AC, especially sections:






Additional guidance may come from your Airline, with respect to it’s Fatigue Risk Management Policies and/or any Guidance that may be included in any Collective Bargaining Agreement or Union Material, (ask around, someone will know).

Again, if you feel fatigued, or suspect that you may become fatigued, don’t fly, better to stand down than have an incident.

Fly Safe, Fly Smart, Fly Well Rested.

Authors Note:

I am not a pilot, I do not commute like a crew member, so I will not pretend to understand how commuting impacts each and every individual. I have great respect for the professionalism of all crew members, so the input by individuals is seriously considered. I will always attempt to side on the side of safety.





Source: Welcome

Acclimatisation Under EASA FTL

Source: Acclimatisation Under EASA FTL

FAR 117.1 “Part 91 tail end ferry”

Slater – (2015) Legal Interpretation

The FAA has clarified the necessary requirements as to when a part 91 ferry flight must be considered as a FAR 117 flight, and when those conditions do not pertain to the part 91 ferry flight.

FAR 117.25 (g) “Compensatory Rest Following Time in DHD Transportation”

On September 18th, the FAA released an interpretation concerning the application of rest following Time in DHD Transportation.

Duncan, Oliver – (2015) Legal Interpretation

This interpretation differs significantly from the FAA’s previous letter of clarification:

FAA Letters of Response 05-Mar-2013

search for viii. Deadheading to find the original clarification.

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