I added guidance for re-scheduling FDP start times in accordance with the FAA letters of clarification from 05-Mar-2013.
Understanding FAR Part 117 v 1.7
I also updated the powerpoint presentation to include the same information.
FAA Flight Crewmember Duty and Rest Requirements FNPRM v1.13
3 thoughts on “Re-Scheduling FDP start time”
I wrote this on the post, but do you think that 117.25(e) will prohibit same day commutes?
(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.
By the way your website was extremely helpful to me to understand 117. Well done!
Commuting … A very difficult issue for the FAA to enforce … But in short I would agree with you assessment, that practice is a violation of the regulations.
It is the shared responsibility of the certificate holder to schedule responsibly, and for the flight crewmember to report fit for duty.
117.5 Fitness for duty
While the rest requirements establish the acceptable means of compliance for both rest periods and sleep opportunity.
Specifically, 117.25(e) and (f).
The FAA has issued Advisory Circulars, AC-117-3 section 10 discusses Commuting Stresses.
Here is the link https://far117understanding.files.wordpress.com/2013/01/ac-117-3.pdf
Thanks, for viewing the site.
If you have any suggestions as to how it may be improved just let me know, I will consider all constructive suggestions and corrections.
Garret, Interesting thoughts on your third example and I had some similar musings on the 12 hour notice for FDPs now impinging the WOCL. The parts that I’m trying to work thru is contact during rest, one call rule, notice and the provisions of 117.25 (a). I’d give anything is the FAA could be a little clearer whenever they put something in writing. I don’t think A4A or any other carrier is interested in asking any more questions, we’re all afraid of what they’ll say. Most of my thinking centers on the verbiage in the clarification under Adjusting FDP start time on pages 19 and 20. The long call provision specifically calls for 10 or 12 hours of notice prior to entering rest. I’m good there. The short call part on page 20 allows the carrier to change the pilots FDP start time to a RAP start. It does not specify any notice requirement. In this scenario, the Company would have to be able to call the pilot during the rest period to advise he/she is now on a RAP. All of the scenarios you describe will be part of an A4A meeting on the 15th in MCO. I’m really curious to see how everyone else views these. I’ll be sure to share whatever comes out of the meeting.