The ALPA/A4A workshop generated a significant amount of discussion regarding the issue of the FDP extension and pilot concurrence.
FAA attorney Bob Frenzel who attended the workshop on behalf of Mark Bury (Assistant Chief Counsel – Regulation Division) clarified that in their interpretive writings, the term “extension” is intended to mean the span of time from the FDP table limit to a pilot’s maximum extension (up to two hours).
Therefore, to exceed the FDP Table B or Table C limit by any amount,:
- ALL FDP extensions require PIC concurrence.
- The Fitness for Duty acceptance qualifies as PIC FDP extension concurrence ONLY when the FDP extension needed is between 1 and 30 minutes, AND the need to extend the FDP is known by the PIC at the time he/she accepts Fitness for Duty.
- Fitness for Duty acceptance does NOT qualify, and a separate PIC concurrence is required for ALL scenarios not covered in point 2 above.