Training material for FAR 121 Subparts P, Q, R and S

I have added a page to allow those seeking training materials for:

FAR 121 Subpart P: Flight Attendant Duty Time Limitations and Rest Requirements

FAR 121 Subparts Q R and S: Flight Time, Duty Time Limitations and Rest Requirements:  Cargo Operations


Readers can download training presentations as well as full texts Kindle and Paperback.

As well as links to the FAA interpretive documentations of the FAR’s under these subparts.

Understanding FAR 121 Subparts P Q R and S


Moving some print material

I have decided to move some of the training materials to

In order to cover the costs of this site, users can now download the Understanding FAR 117 instructional document as a kindle readable document, or order a hard copy from Amazon.


FAR 117.17 – Application of 2 hour inflight rest for Augmented Flight Crews

The FAA issued a clarification on 05-January-2017 concerning the application of the 2:00 / and 1:30 inflight rests.

Previous guidance material on this site remains unchanged.

Snieder – (2017) Legal Interpretation

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.

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.




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.