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.


Updated ALPA FTDT FAR 117 Guide – Feb 2015

ALPA has updated the reference material for FAR 117.

ALPA FTDT FAR 117 Guide Feb2015

FDP Extensions and Cumulative Limits

The FAA issued various interpretations that agree with and supports many earlier interpretations.

Wykoff_ALPAI – (2015) Legal Interpretation

Short-Call Reserve / RAP and Extended FDP

Short-Call Reserve / RAP and Extended FDP.

Short-Call Reserve / RAP and Extended FDP

The FAA sent out a clarification regarding how to calculated the Combined RAP and FDP and the permitted extensions.

Anderson – (2014) Legal Interpretation

Breckeen-ExpressJet Airlines – (2014) Legal Interpretation

FAA Clarifications 08-Jul-2014

The FAA dealt with the following topics:

Definition of Unplanned events.

Mandatory concurrence with FDP Extension.

Company requirement to check schedule during an assigned rest period.

Garciglia – (2014) Legal Interpretation

Phelan-PPA Global Energy – (2014) Legal Interpretation


Keeping the FDP clock running

The FAA released another letter of interpretation 16-Jun-2014.

This letter addresses volunteer flying by a FCM, and conversion from DHD.

Tutt – (2014) Legal Interpretation