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The FAA states that the usage of daily flight time limitations (FTL) allows for less restrictive daily FDP limitations and less restrictive rest requirements, thus allow the airlines more flexibility.
The FAA has also stated that 8 to 9 hours of flight deck duty is an acceptable safety range.
Daily flight time limitations retain their primary purpose: to mitigate transient fatigue that is brought about by time on task.
The FAA has made two fundamental changes to the daily flight time limitations:
- The elimination of the concept of “Legal to Start/Legal to Go”
- The addition of a diurnal component for un-augmented flightcrew members.
To ensure that certificate holders reasonably schedule flight crewmembers for assignments that will not exceed FTL during the course of operation, the FAA has imposed the following requirements:
- mandatory reporting whenever a flight crewmember has exceeded a FTL.
- requirements for corrective actions to avoid any further instances where a FTL has been exceeded.
Q04) What are the flight time limitations for a flight crewmember assigned to a FDP as a member of a 2-pilot flightcrew?
A04) 117.11(a)(1) stipulates to follow the flight time limitations as depicted in Table A. At Report Time when acclimated using either local time at the start of the FDP series or the pilot’s home base time if within 60 degrees longitude or the time zone to where the flight crewmember was last acclimated to when the flight crewmember is in an un-acclimated state.
Table A to Part 117—Maximum Flight Time Limits for Un-augmented Operations
Q05) What are the flight time limitations for a flight crewmember assigned to a FDP as a member of a 3-pilot flightcrew?
A05) 13 hours as stipulated in 117.11(a)(2). Flight time will include any flight deck time as well as in-flight rest periods.
Q06) What are the flight time limitations for a flight crewmember assigned to a FDP as a member of a 4-pilot flightcrew?
A06) 17 hours as stipulated in 117.11(a)(3). Flight time will include any flight deck time as well as in-flight rest periods.
Q07) Can a flightcrew member, assigned to a FDP as a member of a 2-pilot crew be rescheduled to exceed the flight time limits in Table A?
A07) No, this will violate 117.11(a)(1). No certificate holder may schedule and no flightcrew member may accept an assignment or continue an assigned flight duty period if the total flight time:
(1) Will exceed the limits specified in Table A of this part if the operation is conducted with the minimum required flightcrew.
Q08) Can a flightcrew member, assigned to a FDP as a member of a 2-pilot crew takeoff if it is known that the total flight time within the FDP will exceed the flight time limits in Table A?
A08) No, this also will be a violation of 117.11(a)(1), no flightcrew member may accept an assignment or continue an assigned flight duty period if the total flight time:
(2) Will exceed the limits specified in Table A of this part if the operation is conducted with the minimum required flightcrew.
Q09) Can a flightcrew member, assigned to a FDP as a member of a 2-pilot crew takeoff if it is NOT known that the total flight time within the FDP will exceed the flight time limits in Table A?
A09) Yes, 117.11(b), permits: due to unforeseen operational circumstances that arise after takeoff that are beyond the certificate holder’s control, a flightcrew member may exceed the maximum flight time specified in paragraph (a) of this section and the cumulative flight time limits in 117.23(b) to the extent necessary to safely land the aircraft at the next destination airport or alternate, as appropriate.
Q10) What are the responsibilities of the certificate holder should the flight time limitations stipulated in 117.11(a) be exceeded?
A10) The certificate holder must report to the Administrator within 10 days any flight time that exceeded the maximum flight time limits permitted by this section, in accordance with 117.11(c) and must implement the corrective action(s) reported in paragraph (c)(2) of this section within 30 days from the date of the extended flight time limitation.
117.11 Flight time limitation.
(a) No certificate holder may schedule and no flightcrew member may accept an assignment or continue an assigned flight duty period if the total flight time:
(1) Will exceed the limits specified in Table A of this part if the operation is conducted with the minimum required flightcrew.
(2) Will exceed 13 hours if the operation is conducted with a 3-pilot flightcrew.
(3) Will exceed 17 hours if the operation is conducted with a 4-pilot flightcrew.
(b) If unforeseen operational circumstances arise after takeoff that are beyond the certificate holder’s control, a flightcrew member may exceed the maximum flight time specified in paragraph (a) of this section and the cumulative flight time limits in 117.23(b) to the extent necessary to safely land the aircraft at the next destination airport or alternate, as appropriate.
(c) Each certificate holder must report to the Administrator within 10 days any flight time that exceeded the maximum flight time limits permitted by this section or § 117.23(b). The report must contain a description of the extended flight time limitation and the circumstances surrounding the need for the extension.
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Understanding FAR 117 