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Airport/standby reserve is known by several terms among various certificate holders, but ultimately involves a flightcrew member on call at an accommodation or other facility at or near an airport. The flightcrew member is not at home and is not resting. The purpose of such reserve duty is to have an available flightcrew member close to the operation in case of a schedule irregularity. Flightcrew members on these assignments can receive notice to report to work in as little as 1 hour before departure time, requiring them to be in a constant state of readiness. Because of the unique nature of these assignments, and the fact that the flightcrew member is not resting, an airport/standby reserve assignment is considered to be an FDP, regardless of whether a flying assignment is ultimately received by the flightcrew member.
An Airport/Standby Reserve (ASB) is considered duty as well as FDP (see 117.3 definitions)
A short-call reserve flightcrew member typically receives an assignment on relatively short notice, meaning he or she would not be provided an adequate time for a legal rest period before reporting for duty. Report times are typically within two to 3 hours from notification. Short-call reserve differs from airport/standby reserve in that the flightcrew member is likely to be at home and available for contact by the certificate holder, rather than at the airport or a hotel actively awaiting an assignment. Although the flightcrew member may be at home, the opportunity for sleep before reporting for duty cannot be guaranteed. Therefore, a limit on the amount of time spent on short-call reserve duty is necessary.
A Short Call Reserve(SCR), is considered duty since a Reserve Availability Period (RAP) has been assigned to the crewmember, and a RAP is defined as duty. (see 117.3 definitions)
Long call reserve pilots are given relatively substantial advance notice of when they are to fly. This notice may be from 10 hours to over 24 hours. A long-call reserve flightcrew member typically receives an assignment for duty well in advance and will have a sleep opportunity before reporting for duty, and may have enough notice of the assignment to plan his or her rest accordingly.
A Long Call Reserve (LCR) is not considered duty, however the crewmember must be contactable during the time a crewmember is assigned to LCR; the crewmember is not at rest.
Q58) If a flightcrew member is assigned to any reserve assignment are there any specific limitations?
A58) Unless specifically assigned to an Airport/Stand-by Reserve, or Short-Call Reserve assignment, the flightcrew member is considered to be assigned to Long-Call Reserve (117.21(a) refers). The flightcrew member, is not considered on duty, however the crewmember is also not considered to be at rest. There are no specific limitations as to how long a flightcrew member may be assigned to Long-Call Reserve but the pilot would still require 30 hours of rest within the past 168 consecutive hours before beginning a reserve or flight duty period.
Q59) Are there any rest requirements for a Flightcrew member assigned to Long-Call Reserve who is further assigned to Short-Call Reserve of FDP?
A59) Yes, The crewmember must be released from Long-Call Reserve in accordance with 117.21(e) to provide for a Rest Period before the start of next assignment that meets the requirements in 117.25(e). Further if the next assignment is an FDP that starts before 2 am and extends into the WOCL, at least 12 hours notification must be provided (117.21(d) refers)
Q60) If a flightcrew member is assigned to an Airport/Stand-by Reserve assignment are there any specific limitations and rest requirements?
A60) Airport/Stand-By Reserve is considered as a part of an FDP (117.3 Definitions refers), as such need to be applied to the appropriate FDP limitation set forth in 117.13, 117.15, 117.17, 117.19, 117.23 and 117.27. Further such an assignment must satisfy the rest requirements 117.25(b) and 117.25(e)
Q61) If a flightcrew member is assigned to a Short Call Reserve assignment are there any specific limitations and rest requirements?
A61) A Short-Call Reserve must comply with the rest requirements 117.25(b) and 117.25(e), further a Reserve Availability Period (RAP) may not exceed 14 hours (117.21(c)(1).
Q62) If a flightcrew member assigned to a RAP is assigned to an Un-Augmented FDP during the RAP are there any further Limitations?
A62) Yes, 117.21(c)(3) provides, that the FDP assigned must be scheduled to end at the earlier of:
(1) The start time of the RAP plus 16 hours
(2) Using the start time of the RAP, apply Table B limit plus 4 hours.
(3) Using the start time of the FDP assigned, apply the Table B limit.
The FAA has provided the following examples:
For the first example, an acclimated flightcrew member begins a RAP at 0600.
That flightcrew member is then assigned to an unaugmented FDP that begins at 1200 and consists of two flight segments. According to Table B, the FDP limit for a two-segment FDP that begins at 1200 is 13 hours. The applicable 13-hour FDP limit plus 4 hours equals 17 hours. Because this is greater than 16 hours, under § 117.21(c)(3), the pertinent RAP + FDP limit for this unaugmented operation is 16 hours. Given that the flightcrew member in this example began his RAP at 0600, he will have 6 hours of RAP time by the time his FDP will start at 1200. As a result, to stay within the 16-hour RAP + FDP limit, this flightcrew member’s FDP cannot exceed 10 hours without an extension, as his RAP will use up 6 hours of the 16-hour RAP + FDP limit.
For the second example, an acclimated flightcrew member begins a RAP at 1100. That flightcrew member is then assigned to an unaugmented FDP consisting of five flight segments that begin at 1500. According to Table B, the FDP limit for a five-segment FDP that begins at 1500 is 11.5 hours. The applicable 11.5-hour FDP limit plus 4 hours equals 15.5 hours. Because this is smaller than 16 hours, under § 117.21(c)(3), the pertinent FDP + RAP limit for this unaugmented operation is 15.5 hours. Since the flightcrew member in this example began his RAP at 1100, he will have 4 hours of RAP time by the time his FDP will start at 1500. Consequently, this flightcrew member can take the full 11.5-hour FDP as the 11.5-hour FDP plus the 4 hours of RAP will not exceed the 15.5-hour RAP + FDP limit.
Q63) If a flightcrew member assigned to a RAP is assigned to an Augmented FDP during the RAP are there any further Limitations?
A63) Yes, 117.21(c)(4) provides, that the FDP assigned must be scheduled to end at the earlier of:
(1) Using the start time of the RAP, apply Table C limit plus 4 hours.
(2) Using the start time of the FDP assigned, apply the Table C limit.
Q64) May the FDP assigned during a RAP be extended?
A64) Yes, 117.19(a)(1) has been corrected to permit extensions to combined RAP and FDP as defined in 117.21(c(3) or (4) up to 2 hours, however the FDP may not be extended any further than the limitations defined in 117.19(a)(1)(2) and (3)
Scenario Questions:
Combined RAP and FDP with extensions.
Assumptions:
- No Extension in the previous 168 hours without a 30 hour intervening rest period.
- Extensions above scheduled FDP limitations will not exceed the Cumulative FDP limits in 168 / 672 hours.
SQ5) Are Extensions of a FDP assigned during the RAP beyond the 16 hour limit from 117.21(c)(3) as illustrated above?
SQ5) No, In the case illustrated above; the Flightcrew member must be able to expect before takeoff to end the FDP by 19:00. There is no additional extension to a FDP when assigned during a RAP. Should an extension occur after takeoff the FDP may be extended as long as necessary to safely land the aircraft.
SQ6) Are Extensions of a FDP assigned during the RAP beyond the 16 hour limit from 117.21(c)(3) as illustrated above?
SQ6) Yes, In the case illustrated above; the Flightcrew member must be able to expect before takeoff to end the FDP by 20:00. The extension allows the combined RAP and FDP to reach 17 hours in duration. The extension is provided for in 117.19(a)(1).
SQ7) Are Extensions of a FDP assigned during the RAP beyond the 16 hour limit plus 2 hours as illustrated above?
SQ7) No, In the case illustrated above; the Flightcrew member must be able to expect before takeoff to end the FDP by 21:00. The extension allows the combined RAP and FDP to reach 18 hours in duration while the FDP will be limited to 14 hours. The extension is provided for in 117.19(a)(1).
117.21 Reserve status.
(a) Unless specifically designated as airport/standby or short-call reserve by the certificate holder, all reserve is considered long-call reserve.
(b) Any reserve that meets the definition of airport/standby reserve must be designated as airport/standby reserve. For airport/standby reserve, all time spent in a reserve status is part of the flightcrew member’s flight duty period.
(c) For short call reserve,
(1) The reserve availability period may not exceed 14 hours.
(2) For a flightcrew member who has completed a reserve availability period, no certificate holder may schedule and no flightcrew member may accept an assignment of a reserve availability period unless the flightcrew member receives the required rest in § 117.25(e).
(3) For an unaugmented operation, the total number of hours a flightcrew member may spend in a flight duty period and a reserve availability period may not exceed the lesser of the maximum applicable flight duty period in Table B of this part plus 4 hours, or 16 hours, as measured from the beginning of the reserve availability period.
(4) For an augmented operation, the total number of hours a flightcrew member may spend in a flight duty period and a reserve availability period may not exceed the flight duty period in Table C of this part plus 4 hours, as measured from the beginning of the reserve availability period.
(d) For long call reserve, if a certificate holder contacts a flightcrew member to assign him or her to a flight duty period that will begin before and operate into the flightcrew member’s window of circadian low, the flightcrew member must receive a 12 hour notice of report time from the certificate holder.
(e) A certificate holder may shift a reserve flightcrew member’s reserve status from long-call to short-call only if the flightcrew member receives a rest period as provided in § 117.25(e).
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Understanding FAR 117 
117.21(a) says:
“Unless specifically designated as airport/standby or short-call reserve by the certificate holder, all reserve is considered long-call reserve.”
When does that specific designation have to occur? If I have a monthly schedule filled with Reserve 0001-2359, but the day before an actual reserve day the company changes this to Short Call 0400-1600 then would that be legal?
Additionally, if I am required to log into a company system and view my assignment for the next reserve day would that count as required duty?
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Scheduled for Long-Call-Reserve for each day during the month from 00:01-23:59.
Obviously, will be illegal after the 5th day.
FAR 117.23 (b) Before beginning any reserve or flight duty period a flightcrew member must be given at least 30 consecutive hours free from all duty within the past 168 consecutive hour period.
So, I need to assume that periodic breaks of 30:00 will be provided during the month.
While on LCR, the crew member is contactable. All that needs to be provided is sufficient notice of an assignment in accordance to 117.21 (d).
To change a FCM from LCR to SCR 04:00 – 06:00, The operator must comply with 117.21 (e) A certificate holder may shift a reserve flightcrew member’s reserve status from long-call to short-call only if the flightcrew member receives a rest period as provided in § 117.25(e), so the LCR must have ended no later than 18:00, at which point the FCM will be considered to be in a rest period; the FCM should not be contacted any further during the rest period.
Your last question seems to be a gray area.
I believe that everyone agrees that LCR is not rest. The question is LCR duty?
The question of application of the definition of duty with respect to LCR’s seems to have more of a Union/Airline agreement aspect versus a FAR aspect; so I suggest you discuss this internally.
Since a FCM is contactable while on LCR, some kind of system to notify the FCM of an assignment must be provided, eg) Phone, Cell-Phone, Text-Message, Email etc. It is not as simple that the Airline initiate contact, the FCM must also acknowledge the change. Depending on how the airline has described LCR procedures in operations manuals and working agreements, the checking/acknowledgement of schedule changes during the LCR may be reasonable and not considered duty.
/Garret
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Garret, thanks for the help. I apologize for not being clear. Assume a 5day block of reserve days in the middle of month with exactly 30hrs rest prior to 0001 on Day 1 of Reserve. If the company does not specify the type of reserve status issued to the FCM then we are to assume it is Long Call Reserve (117.21(a)). Then, at some point during that 30hr rest period prior to Day 1 the company changes the Day 1 reserve status to a Short Call Reserve 0400-1600. Is this legal? 0001-0359 was previously un-specified Reserve status, so assumed Long Call and not a rest period.
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If the company attempts to contact a FCM during a required rest period, the FCM may voluntarily accept the notification of the SCR starting at 04:00, then the re-assignment is legal.
However the Airline may not
Require
a FCM to perform any duty during a required Rest Period as that would defeat the purpose of a rest period.
Should the FCM wait to begin checking for messages at 0000 during the original scheduled LCR there would be insufficient time to end the LCR and begin the SCR at 04:00 as the minimum required rest period before starting any FDP, ASB or SCR is 10:00 under FAR 117.25 (e), in such a case the earliest time the SCR may begin is 10:00.
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Regarding Q 62, it does not appear to be in line with the FAA clarification of 35/2013. Your answer has the pilot entering table B using the start time of the RAP and adding 4 hours to that amount. The FAA clarification leads me to believe that the pilot should enter table B using the REPORT TIME (i.e., the beginning of his FDP) to get the applicable FDP limit to which he then adds 4 hours.
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Rich,
Thanks for the comment.
I think we are both agree, as to what defines the FDP limit and how it is derived.
It seems that the confusion is from what point to to apply the limitation.
I included the FAA’s example as well as several scenarios concerning Combined RAP / FDP.
Since the Table B / C limits are always derived from the FDP start time that is our basic limitation, FDP limit. (117.13)
The FDP limit is applied at the FDP start time to give a Scheduled FDP expiration time. (117.13)
Also the FDP limit + 4 hours or 16 hours, whichever is less is applied from the RAP start time to give the Combined RAP FDP expiration time.
(117.21(c)(3))
Compare the Scheduled FDP Expiration time to the RAP FDP Expiration time, which ever is earlier is when the FDP must be scheduled to end by.
From that point, the FDP is permitted to be extended in accordance to 117.19.
Garret
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HELP! I’m confused: If a short call reserve is assigned a multi day trip; day one duty maximum obviously takes into account the time spend on call prior to show time for the assignemtn. But day 2 is part of the assignment…the reserve pilot would not be on call prior to show time.
Let’s say day 2 consists of a 6:00 AM show time for two legs of flying followed by a deadhead returning to base at 4:30 PM. Based on the table, the FDP should be 13 hours (6 AM show time and 2 segments) and the deadhead is NOT part of the FDP. Upon arrival in base, can the company keep that reserve on duty for 16 hours total (till 10 PM?!). If another flight assignment is added to the pilot’s schedule, that would be 3 flight segments…which would (for a lineholder) require a maximum FDP of 12 hours. Does that mean that if the company assigns the reserve an additional flight (without intervening rest) that any additional flying (without a 10 hour intervening rest period) would have to be completed by no later than 6 PM? (12 hours after original show time)?
The confusion is how to handle flight assignments without being on reserve first and/or being put back on reserve AFTER completion of a flight segment or segments. How do you calculate maximum duty allowable for any additional flying during that same reserve duty period?
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The FAA specifically addressed this issue in the letters of clarification back in March 2013.
RAA asked whether § 117.21 allows a RAP to be assigned upon completion of a multi-day trip when the flightcrew member still has not reached the FDP limits specified in Table B. To illustrate its question, RAA provided the following scenario. A reserve pilot is assigned a three-day trip. On Day 3, he begins an FDP at 0700, and flies one flight segment until 1430. Upon completion of the one flight segment, the flightcrew member arrives back on base and the carrier assigns him 3 additional flight segments. RAA stated that the revised schedule would not exceed the pertinent FDP or flight time limitations, and it would also not exceed any cumulative limitations. RAA asked whether this schedule would be permissible under § 117.21.
Subsection 117.25(e) prohibits a flightcrew member from beginning a RAP unless that flightcrew member
receives 10 hours of rest with an 8-hour sleep opportunity immediately before the RAP. Thus, a flightcrew member cannot begin a RAP immediately after ending an FDP because that flightcrew member would not have received 10 hours of rest immediately before beginning the RAP.
However, as discussed above, the number of flight segments in an FDP can be changed after an FDP begins. Thus, in RAA’s example a certificate holder could utilize a flightcrew member’s remaining allowable FDP time by
adding three more flight segments to the flightcrew member’s FDP. However, the FAA emphasizes that: (1) the addition of flight segments to an FDP will require a recalculation of the pertinent FDP limit in Table B using the updated number of flight segments; and (2) the flightcrew member will have to reaffirm his or her fitness for duty before beginning each flight segment.
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Can you give me a reference for this letter of clarification?
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John,
First I would begin with:
Click to access 2013-05083.pdf
Secondly, look at the following letters of clarification:
Click to access foltz-2014-legal-interpretation.pdf
Click to access hryniw-2014-legal-interpretation.pdf
Click to access breckeen-expressjet-airlines-2014-legal-interpretation.pdf
Click to access fowler-2015-legal-interpretation.pdf
Garret
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Garret,
Thank you for those refrences. Is there any reason that a Short Call Reserve could not be assigned to fly then put back on reserve for the remainder of their scheduled RAP? For example if they were called in to do a post maintenance flight or a short round trip. After parking the plane and leaving the airport, which normally concludes the FDP, can the pilot be held on reserve and given another assignment several hours later assuming no FDP limits are violated?
John
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The FDP still needs to be a legal FDP otherwise, everyone would just start duty as a SCR.
The requirements for a FDP under 117.13 still applies from the start of the FDP whether assigned to a Line holder or Reserve.
It is the provisions under 117.21 that specifically apply only to a FCM in reserve status.
The intent of the FDP + 4 hours was to prevent a FCM from being assigned a FDP after spending a prolonged amount of time on RAP.
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John,
So the situation is a RAP becomes RAP1 – FDP – RAP2, where the RAP end time is the same as RAP 2 end time, and the total time from RAP1 start to RAP2 end is less than or equal to 14:00.
The FCM is permitted to remain on FDP while awaiting a flight, but RAP2 needs to be considered FDP since the “FDP Clock already started”.
That FDP must remain within the Table B limitations.
The FCM also needs to remain the combined RAP / FDP limits 16 hrs or Table B + 4 hrs (whichever is less).
Likewise, the FCM must also remain within the cumulative FDP limits 60 in 168, 190 in 672.
Where RAP2 actually takes place is inconsequential as long as it is being considered FDP.
If RAP2 is considered RAP it first must be immediately preceded by a rest period of no less than 10 hours (117.25 (e) refers).
I suggest you ask the FAA directly, as they may have differing opinions than mine, but I feel pretty confident that this is the intent of the regulation.
Garret
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A62 point 3 isn’t in 117.21(c)(4) and my company’s subject matter experts are telling us that this translates to a reserve pilot being able to possibly be on duty for longer than the line holding FCM that we are paired with (the lesser of 16 hours or Table B from report time + 4 hours). Where does your interpretation bring point 3 into the answer?
In other words a reserve FCM on duty at 0400 is called and made to report at 0600 for 5-segment flight duty. Without an extension they would need to end the FDP by 1930 (max FDP is lesser of 16 hours or Table B (11.5) + 4 = 15.5 hours).
Meanwhile the line holder with a report time of 0600 will end a no extension FDP by 1730.
This can’t possibly be right, can it?
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