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.
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
The FAA has addressed the application of Table A and Table B (Table C) for Check-Airmen sitting in the Jump-Seat (Observers Seat).
Anderson-Teamsters357 -2- (2014) Legal Interpretation
Two Clarifications were issued today:
Johnson-ALPA – (2014) Legal Interpretation
Clarifies the Definition of Flight Time.
Hryniw – (2014) Legal Interpretation
Clarifies the definitions of RAP and FDP with respect to FCM assigned to duty as a Short Call Reserve (SCR).
The FAA posted a clarification regarding 117.19 FDP extensions.
- Certificate holder / PIC Concurrence
- PIC Refusal
Anderson-Teamsters357 -1- (2014) Legal Interpretation
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