|Application of the Regulation|
Note: Although the FAA, in the Letter’s Of Clarification 05-Mar-2013, addressed Re-Scheduling FDP Start Time for Un-Augmented Operations, It is believed that the same princples will also be applied to Augmented Operations.
- The FAA stated that “FDP limits are determined by scheduled reporting time and not by actual reporting time.”
- The scheduled reporting time for an FDP is created once that FDP has been assigned to a flightcrew member.
- In order to change this scheduled reporting time, the flightcrew member would have to be shifted into either long-call or short-call reserve for the pertinent FDP.
Long-Call Method of Re-Scheduling FDP Start Time
Depiction of a FDP Re-Scheduled Start using the Long Call Method
- If long-call reserve is used to change the FDP start time, the flightcrew member would have to be provided proper notification of the change to the previously-scheduled FDP.
- Pursuant to the definition of long-call reserve in 117.3, a flightcrew member on long-call reserve must be notified of the change to FDP start time before he or she begins the rest period specified in 117.25.
- In addition, if the FDP infringes on the window of circadian low (WOCL), 117.21(d) requires that the flightcrew member receive a 12-hour notice of the change to the FDP start time.
Short-Call Method of Re-Scheduling FDP Start Time
Depiction of a FDP Re-Scheduled Start using the Short Call Method
- If short-call reserve is used to change the FDP start time, the flightcrew member would have to be placed on short-call reserve at the time that his FDP was originally scheduled to begin. In that scenario, instead of beginning an FDP at the originally-scheduled start time, the flightcrew member would simply begin his reserve availability period (RAP) pursuant to 117.21.
- Daily FDP limitations Table-B/C with permitted extensions will use the Re-Scheduled FDP start time.
- The time considered to be on Short-Call Reserve will not be considered towards the Cumulative FDP Limits in 168 / 672 hours, however it must adhere to the limitations for Short-Call Reserve in 117.21.
Re-Scheduling FDP Start Time without Using Long/Short-Call Reserve
Depiction of a FDP Re-Scheduled Start without use of Long/Short Call Reserve.
- The FAA emphasizes that if an FDP start time is not changed pursuant to the long-call or short-call reserve provisions of 117.21, then the FDP begins at the time that it was originally scheduled to begin.
- Daily FDP limitations Table-B/C with permitted extensions will use the Original Scheduled FDP start time.
- The time considered from the Original Scheduled FDP start time to the Re-Scheduled FDP start time will Not be considered towards the Cumulative FDP Limits in 168 / 672 hours.
- The Rest Period / Sleep opportunity will be permitted to overlap the time from Original Scheduled Start of the FDP to the Re-Scheduled start of the FDP.
- This is consistent with 117.25(e) and (f) as rest periods are based upon Actual Times.
- The FAA has decided to adopt a 10 consecutive hour rest requirement that immediately precedes the beginning of a reserve or FDP measured from the time the flightcrew member is released from duty.
- At this point, if the flightcrew member cannot have 8 uninterrupted hours of rest opportunity, the flightcrew member cannot report for the assigned FDP until he/she receives that rest.
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