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Copy of FAR 117

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Alex Coats

on 6 June 2014

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Transcript of Copy of FAR 117

Definitions
Fit for Duty - physiologically and mentally prepared and capable of performing assigned duties in flight with the highest degree of safety.

Flight Duty Period (FDP) - From the time the company require the crewmember report for duty until block-in of the last assignment requiring aircraft movement.

Rest Period - a continuous period determined prospectively during which the flight crew member is free from all restraint by the certificate holder, including freedom from present responsibility for work should the occasion arise.
If possible and it makes sense for the operation, recrew it.
117.5 Fitness for Duty
Flight crewmembers must report for any FDP rested and ready to perform assigned duties.
Just like under 121 rules if a crewmember reports he or she is fatigued they may not continue to operate for that FDP.
Flight crewmembers must sign off fit for duty for each flight segment prior to operating.
Scheduling and Part 117
FAR 117
FAR 117 vs FAR 121
Whats the difference?
Starting January 4, 2014 there will no longer be Part 121 duty day, rest, or flight hour restrictions.
Part 117 replaces all of the current regulations to avoid the onset of cumulative fatigue.
117.11 Flight Time
Forecasting Fatigue
If a Flight Crewmember has multiple flight segments and calls in fatigue on a later flight segment it is not solely up to the Certificate Holder to terminate FDP.
The Flight Crewmember is the expert on whether or not he or she is fatigued.
The FAA cautions the certificate Holder that, as the preamble to the final rule explains, “there are objective sings that could be used to identify crewmember fatigue.”
The FAA has does not want to impose a mandatory regulation because signs used to identify fatigue cannot be synthesized to a objective standard.
The inverse is the FAA does not want to take away from the joint decision of the Certificate Holder from voluntarily terminate FDP’s and actually strongly encourages the Certificate Holder to voluntarily terminate FDP’s of crewmembers who are showing signs of fatigue.
For example if the Flight Crewmember has a r/t and he or she is showing signs of fatigue and says on a recorded line that they will not be able to safely operate the return trip from the out station it would behoove crew scheduling to re-crew the r/t to not strand the A/C other crew members and passengers in the out station.

No certificate holder may schedule and no flight crew 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 flight crew.

Window of report time.
Maximum Block
Legal to start legal to finish?
No more!
If a flight crewmember is expected to over block he or she may not accept that assignment, and we as the Certificate Holder cannot require them to fly prior to departure.

The only exception is an unforeseen operational circumstance that happens in the air

117.13 FDP
No certificate holder may assign and no flight crew member may accept an assignment for a flight operation if the scheduled flight duty period will exceed the limits in Table B of this part.

We know, its a lot to digest at once.
This table is the end all be all for determining
a flight crewmember's max duty day.
How to use Table B for FDP limits.
Every crewmembers FDP will always
start at the report time for any given
day, but that time may not reflect local
time during on overnight. For our
purposes we will always convert report
time to the local of the domicile of the
crewmember.
In Part 121 duty day limitations there was only a blanket
16 hour max duty day. Now we have to couple the
report time with number of segments flown to calculate
max FDP.

If a crewmember duties in between
600-659 local at their Domicile (Anchor City)

And the crewmember is scheduled
to operate 4 flight segments.
The crewmembers max FDP
is 12 hours.
The Journey to FDP
Exception to the rule.
As always there has to be
an exception to the rule.
When the exception is applied to FDP it is called an extension.
First and foremost extensions are
not an operational advantage, and
should not be used lightly. The FAA
recognizes the need for sometimes
breaking the FDP restrictions due
to unforeseen operational
circumstances.
There are 3 types of extensions. 2 of which have very specific criteria that has to be met for the extension to be used:
Any max FDP extension under 30 min has no repercussions, requires crew permission.
Any max FDP extension that occurs post take-off and is not something that can be accurately forecast by the Certificate Holder does not require flight crew permission to use. As soon as the flight safety lands the FDP is terminated.
Any FDP extension that may occur prior to take-off requires flight crew consent verbally or via ACARs, and the FDP terminates as soon as the flight safely lands.
Here is a schedule that is fully legal under part 121 flight duty limitations.
If we look at Table B FDP limits however the assignment now becomes illegal without the use of an extension prior to take-off.
Scheduling would have to contact the flight crew to even see if they will accept an extension.
How often will we use FDP extensions?
Short answer, not often.
FDP under no circumstances are an operational advantage.
Again,
in no way should we ever plan to use an extension
. Planning to use an extension goes against the very essence of the philosophy behind an extension. If it a circumstance that we can plan a head for then it is not an unforeseen operational circumstance, and therefore we should not plan to use an extension.
Answer:
Sparingly and only in unforeseen
operation circumstances.
How to go about using a FDP Extension
First things first, what type of FDP extension is needed?
Let us remember the two types of extensions beyond 30 min that come with repercussions.
Prior to take-off and post take-off extensions.
The end result of these extensions are the same, but us as schedulers really have no control of post take-off FDP extensions other than ensuring that FDP terminations happen right after the crew has landed at their destination or alternate airport and any schedule changes are made appropriately.
After each FDP extension paperwork has to be submitted to the FAA within 10 days. In other words this is a very serious exception, and is very unlike part 121 where every flight crew can be ran up to 16 hours and the only repercussion legally is Whitlow Rest, which is now the new minimum rest anyways. FDP extensions will be rare. Table B is slightly intimidating and it will be the job of anyone with any sort of exceptions open (exceptions, reroute, and supervisors) to recognize when exceeding max FDP will or has occurred.

FDP extensions are not an operational advantage.
FDP extensions are not an operational advantage.
Ever.
Pre Take-Off FDP Extension Procedure
FDP extensions are not an operational advantage.
Pre take-off FDP extensions are one shot, last minute, this flight will cancel unless scheduling and all involved get an extension approved.
Recognize when max FDP will be exceeded beyond 30 min.
Immediately bring this information to a supervisors attention.
Pre take-off extensions over 30 min. will have to approved by a supervisor before any further steps can be taken.
Again, paperwork must be submitted to the FAA within 10 days. Information why, when, who, and where the extension was used.
Also, we must submit to the FAA how we will take steps in the future to not need the use of an extension.
Example:
Flight 3256 goes on a rolling delay and an over max FDP exception occurs an hour and a half before departure. The rerouter looks for options to recrew, but we know late flights out of the smaller bases are difficult to recrew because lack of crews operating in and out the Hub. Our only viable option is to request an FPD extension of 1:02.
Take this information to a supervisor.
If the supervisor approves and FDP extension then Scheduling must contact the CA and request an extension from them.
Remember, the PIC has to approve an extension, even if it is just the FO who requires an extension. Yes
the FO must approve as well, but if the FO says
he or she will accept an extension and the
CA does not approve the extension for the
FO this process ends. The PIC has
final authority over both flight
crewmembers.
If all required flight crewmembers approve the extension, along with the supervisor on on the floor then we can permit the flight to operate.
If and only if the Certificate Holder and the Flight Crew accept an extension over 30 min
and under 2 hours can we allow the flight
to operate. If the CA and FO request and
scheduling decides that it is not
operationaly sound to use an
extension, then we will not use
it. It is up to the flight crew
accept an extension not
to initiate and follow
through with
one.
If a crew is on their last leg of the pairing and they really want to get home, and an extension of 2 hours is needed, but there may be a chance of busting the 2 hour extension then scheduling, the senior hub coordinators, and duty manager must be confident in denying the extension and canceling in order to not have to divert to another outstation and terminate FDP.
Even if a pre take-off extension is used there is a 2 hour limit. Once in the air if another unforeseen operational circumstance
arises that will take the crew over 2 hours we must divert to
the nearest suitable airport and terminate FDP.
Things to remember about FDP extensions.
While daily FDP extension prior to take-off are available, the Certificate Holder shall not approve any cumulative extensions.
No legal to start legal to finish!
Along with all the other criteria needed to use an extension:
Daily flight time limitations must be met.
Cumulative flight time in a rolling 672 hours and and 365 days limitations must be met.
FDP in a rolling 168 and 672 hours limitations must be met.
If all of these limits are met then the process of acquiring a FDP extension can continue.
Rest Period
Part 117 eliminates reduced rest. No longer will a flight crew have
a layover under 10 hours. Since reduced rest is no more, the need
for compensatory rest is eliminated, mostly, there are a couple of odd situations where a flight crew may require some comp rest.
At least 10 hour layovers will be given to flight crewmembers. In this greater than or equal to 10 hours of rest every night an opportunity for 8 hours uninterrupted sleep must exist. The flight crewmember decides when the 8 hour sleep opportunity starts. In the last class it was said that we no longer call during rest. Now our rule is simple, we still have one opportunity to contact the flight crew, but two criteria have to be met. First, if at any point scheduling can contact the flight crew and 9 hours of rest can be reset without taking a delay we can call. Secondly, 30 minutes prior to scheduled report time.
Release
Report
Rest Period
Sleep Opportunity
Release
Report
What is reduced rest for a flight crewmember under part 117?
Answer:
Trick question no such thing as reduced rest in part 117. If you did answer 10 hours that is still correct.
How does this affect Scheduling?
The largest adverse affect of 10 hr min rest will be crew rest delays. No longer will we be able to schedule repositions for canceled flights 8 hours later. Late inbound flight crews will always require 10 hours of rest. This is not negotiable. In the beginning flight crews may be ignorant to completely understanding these rules.
There is no waiving 10 hours of rest.
These limits are not contractual, but as we know laws. This puts extra pressure on evening Exceptions and Re-route positions to re-crew down line flying that we are used to being able to operate the next day or duty period only with 8 or 9 hours of rest.
10 Hours of rest,
.
This is what the exception looks like in the new CrewTrac with 117 rules loaded. It clearly shows this pairing is not giving the crewmember enough rest. The solution is to delay for crew rest in the morning and try to recover down line flying.
When can we make our 1 and only attempt to contact a flight
crewmember during his or hers protected rest?
Answer:
30 min prior to original scheduled report time, or at any point where we can reset 9 hours of rest without taking a delay.
The flight crewmember has the final decision
on when his or hers 8 hour sleep opportunity
begins. Our 1 opportunity to call the flight
crew must be thought about. If we stay set in
our ways after 117 rules enact, then we have the
potential to take massive delays due to rest. 30 min prior and any time when a rest period can be reset, but again we can only call once. Leaving comments and checking comments will be crucial to ensure more than one call does not happen.
So what happens if the flight crewmember's sleep opportunity is disturbed by outside factors the company cannot control, like a a fire alarm.
In this situation the flight crewmember is still the expert on whether his or her's rest has been disturbed. Everyone is different and the FAA does not want to impose a blanket ruling on how and when sleep is disturbed. That being said, if a flight crewmember's sleep is in fact disturbed, then it is the responsibility of that crwemember to contact the Certificate Holder and notify the opportunity for sleep has been disturbed and he or she will not be able to report fit for duty without adjusting report time. This means as soon as sleep is interrupted and "disturbed" they must contact us. Not 3 hours later at report time.
Anchor City- (domicile) for our purposes and Crew Trac limitations we will always calculate FDP duty-in times from the flight crews Anchor City.
What is the Anchor City and timezone for this crew?
On the last day of the pairing, when does the crew duty-in for FDP calculation?
This puts extra pressure
on scheduling to be
confident in calculating
duty-in and FDP.
If a flight crewmember
uses local time versus
Anchor City, it is our job to let
them know that is not how
FDP is calculated.
TDY's- if flight crewmembers are TDY'd we still use their anchor city to calculate FDP. This makes
TDY-ing from east to west advantageous, and
the inverse from west to east a disadvantage because they will duty-in
earlier than local eastern time.
Window of Circadian Low- (WOCL)- a period
of maximum sleepiness that occurs between
0200 and 0559 during a physiological night.
The WOCL is the only thing that we will use
actual local time for where the flight crew
is because the WOCL comes from the
rise and fall of the sun.
Unforeseen Operation Circumstance- an unplanned event of insufficient duration to allow for adjustments to schedules, including un-forecasted weather, equipment malfunction, or air traffic delay that is not reasonably expected.
It is the responsibility of the Certificate Holder to provide flight crewmembers with a meaningful opportunity for rest and sleep. It is also the responsibility for the flight crewmember to take advantage of that opportunity to report for FDP the
next day rested and ready to perform assigned
duties.
This is the best way to reduce fatigue
of flight crews.
Practice max FPD Calculations.
More practice.
Cumulative Limits
No certificate holder may schedule and no
flight crew member may accept an assignment
if the flight crew member's total Flight Duty Period will exceed:
60 flight duty period hours in any 168 consecutive hours and
190 flight duty period hours in any 672 consecutive hours.
Every Flight crew member must have 30 hours free from duty in a rolling 168 hours.
This rule replaces 1-in-7 or the need for a calendar day off.
That being said does this crew member have a legal schedule?
No.
From 7:49 on the 13th
to 7:49 on the 19th there
is no 30 hour free from
duty.
What does this mean for Scheduling?
Cumulative Limits being reached will
be more rare than daily FDP limits, but
none the less they are still vital to know and
understand. FDP extensions will be discussed
shortly, but while daily FDP limits do have an
extension, no cumulative limits do. No legal to start legal to finish.
It is crucial that everyone have their Table B on their desk for the entire shift every shift.
Table B is the most complicated part of 117 from the view of normal daily operation. It is going to take a lot of practice to become proficient at calculating daily FDP, keeping in mind Anchor City vs Local time.
If you have questions always ask.
Extending a reserve flight crewmember.
On the both sides of the operation we extend reserves, that is their upside. An issue with part 117 that greatly affects both sides of the operation is termination of FDP occurs at Block In of duty on the last leg the crewmember is notified of. Obviously the CRJ operation can notify via ACARS, but on the ERJ side it will be crucial to notify by any means possible before the return leg
Reserves
The new regulations have three reserve classifications:
Airport/standby reserve
Short-call reserve
Long-call reserve

Airport/standby reserve

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.

Long-call reserve
When contacted for an assignment on long-call reserve, the crewmember begins by receiving 10 hours of rest.
Contract still supersedes with 12 hour notification.
If the assignment begins before and operates into the pilot’s WOCL, the notification requires a 12 hour call-out.

All regular Table B limits apply to reserves. There is an additional step when calculating daily FDP for short call reserves. This also applies to ARC or Ready Reserve when placed on short call flight crewmembers.
Short-call reserve
The period that a pilot is on-call is referred to as the reserve availability period.
The RAP may not exceed 14 hours.
The RAP plus FDP may not exceed the FDP allowed in
Table B plus 4 hours
or
16 hours total
,
whichever is less
.

How does RAP affect FDP?
As of now, short call reserves have a 15 hour phone liability. We can assign any duty-in time with a 2 hour call out and any number of segs as long as the release time is within
the 15 hour duty. Under 117 Table B continues to
limit flight crews .

121 117
Conclusion
Again, while there may be similarities between Parts 117 and 121, after January 4th there will no longer be Part 121 rules. Part 117 completely replaces all previous.
Cumulative Flight Time Limits
Table A
The certificate holder may not assign and flight crewmembers may not accept an assignment that exceeds these limits.
Flashback:
What is the definition of FDP?
Flight Duty Period (FDP) - From the time the company require the crewmember report for duty until block-in of the last assignment requiring aircraft movement.
So how do DHDs affect FDP?
If the DHD occurs anytime before an operating segment it will count as FDP.

Therefore, if the DHD is at the end of a duty day with no intended aircraft movement scheduled it will not count towards and daily or cumulative FDP limits.
Prior to Take Off Extension Flow Chart
Post Take Off Extension Flow Chart
Converting To Short Call In a Pairing
When a flight is delayed in the outstation it is going to be a lot harder to notify crews of a change to their schedule. If we do not convert them to short call properly CrewTrac will flag exceptions on FDP limits.
Remove the delayed flight and any additional changes to the schedule and add the DTY leg to reflect the “Short call” Also use a “fak FAK” leg to prevent a city continuity. Modify.
Immediately go back and Add the delayed segmant in. This causes CrewTrac to see this flights delayed times as Scheduled and will default report time to 45 minutes prior to the new times.
This pilot is now entering the table at 12:50 instead of 8:50. The rest still ended at the same time 8:50 and the pilot was is on duty from 8:50 to 12:50.
Not many, since the contract is more strict on duty day limitations than the regs assigning open time will not change drastically.

Table B will always have to be consulted before a trip is assigned, but current contract limits still apply.
What changes occur while assigning open time?
Question:
Will we use FDP extensions?
The CA and FO must have 30 hours free from duty before another FDP extention can be used.
If the CA or FO has already used an extention, they shall not use another one until they have 30 hours of consecutive rest.
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