Presentation on theme: "Understanding FAR Part 117"— Presentation transcript:
1 Understanding FAR Part 117 Flight and Duty Time Limitations and Rest Requirements: Flightcrew Members.Version 1.11Introduction
2 Introduction What is the FNPRM? When do the Airlines have to comply? The FAA published the FNPRM (Final Notice of Proposed Rule Making) on04Jan2012 in the Federal Register.The regulations establish:Pilot - Flight / Duty Time Limitations and Rest Requirements.When do the Airlines have to comply?Simply put, 04Jan2014, this date is two years since the publication date.What do the Airlines have to do to comply?Develop scheduling policies.Develop training programs.Update their Operations Specification (OPSPEC).Upgrade crewmember scheduling software, including crew planning and crew tracking software.Introduction
3 Intent of this presentation To summarize the following sections of the FNPRM.Applicability.Definitions.Flight time limitation.Flight duty period: Un-augmented operations.Flight duty period: Split duty.Flight duty period: Augmented flightcrew.Flight duty period extension.Reserve status.Cumulative duty limitations.Rest period.Consecutive nighttime operations.Intent
4 Not included in this presentation The following sections of the FNPRM.Fitness for dutyFatigue risk management systemFatigue education and training programEmergency and government sponsored operationsCurrent Omissions
5 Major Changes Applicability: Part 121 passenger operations must apply FAR part 117 for all operations conducted under -Domestic (subpart Q) orFlag (subpart R) orSupplemental (subpart S)Part 121 All cargo operationsmay still operate under FAR 121 subparts Q, R or S117.1 Applicability.subpart Qsubpart Rsubpart S
6 New scheduling concepts include: Major ChangesNew scheduling concepts include:Flight Duty Period (FDP)AcclimatizationWindow of Circadian Low (WOCL)Part 91 Flightsare now considered the same as Part 121 Flights when conducted during a series of FDP operating under 117.Note: clarifying questions to the FAA have been made concerning the required separation between Part 91 and Part 121 to qualify specific Part 91 flights not to be subject to FAR Part 117 .117.1 Applicability.117.3 Definitions.
7 Cumulative Limitations for: Major ChangesCumulative Limitations for:Flight Duty PeriodFlight Time (Block)Extended Flight Duty PeriodsConsecutive Night DutyFlight duty period: Un-augmented operations.Flight duty period: Augmented flightcrew.Cumulative duty limitations.Rest period.Consecutive nighttime operations.
8 Does not include at this time Part 135 operationsPart 91 Subpart K operationsPart 121 Flight AttendantsAirlines may elect to apply these rules to FA’s117.1 Applicability.
9 Basic Definitions Calendar day means a 24-hour period from 0000 through 2359 using Coordinated Universal Time (UTC) or local time (Base time).Dutymeans any task that a flightcrew member performs as required by the certificate holder, including but not limited to flight duty period, flight duty, pre- and post-flight duties, administrative work, training, deadhead transportation, aircraft positioning on the ground, aircraft loading, and aircraft servicing.Report timemeans the time that the certificate holder requires a flightcrew member to report for an assignment.Rest periodmeans a continuous period determined prospectively during which the flightcrew member is free from all restraint by the certificate holder, including freedom from present responsibility for work should the occasion arise.117.3 Definitions.Calendar day must be configurable since many clients use 0001 to 2400 in contract language and will most likely apply for an alternate interpretation.
10 Basic Definitions Scheduled means to appoint, assign, or designate for a fixed time.Sleep opportunitymeans a period of time when a crewmember is provided and allowed to be in a suitable accommodation to rest in.Suitable accommodationmeans a temperature-controlled facility with sound mitigation and the ability to control light that provides a flightcrew member with the ability to sleep either in a bed, bunk or in a chair that allows for flat or near flat sleeping position. Suitable accommodation only applies to ground facilities and does not apply to aircraft onboard rest facilities.Unforeseen operational circumstancemeans an unplanned event of insufficient duration to allow for adjustments to schedules, including unforecast weather, equipment malfunction, or air traffic delay that is not reasonably expected.117.3 Definitions.
11 AugmentationThe use of Augmentation is restricted under the following conditions:At least one flightcrew member with a PIC type rating must be present and alert on the flight deck at all times.A limitation of 3 flight segments in any FDP.Ninety consecutive minutes are available for in-flight rest for the pilot performing monitoring duties during landing.The flightcrew member who will be landing the aircraft on the final leg of the FDP is required to have 2 hours of uninterrupted rest in the second half of the FDP.Flight duty period: Augmented flightcrew.
12 AugmentationRest facility means a bunk or seat accommodation installed in an aircraft that provides a flightcrew member with a sleep opportunity.Class 1 rest facility means a bunk or other surface that allows for a flat sleeping position and is located separate from both the flight deck and passenger cabin in an area that is temperature-controlled, allows the flightcrew member to control light, and provides isolation from noise and disturbance.Class 2 rest facility means a seat in an aircraft cabin that allows for a flat or near flat sleeping position; is separated from passengers by a minimum of a curtain to provide darkness and some sound mitigation; and is reasonably free from disturbance by passengers or flightcrew members.Class 3 rest facility means a seat in an aircraft cabin or flight deck that reclines at least 40 degrees and provides leg and foot support.117.3 Definitions.Flight duty period: Augmented flightcrew.
13 Augmentation Applied Flightcrew Member Schemes All operational flights contained within a FDP shall be evaluated to determine the minimum applied scheme as follows:This is consistent with current FAR interpretations, to avoid circumvention of Flight Time / Flight Duty Time Limitations and Rest Requirements.FDP with more than 3 legs scheduled, must apply2 Pilot Schemes (Un-augmented).117.3 Definitions.Flight duty period: Augmented flightcrew.Explain TableGive an example – 3 legs - 4 pilots / 3 pilots / 4 pilots – will use 3 pilot schemeExplain that the crew requirements must look across all trips assigned to each particular flight.JL: (a) how will this be indicated to allow increased duty based on number of pilots (to designate a/c with rest facilities?)(b)(2) is based on local time at theater in which crew was last acclimated. How will this be accomplished?To accurately flag a crew that does not have proper rest and reduce FDP?What if trip was scheduled properly (future assignment) and due to a delay or reschedule the rest was not avail therefore no long acclimated?Reports needed to track
14 Augmentation117.3 Definitions.Flight duty period: Augmented flightcrew.Explain TableGive an example – 3 legs - 4 pilots / 3 pilots / 4 pilots – will use 3 pilot schemeExplain that the crew requirements must look across all trips assigned to each particular flight.JL: (a) how will this be indicated to allow increased duty based on number of pilots (to designate a/c with rest facilities?)(b)(2) is based on local time at theater in which crew was last acclimated. How will this be accomplished?To accurately flag a crew that does not have proper rest and reduce FDP?What if trip was scheduled properly (future assignment) and due to a delay or reschedule the rest was not avail therefore no long acclimated?Reports needed to trackExample 1: legal, complies with the requirement for 2 hrs inflight rest in the 2nd half of the FDP, for the pilot who will perform the landing on the final flight.Example 2: illegal, no 2 hr continuous rest in the 2nd half of the FDP can be found.
15 Augmentation117.3 Definitions.Flight duty period: Augmented flightcrew.Explain TableGive an example – 3 legs - 4 pilots / 3 pilots / 4 pilots – will use 3 pilot schemeExplain that the crew requirements must look across all trips assigned to each particular flight.JL: (a) how will this be indicated to allow increased duty based on number of pilots (to designate a/c with rest facilities?)(b)(2) is based on local time at theater in which crew was last acclimated. How will this be accomplished?To accurately flag a crew that does not have proper rest and reduce FDP?What if trip was scheduled properly (future assignment) and due to a delay or reschedule the rest was not avail therefore no long acclimated?Reports needed to trackExample 1: legal for a 3 or 4 pilot flightcrew, complies with the requirement for 2 hrs inflight rest in the 2nd half of the FDP and a 90 minute inflight rest for the pilot performing monitoring duties during landing.Example 2: legal for a 4 pilot flightcrew only, the inflight rest periods must overlap.
16 Flight Duty Period (FDP) Release TimeReport TimeDuty TimeArrive TimeFDPNote:Difference between Duty Time and FDP12112191DHD117.3 Definitions.Describe the basic elements contained within a FDP.How those elements are defined using atomic elements.AWAC – the concept of a FDP seems confusingAS-A DHD segment is not a Flight Segment but is a part of the FDP. If a DHD segment is by itself in a duty period it is not part of a FDP (see definitions p. 398).BlockFlight Time Between Rest PeriodsFlight Time between rest periods -is the sum of the Block for all legs contained within the duty period.
17 AcclimatizationA Theater is a zone 60 degrees wide, relative to the departure station of the duty period.JFK 073 deg WestSFO 122 deg WestCDG 002 deg EastJFK to SFO is in the same Theater. 49 deg differenceJFK to CDG Exits the Theater. 75 deg difference117.3 Definitions.JL: how will acclimatization be tracked, applied (warning message)?
18 Theater 2 un-acclimated AcclimatizationA crewmember is deemed to be acclimated whenever that individual has either:At least 36 hours continuous rest within a specific theaterorHas remained in a specific theater for at least 72 hours.Otherwise the individual is NOT acclimated.JFK - CDGCDG – ATH - CDGCDG - JFKRest < 36Rest >= 36117.3 Definitions.(From FNPRM section B 1)Discuss possibility that a Flightcrew member may never receive a rest period during a Physiological night either referenced to the station of last acclimatization, or at the theater in which they are currently operating in a 72 hour span.One of the principles is that for a flightcrew member to become acclimated, that individual must have a rest period that includes a Physiological night.When a person has accumulated a sleep debt, recovery sleep is necessary to fully restore the person’s ‘‘sleep reservoir.’’ Recovery sleep should include at least one physiological night, that is, one sleep period during nighttime hours in the time zone in which the individual is acclimated. The average person requires in excess of 9 hours of sleep at night to recover from a sleep debt.The ARC also concluded that a flightcrew member can become acclimated by either receiving three consecutive physiological nights’ rest or a layover rest period of 30 to 36 consecutive hours.AS - The Crew would not become acclimated to JFK until receiving 36-hours rest or been in theatre for 72-hours. Pilots who are not acclimated also have reduced FDP limits. THE CREW IS ACCLIMATED AT TIME of REPORTHow will Jeppesen track the 60 degree rule and if a pilot is acclimated to a specific Theatre?Good question – we will need to store the longitude in the database, this must be a floating number, not an integer, to be consistent with the standards set in the US AIP, Lat/Lon are stored as [D]DD-MM-SS.ss this equates to [D]DD.dddddd.FAA Confirmed that they expect the air carrier to use the mathematical equivalent of the official values for an airport as stored in the AIP for that specific airport.Where are the Flight Time (block) limitations if a crew was not acclimated? SLIDE 24Can you go over each of these? YESIs this a list of items that are impacted if a pilot is not acclimated? YESIntention was to always receive a local nights rest, a 36 hour rest guarantees that, while a 72 period may not always guarantee that.The FAA will submit a clarification. 20-Mar-2012Time in Theater < 72Theater 1 acclimatedTheater 2 un-acclimatedTheater 2 acclimatedCrewmember will remain un-acclimated until the 36 hour rest period has been received.
19 AcclimatizationThe FAA issued a letter of interpretation on 30-November-2012The revised final rule states that theater is the geographical area in which the distance between the FCM's departure and arrival point differ by no more that 60 degrees.You could have a scenario where a pilot starts a series of FDPs and heads west 60 degrees, lays over, flies east to the point of origination, lays over and then continues going east 60 degrees.In this case, the FCM is still within a theater that is technically 120 degrees wide.Observations concerning the FNPRM.
20 Acclimatization Acclimatization effects: Daily FDP Limitations Daily Flight Time LimitationsRest RequirementsApplication of WOCL RulesApplication of Night Duty RulesObservations concerning the FNPRM.
21 WOCLPhysiological night’s rest means 10 hours rest that encompasses the hours of 0100 and 0700 at the crewmember’s home base, unless the individual has acclimated to a different theater. If the crewmember has acclimated, the rest must encompass the hours of 0100 and 0700 at the acclimated location.Window of circadian low means a period of maximum sleepiness that occurs between 0200 and 0559 during a physiological night.117.3 Definitions.Discuss that the FAA definition of the WOCL may/may not agree with pre-existing definitions an Air Carrier may already have.JL: physiological night’s rest: 10 hours rest that encompasses…
22 Split Duty Period Duty Break: Split Duty: Is a span of time in which an individual is in a suitable accommodation (Hotel) for no less than 3:00 and not more than a required rest period.A duty break must occur between 22:00 and 05:00A duty break is NOT considered a rest period.A duty break is scheduled prior to the start of the FDP.The actual duty break given must be no less than the scheduled duty break.Split Duty:Is a duty that contains a duty break.117.3 Definitions.Flight duty period: Split duty.JL: (c) : ruletalk will need to flag that there is a rest period scheduled/ rescheduled after the start of the FDP.(e) first segment refers to operational flight; ferry or live? (is limo or deadhead included)Actually it is after the first segment, thereby this refers to any leg, live dhd or nonfly.(f) if scheduled under 14 hours, is there a penalty for exceeding due to delay?This is a hard rule and the FAA will cite a violation.Should there be a warning? track these events?Check-In TimeDuty BreakCheck-Out TimeGround TimeArrival TimeDepart Time
23 Split Duty Period Split Duty: The Total of the FDP’s Before and After the Duty Break – must not exceed the limits in Table B.Check-In TimeDuty BreakCheck-Out TimeGround TimeArrival TimeDepart TimeFlight duty period: Split duty.AS - The rest period does not begin until the pilot reaches the rest facility.I take it you meant DUTY BREAK, Jeppesen expects that the crewmember will go right to the suitable accommodation, travel time to/from the facility must be accounted for.AS – will not use the split duty provision.FDP – Before BreakFDP – After Break
24 Split Duty Period Split Duty: The Total of the FDP’s Before and After the Duty Break – must not exceed the limits in Table B.Scheduled Time of Start(Acclimated Time)Maximum Flight Duty Period (hours) for Lineholders Basedon Number Of (Operational) Flight Segments1234567+9101211.51110.5131412.5Flight duty period: Split duty.The split duty rest must be scheduled and the actual rest may not be less than the scheduled split duty rest (in the suitable accommodation).If I understand your question correctly, if the flightcrew member was scheduled to have 3 hours split duty rest in the suitable accommodation and actually received 4 hours, then the credit would be based upon 4 hours.HOWEVER, the combined FDP and split duty rest may not exceed a total of 14 hours.So, you check in at 2130 hours for 4 segments, the maximum FDP is 11 hours.You are scheduled to have 4 hours in the suitable accommodation, the max time you can be on FDP (combined FDP and split duty break) is 14 hours as it is capped per the regulation.If, however, you check in at 2300 hours and schedule to fly 4 segments, the max FDP is 10 hours.You are scheduled for a 3 hour split duty rest, now the maximum time you can be on FDP is 13 hours (10 hr FDP + 3 hours split duty break).Given the same conditions, if they wanted you to be on duty for 14 hours, they would have to give you 4 hours split duty rest (10 hr FDP + 4 hours split duty rest).The key is to understand that they must schedule the rest, you must actually receive the scheduled amount of rest or more in a suitable accommodation, the scheduled rest period in the suitable accommodation does not include the time to and from the suitable accommodation and the duty period is capped.I hope this answers your questions.Dale E. RobertsAviation Safety InspectorAir Transportation DivisionPart 121 Air Carrier Operations, AFS-220 Federal AviationAdministration800 Independence Avenue, SWWashington, DC 20591Office:Fax:
25 Combined FDP’s and Duty Break Split Duty PeriodSplit Duty:The Combined FDP and Duty Break may not exceed 14:00Check-In TimeDuty BreakCheck-Out TimeGround TimeArrival TimeDepart TimeFlight duty period: Split duty.AS - The rest period does not begin until the pilot reaches the rest facility.I take it you meant DUTY BREAK, Jeppesen expects that the crewmember will go right to the suitable accommodation, travel time to/from the facility must be accounted for.AS – will not use the split duty provision.Combined FDP’s and Duty BreakFDP – Before BreakFDP – After Break
26 Night Duty Night Flight Duty Period (NFDP): Is a Flight Duty Period which infringes upon any portion of the WOCL.123456WOCLConsecutive NFDPs are those which occur during the WOCL on consecutive calendar days.A duty break is a period in which a Flightcrew member is given a sleep opportunity in a suitable accommodation of at least 2 hours between 22:00 and 05:00.Note: A sleep opportunity greater than or equal to 2 hours but less than 3 hours will not qualify a FCM to operate under Split duty limitations (FAR )Consecutive nighttime operations.(AWAC - had a difficult time understanding duties that begin with the WOCL.)(Reg is quoted here)A certificate holder may schedule and a flightcrew member may accept up to five consecutive flight duty periods that infringe on the window of circadian low (WOCL), if the certificate holder provides the flightcrew member with an opportunity to rest in a suitable accommodation during each of the consecutive nighttime flight duty periods.The rest opportunity must be at least 2 hours, measured from the time that the flightcrew member reaches the suitable accommodation, and must comply with the conditions specified in § (a), (c), (d), and (e).Otherwise, no certificate holder may schedule and no flightcrew member may accept more than three consecutive flight duty periods that infringe on the window of circadian low.For purposes of this section, any split duty rest that is provided in accordance with § counts as part of a flight duty period.Requests for Clarifications have been made to the FAA by Jeppesen.
27 Night Duty Night Flight Duty Period (NFDP): A flightcrew member is not allowed to be assigned to more than 3 consecutive NFDPs – unless the following conditions are met …123456WOCLConsecutive nighttime operations.All of the NFDPs must contain a duty break.The Flightcrew member may be assigned a maximum of 5 consecutive NFDPs.
28 suitable accommodation Rest in asuitable accommodationSuitable accommodation:Shall only be applied to ground facilities and not to aircraft onboard rest facilities.Example – HotelRest Period: Sleep opportunity:Measured from Release to Report. Measured from Hotel Check-in to Hotel Check-out.Check-InSleep OpportunityCheck-Out117.3 Definitions.Rest period.Discuss how CMS will need to estimate the travel time to/from a suitable accommodation.Discuss how CMS will need to apply the rule at base.Allow customers to suggest possible solutionsAS - How did you determine that sleep opportunity ( (e) ) is from Check-in to Check-out? I might agree in theory that the rest opportunity does not begin until the pilot has the opportunity to rest but should a pilot choose not to go directly to the hotel that does not mean the sleep opportunity of 8-hours was not provided.Jeppesen expects that the crewmember will go right to the suitable accommodation, travel time to/from the facility must be accounted for.We should have a normal expected Travel time to/from the Hotel.AS – will mandate that the crewmember is given 10:00 rest period in all cases, expected travel time is less than 1:00 according to AS so the crewmember will always be given the 8:00 sleep opportunity.ReleaseRest PeriodReport
29 Rest Requirements Minimum Rest before a FDP or Reserve: Rest Period of 10:00 andSleep opportunity of 8:00(117.25(e) refers)Minimum Rest after a DHD that exceeds The FDP limit in table B:Rest Period of max of DHD time or 10:00( (g) refers)Required Rest in 168:00 all operations:At least one rest period of 30:00 must be found in the previous 168:00 measured from the scheduled start of the Reserve or FDP.Required Rest at Base after a change in Theater for a series of FDP that exceed 168:00:3 Physiological night’s rest with a minimum rest period of 56 hours.Rest period.Actual evaluation must be done at the end of each leg, an illegal leg should be flagged on the 1st occurrence within a FDP.AWAC had a difficult time understanding lookback rest in 168:00AS -Minimum actual rest prior to a FDP is 10-hours. A Sleep opportunity of 8-hours must be provided within those 10-hours.Jeppesen – the crew member must be SCHEDULED for a 10:00 rest period ( e)) , the ACTUAL SLEEP OPPORTUNITY must never be less than 8:00.Eg) ½ hour travel time with a 11:00 SKED rest period release to report this equates to 10:00 scheduled SLEEP OPPORTUNITY a delay of 2:00 occurs - the ACTUAL Rest period is 9:00 the ACTUAL rest opportunity is 8:00 LEGAL FJL: (g): Deadhead may exceed table B, but must be given rest equal to Deadhead, not less than 10 Hours (required rest min)A sleep opportunity must be able to guarantee 8 hours of un-interrupted rest (117.25(f) refers)
30 Rest Requirements123456789Rest period > = 3030 hr168 hour lookback from start of FDP / Reserve - legal168 hour lookback from start of FDP / Reserve - illegalRest period.Actual evaluation must be done at the end of each leg, an illegal leg should be flagged on the 1st occurrence within a FDP.Discuss that some airlines already have a calendar day off requirement, this could cause an FAA legal rest period of 30 hr to be extended,Eg) rest period of 36:00 begins at 06:00 on day 1 and continues to 18:00 on day 2, the calendar in 7 rule could end up requiring that the rest period be increased to 42:00, Airlines will need to come to some agreement with the pilots union.Duty PeriodRest PeriodFDPApplication of 30 hour rest period within the past 168 consecutive hours.
31 Daily Flight Time Limitations Un-Augmented Operations:Limited to flight time limitations in Table A for that duty period.The start time is relative to the Report time of that duty period.Augmented Operations:Limited to 13:00 scheduled flight time for that duty period for 3 pilot flight crewLimited to 17:00 scheduled flight time for that duty period for 4 pilot flight crewTime of Report (Acclimated)Maximum Flight Time (hours)89Table AFlight time limitation.Describe the reverse situation, 4:20 actual then 4:41 due to a delay after takeoff, that situation is legal, since it was due to a situation that was un-forseen to the airline.Discuss how this is different from currrent 121 regs.AWAC – understood that ‘Legal to Start Legal / Legal to Finish’ no longer applies.AS - Based on Scheduled times today (good to start).Need to develop a process for receiving updates from Dispatch directly updating Maestro.Need to be able to separate out pay (FDP) and flight times (block). Considerations deicing, taxi etc.Jeppesen – This is based upon the scheduled report time at the time zone to which the crewmember is currently acclimated to.Flight following feeds should account for the actuals.Same type of rule as ‘Whitlow’, you cannot expect to take off and violate the limitations, but once in the air it is OK.
32 Daily Flight Time Limitations 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:Will exceed the limits specified in Table A of this part if the operation is conducted with the minimum required flightcrew.Will exceed 13 hours if the operation is conducted with a 3 pilot flightcrew.Will exceed 17 hours if the operation is conducted with a 4 pilot flightcrew.(Currently under 121 Regulations this is a scheduled flight time limit)Flight time limitation.Describe the reverse situation, 4:20 actual then 4:41 due to a delay after takeoff, that situation is legal, since it was due to a situation that was un-foreseen to the airline.Discuss how this is different from current 121 regs.AWAC – understood that ‘Legal to Start Legal / Legal to Finish’ no longer applies.4:204:20Total scheduled flight time 8:404:414:20Total flight time 9:01 (due to late arrival on leg 1)
33 Daily FDP Limitations Un-Augmented FDP: Based upon the Time of Report andthe number of (operational) flight segmentsThe scheduled FDP may not exceed the limits in Table B.Non-Acclimated FDPs shall reduce the limits in Table B by 0:30Scheduled Time of Start(Acclimated Time)Maximum Flight Duty Period (hours) for Lineholders Basedon Number Of (Operational) Flight Segments1234567+9101211.51110.5131412.5Flight duty period: Un-augmented operations.(FNPRM – preamble – B-7)Secondly, the FAA includes in this definition that deadhead transportation is not considered a segment for purposes of determining the maximum flight dutyperiod in Table B.Explain why we are inserting Operational into the header.Tell Bea we are removing DHD’s.Table B
34 Scheduled Time of Start Daily FDP LimitationsAugmented FDP:Based upon:the Time of Report andthe number of flight crew andthe type if in-flight rest facility on board,The scheduled FDP may not exceed the limits in Table C.Non-Acclimated FDPs shall reduce the limits in Table C by 0:30Scheduled Time of Start(Acclimated Time)Maximum Flight Duty Period (hours) Based on Rest Facility and Number of PilotsClass 1 Rest FacilityClass 2 Rest FacilityClass 3 Rest Facility3 Pilots4 Pilots15171415.51313.51618.516.514.51918Flight duty period: Augmented flightcrew.Table C
35 Daily FDP Limitations Un-Augmented FDP: Augmented FDP: May be extended up to 2:00Augmented FDP:FDP extensions beyond 0:30 may not occur more than once in any 168:00 period unless an intervening rest period of 30 hours may be found.FDP extensions beyond the Daily Scheduled Limitation in table B/C are further limited should the extension exceed the Cumulative FDP Limitations in FAR (c).Flight duty period: Un-augmented operations.Flight duty period: Augmented flightcrew.Flight Duty Period Extensions.AWAC – thought that they would only allow for extensions up to 0:30AS - Ability to track FDP extensions by crewmember – Jeppesen - AgreesAbility to see in Maestro if one crewmember has been extended but not the other (CA/FO) – Jeppesen – AgreesStress:Most operators will most likely schedule less than the scheduled FDP limitEg) 8:00 planned FDP with a scheduled FDP limit 13:00 for 4 operational flights for a report time 07:00-11:59 ref Table B, in this case there is a 5:00 buffer to the scheduled limit plus a 0:30 limit with an additional 1:30 limit to the max extended limit (15:00) for a total buffer of 7:00.In planning and Tracking:Delays of 2:00 or less, are common with delays of 0:30 or less, being more frequent.In planning:Penalties could be utilized:A logical conclusion is that penalties based upon a FDP that is scheduled to conclude within 1:30 of the planned FDP limit should be penalized. A linear costing system based upon how close to the max extended FDP limit.eg) maximum of ( 1:30 – (planned FDP limit – planned fdp) or 0:00 ) multiplied by a fdp planned cost rate per minuteThe penalization could be further refined to add further costs if the planned fdp is within 2:30 of the max extended fdp limit.Eg) maximum of ( 2:30 – (max extended fdp limit – planned fdp) or 0:00 ) multiplied by a fdp extended cost rate per minuteThe first penalty would discourage FDP from being built that are within 2:00 of the planned FDP limit + 0:30.The second penalty would add further costs if the FDP were constructed within the 0:30 of the planned limit.In tracking:Cautions messages could be utilized.The Caution messages would need to be based upon how close the estimated arrival time (ETA) is to an expiration time, and the estimated time enroute (ETE).Three expiration times will need to be calculated:expiration time planned = report time + planned fdp limit - ETEexpiration time extended = report time + planned fdp limit + 0:30 - ETEexpiration time max extended =report time + max permitted extension ( 2:00 or 0:30 based upon whether a 2:00 is allowed due to previous extensions within theprevious 168:00) + planned fdp limit - ETETests to see if the System time is within 2:00 of any of the three expiration times should be made as long as the flight is not in an IN, ON, OFF, or CANCELED state. Any flight that is within any of those three times, detailing which limit is to be violated, and how much time is left until the flight will be illegal to actually takeoff and must return to the gate.
36 Daily FDP LimitationsFlight duty period: Un-augmented operations.Flight duty period: Augmented flightcrew.Flight Duty Period Extensions.Lookback is from the start of a FDP.Should a FDP that has been extended by more than 0:30 be found in the past 168:00 and no intervening rest period of 30:00 or more can be found in since the end of the previous extended FDP, then the FDP being evaluated may not be extended beyond the max scheduled FDP + 0:30, versus the max scheduled FDP + 2:00.Application of FDP extensions greater than 0:30 in any 168 hour period
37 Daily FDP LimitationsFlight duty period: Un-augmented operations.Flight duty period: Augmented flightcrew.Flight Duty Period Extensions.Lookback is from the start of a FDP.Should a FDP that has been extended by more than 0:30 be found in the past 168:00 and no intervening rest period of 30:00 or more can be found in since the end of the previous extended FDP, then the FDP being evaluated may not be extended beyond the max scheduled FDP + 0:30, versus the max scheduled FDP + 2:00.JL: (b) (2): the applicable flight duty period is based on the local time at the theater in which the flight crew was last acclimated (how will this be accomplished?)(b) (2): the applicable flight duty period is based on the local time at the theater in which the flight crew was last acclimated (how will this be accomplished?)(a) (3) a FDP cannot be extended…if it causes a flight crew member to exceed cumulative FDP.(b) (3) (augmented) can be extended…may exceed cumulative FDP.FDP on day 8 is illegal if it is extended more than 0:30 beyond the scheduled FDP limit
38 Is a Lookback from point of evaluation Accumulative LimitationsToday Day 7Day 1Day 2Day 3Day 4Day 5Day 6Day 8Day 9Is a Lookback from point of evaluationCumulative duty limitations.Explain that these are scheduled limitations.Express concerns that airlines may wish to apply 28 day limits versus 672 hr limits. ( this may be difficult fo rthe crewmember but the FAA stood firm on this.AS - FDP limitations should include look forward calculationsJeppesen – The Tracking system should always be checking all FUTURE events – Maestro always does.Discuss that 30 in 7 / 32 in 7 / 100 in 30 days / 100 in Calendar month / 1000 in calendar year / 1000 in 12 calendar months no longer apply.Uses Actual values for previously performed activities.Scheduled values for activities to be completed
39 Accumulative Limitations Flight Time Limitations:May not exceed 100:00 in 672:00May not exceed 1000:00 in 365 Calendar Days (Base Time)Two checks required for legs that cross midnightFDP Limitations:May not exceed 60:00 in 168:00May not exceed 190:00 in 672:00Extended FDP before takeoff may NOT cause a violation ofCumulative FDP Limits ( (a)(3) refers)Lookback is from arrival time of leg or Midnight.Lookback is from arrival time of leg.Cumulative duty limitations.Explain that these are scheduled limitations.Express concerns that airlines may wish to apply 28 day limits versus 672 hr limits.Cumulative FDP will use latest available FDP, ASB. Time assigned to SC and LC before a FDP is NOT to be applied towards the FDP limit.20-Mar-2012CM may not be allowed to extend a FDP if the Extended FDP will cause a Cumulative FDP Violation.20-Mat-2012
40 Reserves Airport Standby (ASB): Short Call Reserve (SC): Occurs when a crewmember reports for flight duty at a specific location to await assignment to a trip.Is considered duty as well as flight duty period.Is subject to flight duty limitations.Is subject to rest requirementsShort Call Reserve (SC):means a period of time in which a crewmember does not receive a required rest period following notification by the certificate holder to report for a flight duty period.Is subject to flight duty limitations when assigned to a FDP.Long Call Reserve (LC):Is NOT considered duty OR flight duty period.Will require an intervening rest period prior to being assigned to a SC Reserve or FDP when a flightcrew member is notified by the certificate holder to report for duty.117.3 Definitions.Reserve status.Discuss with users about the different types of Reserves currently used within their particular system.Questions to FAAWhat about ASB or SC Before a Split Duty? How is the crewmember supposed to manage their pre-FDP rest to manage fatigue?
41 Reserve Limitations Report Arrive Time Airport Reserve FDPAirport ReserveFDP for Airport Reserve (ASB):Is measured from Report of the Reserve to the later of Release from the Reserve or the last operating Flight in the 1st FDP.FDP Limits:Is from Table B, using the Report time of the Reserve and the number of flights, If the ASB is not assigned a trip the FDP shall be limited using 1 Flight.Reserve status.Questions to FAAWhat about ASB Before a Split Duty?Are we to use TABLE B or are we to use Split Duty FDP Limit of 14:00.JL: ASB limitation based on report time, rest after 10 hours?FDP limit is based upon ASB Report.ASB must be scheduled to have 10 hrs rest before
42 Reserve Limitations Reserve Availability Period(RAP): Start of SC Arrive TimeReport of TripFDPShort Call ReserveReserve Availability Period(RAP):Is 14:00 maximumthis is the time frame that an air carrier may contact, require a flightcrew member to report to a trip.Reserve status.Trips assigned outside the RAP require a minimum rest period of 10:00 with a minimum sleep opportunity of 8:00.
43 Combined RAP and FDP Limit Reserve LimitationsCombined RAP and FDP for Short Call Reserve (SC):Is measured from start of the reserve to the later of release from the reserve the last operating Flight in the 1st FDP.Combined RAP and FDP LimitArrive TimeStart of SCReport of TripFDPShort Call ReserveReserve status.Questions to FAAWhat about SC Before a Split Duty? Are we to use TABLE B or are we to use Split Duty FDP Limit of 14:00 + 4:00.Is the FDP Limit from Table B, Are we to enter the table using the report time of the FDP or the Start Time of the SC ?Uses the Start Time of the SC. FAA 20-Mar-2012Combined RAP and FDP LimitsUn-Augmented Operations:Is the lesser of:16:00Table B + 4:00applied to the start time of the RAPUse the Start Time of the FDP to find the FDP limit from Table B + 4:00.
44 Combined RAP and FDP Limit Reserve LimitationsCombined RAP and FDP for Short Call Reserve (SC):Is measured from Report of the reserve to the later of Release from the reserve or the last operating Flight in the 1st FDP.Combined RAP and FDP LimitStart of SCArrive TimeReport of TripFDPShort Call ReserveReserve status.Questions to FAAIs the FDP Limit from Table C, Are we to enter the table using the report time of the FDP or the Start Time of the SC ?Uses the Start Time of the SC. FAA 20-Mar-2012Combined RAP and FDP Limits Augmented Operations:Is Table C + 4:00, applied to the start time of the SC.Use the Start Time of the FDP to find the FDP limit from Table C + 4:00
45 Reserve LimitationsReserve status.Questions to FAAIs the FDP Limit from Table C, Are we to enter the table using the report time of the FDP or the Start Time of the SC ?Uses the Start Time of the SC. FAA 20-Mar-2012In this example, the FCM is strictly limited by the permitted extensions for the FDP assigned during RAP, where No extension beyond 1900 will be permitted.
46 Reserve LimitationsReserve status.Questions to FAAIs the FDP Limit from Table C, Are we to enter the table using the report time of the FDP or the Start Time of the SC ?Uses the Start Time of the SC. FAA 20-Mar-2012In this example, the crewmember is strictly limited by the permitted extensions of the FDP assigned during the RAP, and no further extension beyond 20:00 will be permitted if the condition is known before takeoff. As you can see the FDP is extended beyond the combined RAP and FDP limit of 16:00.
47 Reserve LimitationsReserve status.Questions to FAAIs the FDP Limit from Table C, Are we to enter the table using the report time of the FDP or the Start Time of the SC ?Uses the Start Time of the SC. FAA 20-Mar-2012In this example, we can see how the combined RAP and FDP limitation is now the controlling factor.Since the Combined RAP and FDP, requires a scheduled end of the FDP by 19:00, it will only be permitted to be extended by 2:00 until 21:00, even though the FDP assigned during the RAP would permit the extension to 22:00.Extension rules that are still in effect are previous extensions beyond 0:30 within the previous 168:00 without an intervening rest greater than or equal to 30:00, and Cumulative FDP limitations.
48 Reserve Limitations Required Rest period after Long Call Reserve (LC): WOCLRelease from(End of) LCReport of TripLong Call ReserveRest PeriodTime of Notification>= 12:00Reserve status.Required Rest period after Long Call Reserve (LC):Is 10:00 if assigned to a Trip, SC reserve, ASB reserve.If the following Flight Duty Period Operates Into the WOCL:The FCM must have at least 12:00 notification prior to the report of the FDP.
49 Re-Scheduling FDP Start Time Long–Call MethodRest PeriodWOCLAt Time of Notification it must provide for a Rest Period of 10 hours and a Sleep Opportunity of 8 hours.Time of NotificationSleep opportunityTime of NotificationReserve status.NotificationAt least 12 of Notification must be given if the FDP will operate into the WOCL it must provide a Rest Period of 10 hours and a Sleep Opportunity of 8 hours.Sleep opportunityRe-Scheduled FDP start time.Daily FDP limitations Table-B/C with permitted extensionswill use the Re-Scheduled FDP start time.
50 Re-Scheduling FDP Start Time Short–Call MethodRest PeriodAt Time of Notification it must provide for a Rest period of 10 hours with a Sleep opportunity of 8 hours.Time of NotificationNotificationSleep opportunityOriginal FDP start time.Time from Original FDP start Time toRe-Scheduled FDP start time is consideredto be Time on Short-Call Reserve.Reserve status.Re-Scheduled FDP start time.Daily FDP limitations Table-B/C with permitted extensions will use theRe-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
51 Re-Scheduling FDP Start Time Without using Long/Short Call Reserve Rest PeriodTime of Release from the Duty PeriodThe Time of Release from the Previous Duty period must provide for a Rest period of 10 hours with a Sleep opportunity of 8 hours.Sleep opportunityReserve status.Original FDP start time.Re-Scheduled FDP start time.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 to the Re-Scheduled FDP start time will Not be considered towards the Cumulative FDP Limits in 168 / 672 hours.The Period / Sleep opportunity will be permitted to overlap the time from scheduled Start of the FDP to the Re-Scheduled start of the FDP.