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Newsflash from ALPA International

ALPA’s FTDT ComparisonPart 2International Operations and how to apply some of the new rules
December 27, 2011
In the December 23, 2011 FastRead, we outlined some of the major differences between the current FAR Part 121 and the FAA’s new FAR Part 117, particularly for unaugmented operations. This Fastread will highlight the augmentation provisions contained in the new FAR. Note that we are not describing these changes in terms of domestic and international. The new FAR Part 117 was specifically designed to cover all operations, without differences in international, domestic or supplemental operations. This is just another important point as to why there should be no distinction between cargo and non-cargo operations and ALPA will continue to push to have cargo operations included. Remember, while the FAA announced and released their new regulation on December 21, 2011, the new FAA regulations do not take effect for 2 years, allowing time for your company, working with your MEC, to develop an implementation plan.

FAR Part 117 Flight Duty periods—Augmented Operations (Table C)

Scheduled Time
 of Start
(Acclimated Time)  

Maximum Flight Duty Period FDP (hours)
Based on Rest Facility and Number of Pilots  
Class 1 Rest Facility   Class 2 Rest Facility  Class 3 Rest Facility
3 Pilots   4 Pilots   3 Pilots   4 Pilots   3 Pilots   4 Pilots
00:00 – 05:59   15:00   17:00   14:00   15:30   13:00   13:30
06:00 – 06:59   16:00   18:30   15:00   16:30   14:00   14:30
07:00 – 12:59   17:00   19:00   16:30   18:00   15:00   15:30
13:00 – 16:59   16:00   18:30   15:00   16:30   14:00   14:30
17:00 – 23:59   15:00   17:00   14:00   15:30   13:00   13:30

Table C, Maximum Flight Duty periods—Augmented Operations, defines the maximum flight duty period that an acclimated augmented flight crewmember may be assigned or accept. It is very important to remember that this chart is the maximum FDP, not the maximum flight time. Just like Table B, Maximum Flight Duty Period, unaugmented operations, the chart is entered using the report time for the FDP.

Note: The ARC recommendations and the Notice for Proposed Rulemaking (NPRM) had the Scheduled Time of Start based on either home base time or acclimated time. ALPA believes that this should have been retained and will work with the FAA to obtain further clarification. It is important since it will have an effect on FDP lengths for west coast pilots starting duties on the east coast and vice versa. We will have more information in the future.

Before we run through some examples describing how to use this chart, here are some definitions and tables A and B that we’ll be using (these are not all of the definitions, just those used in the following examples):

“Acclimated” means a condition in which a flightcrew member has been in a theater for 72 hours or has been given at least 36 consecutive hours free from duty.

“Augmented Flightcrew” means a flightcrew that has more than the minimum number of flightcrew members required by the airplane type certificate to operate the aircraft to allow a flightcrew member to be replaced by another qualified flightcrew member for in-flight rest.

“Duty” means 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.

“Flight duty period (FDP)” means a period that begins when a flightcrew member is required to report for duty with the intention of conducting a flight, a series of flights, or positioning or ferrying flights, and ends when the aircraft is parked after the last flight and there is no intention for further aircraft movement by the same flightcrew member. A flight duty period includes the duties performed by the flightcrew member on behalf of the certificate holder that occur before a flight segment or between flight segments without a required intervening rest period. Examples of tasks that are part of the flight duty period include deadhead transportation, training conducted in an aircraft or flight simulator, and airport/standby reserve, if the above tasks occur before a flight segment or between flight segments without an intervening required rest period.

“Rest facility” means a bunk or seat accommodation installed in an aircraft that provides a flightcrew member with a sleep opportunity

(1) “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.

(2) “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.

(3) “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.

Table A, Maximum Flight Time Limits, Unaugmented Flightcrew

Time of Report (Acclimated) Maximum flight time (hours)
00:00-04:59 8:00
05:00-19:59 9:00
20:00-23:59 8:00

Maximum Flight Time Limits, Augmented Flightcrew

• 13 hours if the operation is conducted by a three pilot flight crew
• 17 hours if the operation is conducted by a four pilot flight crew

Table B, Maximum Flight Duty Period, Unaugmented Operations

Time of Start
(Acclimated Time)

Maximum Flight Duty Period (hours)
For Lineholders Based on Number of Flight Segments 
 

1   2   3   4   5   6   7+
00:00-03:59   9:00   9:00 9:00   9:00   9:00   9:00   9:00
04:00-04:59   10:00   10:00   10:00   10:00   9:00   9:00   9:00
05:00-05:59   12:00   12:00   12:00   12:00   11:30   11:00   10:30
06:00-06:59   13:00   13:00   12:00   12:00   11:30   11:00   10:30
07:00-11:59   14:00   14:00   13:00   13:00   12:30   12:00   11:30
12:00-12:59   13:00   13:00   13:00   13:00   12:30   12:00   11:30
13:00-16:59   12:00   12:00   12:00   12:00   11:30   11:00   10:30
17:00-21:59   12:00   12:00   11:00   11:00   10:00   9:00   9:00
22:00-22:59   11:00   11:00   10:00   10:00   9:00   9:00   9:00
23:00-23:59   10:00   10:00   10:00   9:00   9:00   9:00   9:00

These times are further reduced by thirty minutes if the crew is not acclimated.

Let’s look at a practical application. The first example is a flight flown from JFK to Madrid. Using the trip description, you can see that the report time is 1620. That time should be used to determine the allowable FDP and flight time:

Key points:

• Remember to enter the table with your report time, not your departure time.
• Both the FDP and flight time limit control. If either is exceeded, augmentation is required.

Now, let’s look at the return flight. In this case the report time is 0240 JFK time, based on a 90-minute report before a 0410 departure, also converted to JFK time (90 minutes report in this example is contractual for this carrier):

Let’s take another example where we will have to use Table C to determine the maximum augmented FDP and required crew compliment. In this example, a flight is scheduled from Detroit to Seoul Inchon. Using the trip description, you can see that the report time is 1055. That time should be used to determine the allowable FDP and flight time:

With it now determined that augmentation will be required, we move to Table C to determine the maximum augmented FDP:

Key points:

• Remember to enter the table with your report time, not your departure time.
• Both the FDP and flight time limit control. If either is exceeded, either a higher standard of rest facility must be used or an additional pilot be added.

In summary, as you can see the methodology to determine if you need an augmented crew and then determining the maximum FDP and required crew compliment is more complex than the current FAR.

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