121.505

[DC8 Flyer]

Anyone have access and can post any legal interps the feds may have on applying 121.505. The way I understand it, legal to start legal to finnish, is a leg by leg basis, not a full day(s) schedule.

 

[pianoman]

As far as I know the Whidlow (sp?) 16 hour duty day limit is applied on a leg-by-leg basis, meaning you can't start that last flight if you know you'll exceed 16 hours (with the debrief) based on expected taxi and flight time. The 8 hours max scheduled flying is a legal to start the day thing which is applied unless scheds has modified your day. (A diversion does not count; it is looked at as your originally scheduled trip.)

This is my airline's view.

 

[DC8 Flyer]

The 8 hour one, is the one I think there is a lot of "confusion" on. The regs use language like scheduled "flights". I take that to mean a leg by leg basis. If I have four, 2 hour legs scheduled, and at the end of leg 3 I have 6.1 hours on me, I can not legally do the last leg, since it is "scheduled" to put me over 8. This whole "legal to start, legal to finnish" I think, applies on a leg by leg basis, not a "day". No where in the regs (121, supplemental that is) does it state day or sequence, just "not to be scheduled for more than 8 hours of flight duty...)

 

[BusdrivnAce]

I agree with pianoman, i've done 10.2 hr days that end when I hit 16 hrs. duty. My crew sched uses the start of the day premis, and I have never heard of them being questioned. Supp may be different though, haven't even dreamed of looking at those regs.

 

[DC8 Flyer]

Ive done the plus 8 hour block as well, but it was because all of my other flights were actually under block and more trips were added through the day. The last leg was "legal" because I had 7.2 on me, but the leg was only blocked for .6. Turned out to be a 1.5 hour leg and wammo over 8. Now if you go back and add up what the "original" schedules were it was something liek 10.5 hours.

What I am looking for is some kind of FAA interp that specifically says, legal to start legal to finnish applies to a day or to each specific leg. I don't eve know where to look for something like that.

 

[chperplt]

The rule hasn't changed..

Legal to start / Legal to finish is for your scheduled DAY.... Unless your schedule has been altered after the start of your day.

You can fly 10+ hours legally if you are on the same schedule you started the day with. Once your schedule changes from its original format, you then become LEG to LEG.

Whitlow has nothing to do with Legal to start / Legal to finish. Whitlow deals with minimum rest during a 24 hour period.

 

[DC8 Flyer]

The rule hasn't changed..

Legal to start / Legal to finish is for your scheduled DAY.... Unless your schedule has been altered after the start of your day.

You can fly 10+ hours legally if you are on the same schedule you started the day with. Once your schedule changes from its original format, you then become LEG to LEG.

Whitlow has nothing to do with Legal to start / Legal to finish. Whitlow deals with minimum rest during a 24 hour period.

Where is that spelled out though. I understand that is how some people interpret the rule but I cannot find a FAA interpret on it. I, and a I'm not alone, think that once you go over or under your scheduled block, that is a "change" to the schedule. And which schedule counts, the crew card block times or the flight plan scheduled time? There is no definition in the regs for "scheduled".

(g) A flight crewmember is not considered to be scheduled for flight time in excess of flight time limitations if the flights to which he is assigned are scheduled and normally terminate within the limitations , but due to circumstances beyond the control of the certificate holder (such as adverse weather conditions), are not at the time of departure expected to reach their destination within the scheduled time.

this is the part of the REG that gets me. It is basically saying you can depart on a leg if you know ahead of time conditions will not allow you to complete the leg with the the scheduled time. I take scheduled to mean flight plan time, not block time, since block time is an average time of the flight used by the company for pay, line building, etc and has too many variables to be a day to day "schedule". And the REGS make no reference to block times, just scheduled times. Personnally I have been taking off every flight where I would exceed 8 in a single duty period because of enroute delays and such and the last leg would put me over 8.

If anyone has any specific examples of themselves going over 8 in a single duty day where there has been no modification to your original schedule that would be great. It doesnt seem right, and I know that has little meaning anymore, that if I have two 4 hour flights blocked for the day, and the first leg ends up being 6.2 because of weather, deicing, etc, that I am legal to do the last leg. If it is the other way around, yup know problem, I was legal to start the leg (assuming it was flight planned for 4.0).

Again, any insight anyone has, not just this is how XYZ airline does it, but any FAA interps, NASA form stories, etc, would be great.

 

[chperplt]

Where is that spelled out though. I understand that is how some people interpret the rule but I cannot find a FAA interpret on it. I, and a I'm not alone, think that once you go over or under your scheduled block, that is a "change" to the schedule. And which schedule counts, the crew card block times or the flight plan scheduled time? There is no definition in the regs for "scheduled".

I don't have the legal opinion... Go to www.propilot.com and ask them for it. I can tell you for a fact that you and your friends are wrong. Going over or under your schedule block does not change your schedule. Having leg 2 of your day changed will change your schedule.

this is the part of the REG that gets me. It is basically saying you can depart on a leg if you know ahead of time conditions will not allow you to complete the leg with the the scheduled time. I take scheduled to mean flight plan time, not block time, since block time is an average time of the flight used by the company for pay, line building, etc and has too many variables to be a day to day "schedule". And the REGS make no reference to block times, just scheduled times. Personnally I have been taking off every flight where I would exceed 8 in a single duty period because of enroute delays and such and the last leg would put me over 8.

Once again you're incorrect. Don't take this offensively, but did you stay awake during indoc?? What airline do you work for that you can just take yourself off a flight because you think (incorrectly) that you're not legal?

Scheduled refers to BLOCK time, not actual time when dealing with daily flight time limitations. When you go to the propilot website, do a search for a letter United Airlines sent the FAA in the late 80s asking about non seasonal high winds. The FAA stated in that opinion that seasonal BLOCK time should be used, and that if a specific days flight plan carries the single leg which is normally done under 8 hours to go over 8 hours prior to departure, that flight was legal to depart.

If anyone has any specific examples of themselves going over 8 in a single duty day where there has been no modification to your original schedule that would be great. It doesnt seem right, and I know that has little meaning anymore, that if I have two 4 hour flights blocked for the day, and the first leg ends up being 6.2 because of weather, deicing, etc, that I am legal to do the last leg. If it is the other way around, yup know problem, I was legal to start the leg (assuming it was flight planned for 4.0).

I can't count the times I've gone over 8 hours in a single day when my 6 leg day carried me over. Like it or not, you're example is legal. If you feel it's too much for you, you can always call in fatigued.

Again, any insight anyone has, not just this is how XYZ airline does it, but any FAA interps, NASA form stories, etc, would be great.

This is not about what XYZ airline does. This is what the FAA mandates. Everyone should be doing it the same way as it's the same rule for everyone. I'm not blowing smoke up your tailpipe. I have extensive education on this very topic in the form of a Masters Thesis.

I routinely fly 2 leg days blocked at 7 hours and 20 minutes.. By your thought process, if leg 1 takes an extra 41 minutes, I've got to go to a hotel or ferry it back empty... Doesn't work that way.

If you're employed by a 121 airline, why don't you call your training department as ask for a review.

 

[CFIse]

Anyone have access and can post any legal interps the feds may have on applying 121.505. The way I understand it, legal to start legal to finnish, is a leg by leg basis, not a full day(s) schedule.

What part of 121.505 is unclear. It says "schedules a pilot to fly more than eight hours" then blah, blah, blah about rest. So it's scheduled, not actual.

I doubt there is an interpretation, because it doesn't need interpreting.

 

[wings421]

Look at the ALPA FLIGHT TIME LIMITS. I don't have the link, but its a great resource and I'm sure that someone has the link.