FAA Rest Rules: Impact on Various Types of RESERVE (doc p 63+)

[Voice Of Reason]

p 7 & 8:

"The ARC’s goal was to reach as much agreement as possible on the prospective
regulation. However, the members recognized early on that they would not be able to
reach consensus on all issues. They were, however, generally successful in agreeing
upon broad regulatory approaches and were able to reach consensus on two issues – how
to address reserve and the role of commuting in any proposed regulations."

http://www.faa.gov/regulations_policies/rulemaking/recently_published/media/FAA_2010_22626.pdf

p63+:

I. Reserve duty
While the term “Reserve” has been used for years in the air carrier industry, the
term is not addressed at all in part 121. The agency has issued 11 legal interpretations on
the subject of reserve, which range from examples of whether a crewmember is on duty
and, if applicable, whether the required rest associated with that duty period is impeded
by being in a reserve status.
The ARC discussed various definitions of reserve and initially proposed that
reserve means that a pilot that does not have a regular flying schedule and is available for
flight when contacted by the company. That pilot has no telephone or reporting
responsibility to the company. The ARC refined the definition of “reserve” to read “a
flightcrew member that is required by a certificate holder to be available to receive an
assignment for duty.” In addition, the ARC established the following types of reserve
duty: long-call, short-call, and airport/standby. The ARC noted that the policies that
apply to reserve flightcrew members vary significantly between certificate holders, but
also found that there are some relatively consistent conditions.
CAP-371 places restrictions on “Standby Duty”, which is generally the equivalent
of short-call reserve discussed below. When standby duty is undertaken at home, or in a
suitable accommodation provided by the operator, during the period 2200 to 0800 hours
local time and a crew member is given 2 hours or less notice of a report time, the
allowable FDP starts at the report time for the designated reporting place. EASA
recognizes “standby duty”, but does not place any regulatory restrictions on this type of
duty.
Reserve duty is inherently based on unpredictable events, such as covering trips
for flightcrew members who become ill, have difficulty traveling to the airport for an
assignment because of weather or other reasons, or are stranded due to severe weather
creating flightcrew member shortages throughout a certificate holder’s system. The very
nature of reserve duty makes injecting predictability into a reserve flightcrew member’s
schedule a challenge.
The ARC set a goal to make reserve duty as predictable as possible, and to
manage fatigue as much as possible. The proposal on how to address reserve limits was
one of two areas of consensus by the ARC. The ARC concept includes defining limits
associated with flight duty period, duty period and rest limitations.
One of the most fatiguing elements of reserve duty is the lack of predictability..."
-----------------------------

...Goes on for several pages more to breakdown suggestions on different types of RESERVE duty

Anyone look at section yet and have any thoughts on what this might mean to Reserve Pilots? Better? Worse?

 

[bluefin]

If I understand it correctly this suggests that if you are on short call in the middle of the night the company needs to put you up in a hotel, "accomodations supplied by the operator" any one else read it this way?

 

[Daytonaflyer]

I think they can put you up pretty much anywhere based on that. A crew room, a hotel, a trailer, wherever.

 

[JudgeSmails218]

I think they can put you up pretty much anywhere based on that. A crew room, a hotel, a trailer, wherever.

The trailer MUST be a double wide with a fridge full of Natty Light on the porch, a toilet bowl flower planter in the yard, and a dog tied to a cinder block for "protective adequate rest".

 

[Lear70]

If I understand it correctly this suggests that if you are on short call in the middle of the night the company needs to put you up in a hotel, "accomodations supplied by the operator" any one else read it this way?

No.

It starts out saying, "A crewmember sitting reserve AT HOME or in suitable accommodation provided by the certificate holder"...

There's nothing in there even VAGUELY insinuating they have to get you a hotel, just that if you're sitting reserve between those late hours, your duty period started at the beginning of your telephone availability period.

For most operators, this isn't really important. Yes, we know that "reserve isn't duty and it isn't rest", but for all intents and purposes, with the Whitlow interpretation, being on reserve and having to see 8 hours of look-back rest within the preceding 24 hours, you were limited to a maximum of 16 hours from when you first went on call, anyway.

If these rules are applied to charter operators, things could get really interesting...

 

[Raoul Duke]

crew room definately meets that definition

 

[Voice Of Reason]

crew room definately meets that definition

I wouldn't put it past a lot of outfits...
Isn't that where at least one of the Colgan crew slept the prev nt?

 

[skywdriver]

The interesting part of this is the hour limitation. Hopefully, this will give more days off to reserves assuming they operate under a contract as bad as CAL's