How is FAR 117 transition going

[DCAA320]

(yes, almost 4 years after merger the systems aren't compatible)

My buddy Barack hired your software guys for Obamacare, otherwise your stuff might be compatible, or not.

 

[densoo]

My buddy Barack hired your software guys for Obamacare, otherwise your stuff might be compatible, or not.

That explains it. When I checked in for my last flight I got a text confirming my doctor appointment.

 

[relief tube]

10 hours in the hotel sucks.....when your go home days 1st flight is now delayed 90 mins

 

[GogglesPisano]

Better 10 than 8. I've never been one of these "productivity" guys when it comes to layovers. What good are you to your family if you come home exhausted and out-of-shape. Have a meal, 9hrs of sleep, a good workout, breakfast. That's about 13-14 hrs. The idea of anything less than that gives me the CBGB's.

 

[flexpilot]

The Law of Unintended Consequences strikes again. What a needlessly complicated, counterproductive, and ultimately ineffective regulation.

And a bunch of morons at my fractional are practically BEGGING the Fed to extend 117 to Part 91K and Part 135. They have NO IDEA. Be careful what you wish for...

Yes it would be terrible to have adequate rest rules. We aren't paid hourly so we wouldn't be complaining for the same reasons.

What are the consequences, intended or unintended you foresee with implementation of these rules for Part 135/91K?

 

[Singlecoil]

You have to self-certify when you check in for your day? Ours is an additional signature on the release, just prior to push.

Bubba

Both crewmembers have to send a special acars which acts as a digital signature certifying fit for duty, release acceptance, and fdp extensions.

 

[temcgrew]

Yes it would be terrible to have adequate rest rules. We aren't paid hourly so we wouldn't be complaining for the same reasons.

What are the consequences, intended or unintended you foresee with implementation of these rules for Part 135/91K?

14 hours of duty and 10 rest for 135. How could it get simpler than that? Why change it? Tracking all of this is impossible without the help of an app or program, of which there are none that are credible to use right now. The FAA should provide a way for us to track it if they are to burden us with compliance.

 

[temcgrew]

It may get worse in February when the 117 rules require a look back to the previous month.

It's not a month look back, it's a rolling hourly window for duty and flight (28 days and 7 days....by the hour). The only thing that is a calander day is the 1,000 hours in a rolling year.

Basically what you fly this year until 01/04/2015 will roll with you and basically stay the same if you are flying the same average. This should be the same with the rolling hourly 28 days. There is no more calander month and 30/7 is totally gone.

 

[gutshotdraw]

Yes it would be terrible to have adequate rest rules. We aren't paid hourly so we wouldn't be complaining for the same reasons.

What are the consequences, intended or unintended you foresee with implementation of these rules for Part 135/91K?

While our rest rules are far from perfect, we're very lucky to have a no-fault fatigue policy. Call the ACP, utter the word, and you're done for a minimum of 14 hours.

That said, I'd like to see the following:

Absolute minimum is 10 hours off.

No rest period shorter than the preceding duty period, rounded up to the next hour ie: 11:15 duty, 12 off, 10:50 duty, 11 off, etc.

Cross more than 3 time zones, you get an additional hour per time zone crossed.

Minimum.

Simple. Easy to calculate. Easy to predict.

Remember, "no operator may assign and no pilot may accept" a non-compliant brief. Our scheduling is so jacked, they'll issue non-compliant briefs left and right and it will be on US to decipher the horrendously complicated time chart to prevent a violation.

Whose time zone are we using to calculate? The east coast PIC or the west coast SIC? CMH time? What about when we're international in Geneva? Or Singapore? Or Timbuktu? We're rarely there long enough to become "acclimated." What time do we use then to properly calculate the circadian limit on flight and duty time?

Don't even get me started on the 30 hours off every 7 days. You don't think the company would roll back on us for more duty days every year to make up the productivity loss?

And the disruption to the customer is potentially so dramatic as to drive them even further away from 91K/135 and back to owned Part 91. Because I doubt these rest rules would EVER be applied to straight 91.

Those are just some of the unintended consequences.

I can only hope that the 121 goat rope we're seeing on Part 117 implimentation will kill any effort to extend this abortion to 91K/135.

 

[waveflyer]

Said in the other thread- but you don't sound informed gut. Kind of an all passion, no brains approach

 

[gutshotdraw]

Then you obviously didn't read what I wrote above....

 

[waveflyer]

No, gut shot-
That may make it easier for you since you've sort of taken 117 on as your crusade.
But I read it.
Overly simplistic and clear that you don't understand 117

 

[scoreboardII]

What I am seeing from 117 so far is the ability of a company to keep you on the road for many more days, and pay you many less dollars to do it.

I do like the ten hours off though, that has paid off twice in three days. No more hang the sticky shirt up to put it back on 6 hours later, after having my legal "8hrs" away from the jet, let alone airport. You young whippersnappers who don't like the ten hour rule, sorry.

 

[waveflyer]

I dont know about you scoreboard- but I've been banking this week$$

Probably has more to do with the contract though

 

[Ty Webb]

Better 10 than 8. I've never been one of these "productivity" guys when it comes to layovers. What good are you to your family if you come home exhausted and out-of-shape. Have a meal, 9hrs of sleep, a good workout, breakfast. That's about 13-14 hrs. The idea of anything less than that gives me the CBGB's.

Yup. Agree completely. If I wanted to be worked like a rented mule, I'd go to a regional.

 

[scoreboardII]

I dont know about you scoreboard- but I've been banking this week$$

Probably has more to do with the contract though

Ditto, I made in six days what it would take 12. However, that's unusual ops and only because the company threw in the towel and started assigning everything PP or JA. Fast forward to a few months into the summer, and the schedulers will have plenty of time to let the sodimzer equalize everyone online, and you will find you'll be rerouted to an optimized paring making zero extra bucks because, well, you've been sodomized.

 

[waveflyer]

Ok, 117 doesn't change our contract-
What about 117 makes you think the company can extend us without pay?

 

[scoreboardII]

Wave, what used to require them getting your OK, is now not required and in fact hidden inside the mass of paperwork you get to push. "Here, sign this". Under current 117, if you take longer to fly the same, you get paid the same, but you just ate up FDP for less pay per FDP hr/minute, ate up potential FDP at a later time, and may prevent yourself from being legal at a later date to pick up more trips for more pay.

The perfect storm for pilots will be the normal summer Tstorms, causing diverts, causing reroutes, on a very minor scale and easily handled by the few in scheduling, you will be extended, you will be sodomized, and at the end of the day most likely have flown the same time, taken longer FDP, and made the same money. But, you lost a future opportunity because you have less FDP to use. Example, sit in LAS for three hours waiting out Tstorms in DEN. No reroute, no divert, no more pay, but you used 3FDP hours for free. Unless of course you hit rigs.

 

[igneousy2]

But, you lost a future opportunity because you have less FDP to use.

Or, you could potentially be paid for sleeping in at home because you ran out of FDP. At worst it's a wash. I think it's better than a wash...If the new rules allow me to sit at home 1 extra day with pay and lose 5 days of "OPPORTUNITY" to go and work extra...I would call that a very big win.

That's just me though, which is probably one of the many reasons I could never get hired at SWA.

 

[MECH]

Wave, what used to require them getting your OK, is now not required and in fact hidden inside the mass of paperwork you get to push. "Here, sign this". Under current 117, if you take longer to fly the same, you get paid the same, but you just ate up FDP for less pay per FDP hr/minute, ate up potential FDP at a later time, and may prevent yourself from being legal at a later date to pick up more trips for more pay.

The perfect storm for pilots will be the normal summer Tstorms, causing diverts, causing reroutes, on a very minor scale and easily handled by the few in scheduling, you will be extended, you will be sodomized, and at the end of the day most likely have flown the same time, taken longer FDP, and made the same money. But, you lost a future opportunity because you have less FDP to use. Example, sit in LAS for three hours waiting out Tstorms in DEN. No reroute, no divert, no more pay, but you used 3FDP hours for free. Unless of course you hit rigs.

What you have stated is not true for any group that has CX pay in their contract. FDP extensions only apply to operational delays. So if you extend more then 30 minutes on day one of a trip. You can not be extended more then 30 minutes again until you have a 30 hour break. So if operationally you need to be extend again without the 30 hour break. You are done and going home/hotel. These extensions have nothing to do with the scheduling/ pick up FDP. So you were either legal to pick it up or not.

 

[Jim]

What you have stated is not true for any group that has CX pay in their contract. FDP extensions only apply to operational delays. So if you extend more then 2 hours on day one of a trip. You can not be extended more then 2 hours again until you have a 30 hour break. So if operationally you need to be extend again without the 30 hour break. You are done and going home/hotel. These extensions have nothing to do with the scheduling/ pick up FDP. So you were either legal to pick it up or not.

FIFY. You can be extended 30 mins as often as you will accept.

 

[waveflyer]

How often would that happen score- w/o our rig kicking in?

Rigs kick in for me all the time with the schedules we had

 

[MECH]

FIFY. You can be extended 30 mins as often as you will accept.

Not true. Not until you hit 31 minutes does PIC concurance required. 30 minutes is an automatic extension that the company can use for operational reasons out side of their control.

What I stated is completely true from 31 minute to 2 hour extension.

 

[MECH]

FIFY. You can be extended 30 mins as often as you will accept.

Next time you quote me don't change my words!!! You can never be legally extended more then two hours.

 

[Jim]

Next time you quote me don't change my words!!! You can never be legally extended more then two hours.

Sorry, I miss read what you wrote. I thought you were saying only one 30 min extension between 30 hour rest periods. You are right, there can be as many 30 minute or less extensions as you will accept but only one extension between 31 minutes and 2 hours.

BTW, FIFY tells everyone I am changing your words so they know it is not what you wrote. In this case I didn't Fix It For You.....

 

[NuGuy]

Not true. Not until you hit 31 minutes does PIC concurance required. 30 minutes is an automatic extension that the company can use for operational reasons out side of their control.

What I stated is completely true from 31 minute to 2 hour extension.

I'd like to see your evidence of that.

FAR 117.19 (nor the Federal Register Clarifications) makes no mention of what you are saying. It simply says that extensions UP TO 2 hours require both the PIC and company concurrence.

Once you are beyond 30 minutes, other items come into play...the once per 30 hour rest, reporting to the FAA the nature of the extension and so on.

There is NO mention that a 30 minute extension can happen ONLY with the company's say so.

BTW, extensions may NOT violate cumulative limits.

Nu

 

[MECH]

I'd like to see your evidence of that.

FAR 117.19 (nor the Federal Register Clarifications) makes no mention of what you are saying. It simply says that extensions UP TO 2 hours require both the PIC and company concurrence.

Once you are beyond 30 minutes, other items come into play...the once per 30 hour rest, reporting to the FAA the nature of the extension and so on.

There is NO mention that a 30 minute extension can happen ONLY with the company's say so.

BTW, extensions may NOT violate cumulative limits.

Nu

Look at page 2 of the preamble. It is item number 6 "Extension of Flight Duty Periods".

 

[CaptainSpaz]

Agreed. I'm getting the impression some airlines or unions are telling the pilots something contrary regarding the 30 minutes and PIC concurrence?

I'd like to see your evidence of that.

FAR 117.19 (nor the Federal Register Clarifications) makes no mention of what you are saying. It simply says that extensions UP TO 2 hours require both the PIC and company concurrence.

Once you are beyond 30 minutes, other items come into play...the once per 30 hour rest, reporting to the FAA the nature of the extension and so on.

There is NO mention that a 30 minute extension can happen ONLY with the company's say so.

BTW, extensions may NOT violate cumulative limits.

Nu

 

[NuGuy]

Look at page 2 of the preamble. It is item number 6 "Extension of Flight Duty Periods".

That is simply saying in designing the actual final rule, the FAA thought providing a 30 minute buffer for each FDP was appropriate and reasonable. They are supporting their decision process as opposed to what was published in the NPRM.

However, the actual mechanism of extending the FDP for ANY length of time, up to and including 2 hours, requires both the PIC and the company's approval.

Section 117.19 delineates the exact mechanism of this extension:

? 117.19 Flight duty period extensions.​

​

​

​

​

(a) For augmented and unaugmented operations, if unforeseen operational​

circumstances arise prior to takeoff:​

(1) The pilot in command and the certificate holder may extend the​

maximum flight duty period permitted in Tables B or C of this part up to 2 hours.​

Note that it does NOT say in 117.19.a.1 is that the certificate holder may extend the maximum flight duty period permitted in Tables B or C of this part up to 30 minutes.

Nor does the 117 interpretation published by the FAA in the Federal Register support your viewpoint.

Everything that I have heard is that the PIC needs to approve any extension of any length (and may, later, rescind such extension should events warrant). Certainly if there was verbage to support otherwise, managements would be all over it.

Nu

 

[scoreboardII]

How often would that happen score- w/o our rig kicking in?

Rigs kick in for me all the time with the schedules we had

Rigs get you .73 pay.

I'm not saying it will happen all the time, just that before, you never had a duty day restriction which followed you around and could limit future work a week later, only 30/7.