New Rest Rules tomorrow, 12/21/11

[Turtle21]

The snowball rolling down the hill is irregular operations. Say you divert, hit the 8 hour point, however now we can fly to 9. But the scheduled flight is 61 minutes from divert to overnight, now you're done when before you could have kept going till you cried uncle.

Or better, lets say you hit the 8 hr point after you diverted, the flight from divert to overnight airfield is 30 minutes with a 31 minute divert flight because it's still at minimums. I consider I will need to account for all possible flight time, including another divert. And yes, I have diverted twice in one day.

It looks like you can extend past the scheduled FDP for unforeseen operational circumstances (up to two hour extension), with different conditions prior to or after takeoff. Also some pretty strong restrictions and reporting requirements if the extension is longer than 30 minutes.

§ 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.
(2) An extension in the flight duty period under paragraph (a)(1) of this section of more than 30 minutes may occur only once prior to receiving a rest period described in § 117.25(b).
(3) A flight duty period cannot be extended under paragraph (a)(1) of this section if it causes a flightcrew member to exceed the cumulative flight duty period limits specified in 117.23(c).
(4) Each certificate holder must report to the Administrator within 10 days any flight duty period that exceeded the maximum flight duty period permitted in Tables B or C of this part by more than 30 minutes. The report must contain the following:
(i) A description of the extended flight duty period and the circumstances surrounding the need for the extension; and
(ii) If the circumstances giving rise to the extension were within the certificate holder’s control, the corrective action(s) that the certificate holder intends to take to minimize the need for future extensions.
(5) Each certificate holder must implement the corrective action(s) reported in paragraph (a)(4) of this section within 30 days from the date of the extended flight duty period.

(b) For augmented and unaugmented operations, if unforeseen operational
circumstances arise after takeoff:
(1) The pilot in command and the certificate holder may extend maximum flight duty periods specified in Tables B or C of this part to the extent necessary to safely land the aircraft at the next destination airport or alternate airport, as appropriate.
(2) An extension of the flight duty period under paragraph (b)(1) of this section of more than 30 minutes may occur only once prior to receiving a rest period described in § 117.25(b).
(3) An extension taken under paragraph (b) of this section may exceed the cumulative flight duty period limits specified in 117.23(c).
(4) Each certificate holder must report to the Administrator within 10 days any flight duty period that exceeded the maximum flight duty period limits permitted by Tables B or C of this part. The report must contain a description of the circumstances surrounding the affected flight duty period.

 

[Turtle21]

You must have some really crappy pairings, I haven't done less than a 10 hour overnight in months, and maybe only one or two in the last year.


Not sure how you got that out of the reg.

It's 8 hours behind the door. If it's going to be less than that because of delays getting to the hotel or checking in, you can adjust it accordingly, but it's not 8 hours plus time to get ready and get downstairs... nice try though.

Eight hours uninterrupted sleep opportunity. I can't sleep while I am brushing my teeth.

And on occasion I have been unable to sleep because of terribly rude mobs of drunk guests in a hotel. If I call the hotel night manager and tell him that he needs to come up to the 5th floor to inform his drunk guests to kindly be quiet so that his many other guests have the opportunity to sleep without interruption... then the night hotel manager will surely remember my sleep opportunity was interrupted when he is subpenaed to testify at my accident investigation.

If scheduling calls me at the hotel and wakes my ass up (or asks the hotel clerk to knock on my door to reach me) to ask if I can help them out, then I'll tell them to hack their clock and call me back in eight hours after I have had my uninterrupted sleep opportunity.

§ 117.25 Rest period.

(e) The 10 hour rest period must provide the flightcrew member with a minimum of 8 uninterrupted hours of sleep opportunity.
(f) If a flightcrew member determines that a rest period under paragraph (e) of this section will not provide eight uninterrupted hours of sleep opportunity, the flightcrew member must notify the certificate holder.

And the clarifying info from page 227:

Based on the comments received from the certificate holders, the FAA agrees that using the time when a flightcrew member reaches the hotel or other suitable accommodation would present more issues for implementation than it actually solved. The FAA’s main objective with this provision was to ensure that flightcrew members have an 8 hour sleep opportunity. Building from that and mindful of the comments received, the FAA has decided to adopt a 10 consecutive hour rest requirement that immediately precedes the beginning of a reserve or FDP measured from the time the flightcrew member is released from duty. At this point, if the flightcrew member cannot have 8 uninterrupted hours of rest opportunity, the flightcrew member cannot report for the assigned FDP until he/she receives that rest. If the reason for the shortened rest opportunity is travel delays, reservation confusion, or the flightcrew member’s actions, the certificate holder is free to address the root cause. However, it must provide the required 8-hour rest opportunity.

 

[Turtle21]

They did better. 10 hours free from duty. At my airline duty ends 15 minutes after block in and starts 30 prior to block out. 10:45 block to block is better than a lot of pairings currently provide.

Then there's 8 hours of uninterrupted rest. I'm not resting when I'm showering and getting ready for the day. I would interpret this as 8 hours from door closed to alarm goes off. For me, 8:45 behind the door.

The ten hours free of duty will eliminate the 9:15 crap that some of our pairings have, a good deal.

However the real gem is the 8 hours uninterrupted sleep opportunity. The airlines would be fools to plan less than 9 hours at the hotel since it would be unreasonable to deny crews 30 minutes to brush their teeth and get into their pajamas for the night and 30 minutes in the morning to reverse the process.

But the real beauty will be when the occasional drunk party animal crowd wakes me up. I will have to call the night manager to have him come upstairs and do some of that management vodoo on the drunks,... then I will be obligated to immediately call my scheduler and tell them (on a recorded phone line) that I just finished having a conversation with the hotel night manager about my interrupted sleep. Hack the clock for eight hours.

 

[Lear70]

But the real beauty will be when the occasional drunk party animal crowd wakes me up. I will have to call the night manager to have him come upstairs and do some of that management vodoo on the drunks,... then I will be obligated to immediately call my scheduler and tell them (on a recorded phone line) that I just finished having a conversation with the hotel night manager about my interrupted sleep. Hack the clock for eight hours.

That's completely reasonable.

However the real gem is the 8 hours uninterrupted sleep opportunity. The airlines would be fools to plan less than 9 hours at the hotel since it would be unreasonable to deny crews 30 minutes to brush their teeth and get into their pajamas for the night and 30 minutes in the morning to reverse the process.

Yeah, good luck with telling your chief pilots you needed extra time to brush your teeth and wrap up in your snuggy.

By the way, the airlines aren't GOING to plan less than 9 hours at the hotel. They have to PLAN for at least 10 hours off-duty (which includes the post-flight the night before and pre-flight report the next day). Not too many places that are going to take longer than half an hour each-way to/from the hotel.

 

[scoreboardII]

It looks like you can extend past the scheduled FDP for unforeseen operational circumstances (up to two hour extension), with different conditions prior to or after takeoff. Also some pretty strong restrictions and reporting requirements if the extension is longer than 30 minutes.

So, the penalty for exceeding the limit is more time doing paperwork after work that we don't get paid for? Riiiigght.

 

[PCL_128]

So, the penalty for exceeding the limit is more time doing paperwork after work that we don't get paid for? Riiiigght.

If the limits are exceeded, we don't have to do all of the paperwork, the company does. They are the ones saddled with all of the reporting requirements.

 

[Turtle21]

Yeah, good luck with telling your chief pilots you needed extra time to brush your teeth and wrap up in your snuggy.

By the way, the airlines aren't GOING to plan less than 9 hours at the hotel. They have to PLAN for at least 10 hours off-duty (which includes the post-flight the night before and pre-flight report the next day). Not too many places that are going to take longer than half an hour each-way to/from the hotel.

I agree the schedules will normally result in at least 9 hours at the hotel.

If circumstances result in a late arrival at the hotel I doubt the chief pilot will require us to check-out 8 hours after check-in, otherwise the accident investigator will find that the chief pilot denied the crew an opportunity for 8 hours sleep.

I really don't think occasional delays will be a big deal. In the last six months I have had to delay a takeoff just a few times for crew rest and each time was only 20 or 30 minutes. The chief pilot never called to discuss it.

Personally I think the "8 hours uninterrupted" is an excellent addition. It isn't some huge windfall of beauty rest. It is simply a reasonable and appropriate amount of sleep.

 

[rudder]

In Canada, the CAR's use the "8 hours prone rest" provision and specifically exclude pre-flight duties, post-flight duties, hotel travel times, and meal times. And while many collective agreements allow for increased minimum rest times on overnights, you will never see scheduling less than 10 hours and more common is an 11 hour minimum. If the company is dumb enough to plan just 10, then be prepared for lots of delayed departures in the a.m.

For years we have watched you guys get 5 hours sleep at the hotel and could not believe that was legal. Guess that will continue for another 2 years

 

[scoreboardII]

If the limits are exceeded, we don't have to do all of the paperwork, the company does. They are the ones saddled with all of the reporting requirements.

Until new section XYZ of the FOM states "and pilots will fill out IR XYZ if they bust the FAA times".

 

[Maria]

The petition is at https://wwws.whitehouse.gov/petitio...shed-flightcrew-member-duty-and-rest/1LB3x9Nd

Thanks!