WXMAN
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Joined: Sat Feb 13, 2010 5:21 pm

FAR 117 ( Is Everyone Ready?)

Tue Dec 25, 2012 5:16 pm

Seek input from the FAR 121 pilots to see if the following interpretation for FAR 117 makes sense.

http://far117understanding.wordpress.com/about/

Is it accurate?
Is it complete?
Is it easy to follow?
Can the presentation be improved?
Is your Airline doing something different?

Be honest, but constructive.
 
WXMAN
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RE: FAR 117 ( Is Everyone Ready?)

Sat Mar 23, 2013 9:44 pm

Opinion concerning FAR 117 and the updates from 05-Mar-13

New Flightcrew Member Duty and Rest Requirements attract the same level of Controversy as the old Flight and Duty Time Regulations
http://jdasolutions.aero/blog/new-fl...-flight-and-duty-time-regulations/

The latest interpretations can be found here:

http://far117understanding.wordpress.com
 
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tb727
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RE: FAR 117 ( Is Everyone Ready?)

Sat Mar 23, 2013 11:56 pm

No because cargo carriers are exempt unless their company voluntarily ops to follow the new 117 rules. I'm pretty sure not one will do so because the company is at a competitive disadvantage as soon as they do so. It's pretty ridiculous.
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WXMAN
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RE: FAR 117 ( Is Everyone Ready?)

Sun Mar 24, 2013 12:16 pm

Quoting tb727 (Reply 2):
No because cargo carriers are exempt unless their company voluntarily ops to follow the new 117 rules. I'm pretty sure not one will do so because the company is at a competitive disadvantage as soon as they do so. It's pretty ridiculous.


I understand tb727, You guys doing cargo are exempt, unless congress steps in ( and they will not ).
But there are other supplemental operators (charters), as well as the scheduled 121 ops that still are impacted.
 
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tb727
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RE: FAR 117 ( Is Everyone Ready?)

Sun Mar 24, 2013 5:47 pm

Quoting WXMAN (Reply 3):
I understand tb727, You guys doing cargo are exempt, unless congress steps in ( and they will not ).
But there are other supplemental operators

Yeah I fly for a 121 Supp carrier and we were really excited when this all came up until they all of the sudden put the loop hole in. Unfortunately I don't have as much money as the special interest groups that created it so my safety doesn't matter, pretty big let down. We by far have a much worse schedule than any of the other 121 carriers out there.

I will say that my company has been trying some different math to come up with rest when we finish our trip based on how long we were on duty and how much we fly. Unfortunately we still have no set duty day on flights outside the contiguous 48 states and only a 2 hour notice on flights regardless of the time of day the charter goes so we are always "on reserve" if you want to look at it that way. We just can't go over 12 hours of flying in a 24 hour period(3 man crew), if we get close we can just stop and drop some time for a couple hours but no guaranteed rest unless we call fatigue in the middle of a trip. I find it hard to believe that congress would consider that safe but money talks.

I still hope that the FedEx or UPS pilots union fight it but I have no idea where they are on it if they have even done anything about it.
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WXMAN
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RE: FAR 117 ( Is Everyone Ready?)

Sun Mar 24, 2013 8:42 pm

tb727, even with a 3 pilot crew, are you not still limited to 18 hrs duty in any 24 121.507(b) even if out of the 48 states?
121.513 only discusses flight time limits not duty limits.
So at 18 hrs duty will you need to be released into a rest period?

I also thought that all certificate holders are supposed to have an approved FRMP in place already.

I may be naive on these points, so maybe you can enlighten me.

No challenge or disrespect intended.
 
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tb727
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RE: FAR 117 ( Is Everyone Ready?)

Sun Mar 24, 2013 11:55 pm

It's common to go over the mark due to things that aren't scheduled like freight delays. Weather, maintenance, 91 reposition legs, airport closures, loading/offloading, fueler, customs and broker problems also throw a wrench in things. The real problem is we can be called out after being up all day and still legally be expected to carry out a full duty day(even if only 16 hours) without having a "defined rest period" given prior to the flight. Not being at work is what is considered being in a rest period but it's impossible to be ready 24 hours a day unless you get cryogenically frozen and woken up for a trip!

We do have an FRMP in place and that has helped out greatly recently but I think it needs some tweaking. It has been a while since I have had a real ball buster trip but it depends on which way the freight is flowing and where we are at in relation to it. Meaning is it flowing from or to Mexico and how far North are the trips going towards Detroit and Canada and vice versa.
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WXMAN
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RE: FAR 117 ( Is Everyone Ready?)

Mon Mar 25, 2013 12:49 am

tb727
Ah, yes, the part 91 re-positions, sorry I overlooked that.
On duty for 15 hours doing part 121 flying, now would 'please' move the aircraft to this airport, it's only a 5 hour flight, then we will give you a rest period, and call you when we will need you.

Did the FAA ever learn anything from the Kalitta crash at Gitmo?

Thanks and good luck.
 
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tb727
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RE: FAR 117 ( Is Everyone Ready?)

Mon Mar 25, 2013 1:26 am

Quoting WXMAN (Reply 7):
Did the FAA ever learn anything from the Kalitta crash at Gitmo?

Yeah, that one did a lot but not enough apparently. At least it's heading in the right direction now I hope!
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FlyMKG
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RE: FAR 117 ( Is Everyone Ready?)

Mon Mar 25, 2013 6:08 am

Quoting WXMAN (Reply 5):
tb727, even with a 3 pilot crew, are you not still limited to 18 hrs duty in any 24 121.507(b) even if out of the 48 states?
121.513 only discusses flight time limits not duty limits.

121.507(b) is not the FAR that gets us supplemental guys. If you read through 121.513-.521 & .525 you find no limitations on duty time. As long as we have two pilots & an FE and do an international trip we never have to receive rest until we reach our flight time limits. Duty is unlimited.

FlyMKG
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WXMAN
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RE: FAR 117 ( Is Everyone Ready?)

Mon Mar 25, 2013 12:31 pm

FlyMKG

As I said to tb727,
121.513 is to only replace the Flight Time Limits, Not the Duty Limits:

121.513 – Flight time limitations: Overseas and international operations: airplanes.

In place of the flight time limitations in §121.503 through 121.511, a certificate holder conducting supplemental operations may elect to comply with the flight time limitations of §121.515 and 121.521 through 121.525 for operations conducted—
(a) Between a place in the 48 contiguous States and the District of Columbia, or Alaska, and any place outside thereof;
(b) Between any two places outside the 48 contiguous States, the District of Columbia, and Alaska; or
(c) Between two places within the State of Alaska or the State of Hawaii.

So a 3 pilot crew under 121.507 has
121.507 – Flight time limitations: Three pilot crews: airplanes.
(a) No certificate holder conducting supplemental operations may schedule a pilot—
(1) For flight deck duty in an airplane that has a crew of three pilots for more than eight hours in any 24 consecutive hours; or
(2) To be aloft in an airplane that has a crew of three pilot for more than 12 hours in any 24 consecutive hours.
(b) No pilot of an airplane that has a crew of three pilots may be on duty for more than 18 hours in any 24 consecutive hours.

But a 3 pilot crew doing international is:
121.521 – Flight time limitations: Crew of two pilots and one additional airman as required.
(a) No certificate holder conducting supplemental operations may schedule an airman to be aloft as a member of the flight crew in an airplane that has a crew of two pilots and at least one additional flight crewmember for more than 12 hours during any 24 consecutive hours.
(b) If an airman has been aloft as a member of a flight crew for 20 or more hours during any 48 consecutive hours or 24 or more hours during any 72 consecutive hours, he must be given at least 18 hours of rest before being assigned to any duty with the certificate holder. In any case, he must be relieved of all duty for at least 24 consecutive hours during any seven consecutive days.
(c) No airman may be aloft as a flight crewmember more than—
(1) 120 hours during any 30 consecutive days; or
(2) 300 hours during any 90 consecutive days.

My understanding is that 121.507(a)(1) & (2) becomes 121.521(a) & (b), but 121.507(b) duty limit 18 in 24 hours was still in effect, Are you saying 121.507(b) is no longer in effect when international?

WXMAN
 
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tb727
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RE: FAR 117 ( Is Everyone Ready?)

Mon Mar 25, 2013 3:47 pm

Quoting FlyMKG (Reply 9):
Duty is unlimited.

Until we have to do our 1 in 7 which has been in ELP a lot lately!

[Edited 2013-03-25 09:12:01]
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WXMAN
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RE: FAR 117 ( Is Everyone Ready?)

Mon Mar 25, 2013 9:34 pm

Gentlemen,

Here is a web link concerning Subpart S duty limits:

http://www.faa.gov/about/office_org/...tions/data/interps/2005/marcus.rtf

http://www.faa.gov/about/office_org/...tions/data/interps/2012/slater.pdf

I will let you make your own decisions.

[Edited 2013-03-25 14:40:06]
 
FlyMKG
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RE: FAR 117 ( Is Everyone Ready?)

Wed Mar 27, 2013 4:57 am

Quoting WXMAN (Reply 10):
As I said to tb727,
121.513 is to only replace the Flight Time Limits, Not the Duty Limits:

Not to derail your thread but for those of us operating under the 121S rules, flight time is not the issue. Flying 12 hours during a duty period isn't hard as long as the turns are quick and there was good rest beforehand. The unlimited duty is the hard part. Waiting on the plane for 6-10 hours for freight because there is nowhere else to go is excruciatingly boring.

Quoting tb727 (Reply 11):
Until we have to do our 1 in 7 which has been in ELP a lot lately!

We have been overnighting in Mexico lately. Not my favorite.

FlyMKG
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