Part 117 Interpretations

No. Interpretation Description
58 Kravit 3/7/2019 The FAA on March 7, 2019 responded to a request for an interpretation of § 117.5(c) in a scenario where the only qualified Pilot in Command becomes fatigued and feels unable to continue to the destination on a flight augmented by three type-rated first officers. The FAA responded that under the circumstances presented the certificate holder must be notified and the PIC must declare an emergency and land at the nearest suitable location. The FAA noted an option that would allow the flight to continue was for the air carrier to have assigned and designated more than one PIC prior to takeoff.
57 Carbone 11/15/2018 The FAA clarified its interpretation that a flightcrew member’s FDP could begin prior to the scheduled report time if he/she performed ground duties such as cleaning the aircraft when commuting to work. (de Lancie). The FAA does not consider “de minimus” cleaning or other light activities that are required during commuting to constitute duty. However, “there may be circumstances where the activities required of the commuting employee may rise to a level where they significantly contribute to fatigue that could affect a flightcrew member’s safe performance and thus constitute duty. (For example, baggage handling, strenuous cleaning or activities more extensive than can be completed in a short period of time).” (Carbone)
56 Schnaubelt III 10/24/2018 In Schnaubelt III (10/24/18), the FAA held that an augmented pilot may consider his or her reasonable expectation of receiving in-flight rest when affirming fit-for-duty under FAR 117.5(d). The FAA in explained in Schnaubelt III that a reasonable expectation of receiving effective in-flight rest is unique to the individual pilot and can be based on prior experience on a route. In Schnaubelt II (4/28/17) the FAA clarified that fit-for-duty is an individual determination “based on multitude of factors,” including time awake, time of day and a pilot’s self-knowledge of reaction to fatigue. Schnaubelt III reverses the FAA’s original holding in Schnaubelt I (4/4/16) that a pilot cannot rely upon anticipated in-flight rest when reporting fit-for-duty because the pilot does not know whether in-flight rest will occur or be effective.
55 Dewey 07/10/2018 New FAA interpretation addresses reassignment to an augmented crew after unaugmented FDP report - The FAA on July 10, 2018 clarified when Part 117’s less restrictive augmented flight and duty limits may apply to a pilot who reports for an unaugmented flight duty period, but is reassigned to an augmented crew. In this case, the pilot’s schedule was changed after the start of his assigned unaugmented FDP, but before any flying took place, to two 5-hour augmented flight segments for a total of 10 hours scheduled flight time. Under Part 117, Table A, unaugmented pilots are limited to no more than 9 hours flight time. The FAA had previously taken the position that in a mixed duty operation the more restrictive unaugmented flight and duty limits of Tables A&B apply. In this case the FAA found that the pilot’s duty was “not a true mixed operation since the only flights conducted during the pilot’s FDP were augmented.” Consequently the maximum flight time limits for unaugmented operations in Table A do not apply and the maximum FDP for augmented operations under Table C applies, so the reassignment complied with Part 117.
54 De Lancie 7/3/2018 The FAA on July 3, 2018 clarified the Part 117 definition of “duty” and “flight duty period” in the context of an air carrier requiring flightcrew members to perform aircraft cleaning duties at the conclusion of two flight segments while commuting to a flight assignment. The question presented was whether the FDP began at the time of the first cleaning duty or when the flightcrew member reported for the assigned FDP. The FAA has consistently stated that duty means all actual work for an air carrier, including pre-flight and postflight activities. The report time is not necessarily the assigned start time of the FDP if prior to the report time the flightcrew member was engaged in ground duties for the air carrier. All activities performed for the air carrier must be included in the flight duty period to mitigate any fatigue that might affect the flight assignment.
53 Ennis 05/04/2018 The FAA clarified the application of §117.25(d), 56 consecutive hours rest requirement, in mixed cargo and passenger operations. A flightcrew member is assigned passenger-carrying flights and is away from home base more than 168 hours. Following these flights, the flightcrew member does not return to home base but travels more than 60 degrees longitude into a cargo-only part 121 assignment and returns to home base after the cargo-only assignment is completed. The §117.25(d) rest is not triggered until the flightcrew member returns to home base. Therefore, the 56 consecutive hour rest is not required prior to the all-cargo assignment nor is it required after completion of the all-cargo assignment. Since that assignment was conducted under Part 121 flight time and rest requirements, Part 117 would not apply and the crewmember would have to receive the Part 121 required rest.
52 Eperson 2/21/2018 The FAA was asked about a seven-day period during which a pilot conducted a flight on day one and then attended training for six days. Classroom training was conducted on days two through four and simulator work was conducted on days five through seven. The pilot asked whether §117.25(b) was violated by working seven consecutive days without a 30-hour rest period. The FAA answered by explaining that because §117.25(b) only requires a consecutive 30-hour rest period in the 168-hour period preceding a reserve or FDP assignment, in this case no violation occurred.
51 KaiserAir, Inc. 02/01/2018 The FAA addressed two scenarios concerning the 2-hours in-flight rest requirement on augmented flights (§117.17(c)(1)). The first scenario was a 13.5-hour FDP that had 1.5 hours of flight time in the first half of the FDP and 1-hour of flight time in the second half. Since there was only 1-hour of flight time in the second half of the FDP, the 2-hours in-flight rest was not possible. The FAA said §117.17(c)(1) “unambiguously prohibits the assignment or acceptance of an augmented operation unless two consecutive hours in the second half of the FDP are available for the landing pilot’s in-flight rest.” Therefore, §117.17(c)(1) was not applicable as the crew does not fall under the definition of an augmented flightcrew and the Table C limits could not be applied. The second scenario addressed a 3-segment augmented flight with two landings in the second half of the FDP. The landing pilot received 2-hours in-flight rest during the second half of the FDP and was the landing pilot for both the 2nd and 3rd segments. The FAA affirmed that the in-flight rest requirement is intended to apply only to the pilot landing the final flight segment, so this scenario did comply with §117.17(c)(1).
50 Wykoff 12/04/2017 The FAA clarified that multiple extensions of more than 30 minutes up to two hours may be requested without triggering the 30-hour rest requirement under FAR 117.19(a)(2) if the first requested extension over 30 minutes had not been actually used. For example, a PIC agreed to an FDP extension of 45 minutes. However, before takeoff, it was determined an additional 45-minute extension was required to complete the flight. This second extension request did not trigger the 30-hour rule rest because the first 45-minute extension had not been “used,” “use[d] up,” or “taken.” If an extension of more than 30 minutes actually occurs, the rest period requirement of FAR 117.19(a)(2) comes into effect.
49 Batman 11/14/2017 The FAA clarified that a flightcrew member is considered to be on duty and operating within the FDP when repositioning the same or another aircraft after completing all scheduled revenue flights. If a flightcrew member has not yet started a rest period and is asked to reposition a different (or the same) aircraft, the certificate holder may do so by holding the pilot on duty with the FDP clock running. The FAA also clarified that a flightcrew member may not use FDP extension time to reposition an aircraft. A post-takeoff extension terminates once the aircraft is safely landed. Since prior-to-takeoff extensions are more strict than post-takeoff extensions, repositioning of the same or different aircraft after the flight has landed using a prior-to-takeoff FDP extension is not permissible.
48 Putek 6/4/2017 Required Distance Learning Completed During Rest Period – FAR 117.25 – The FAA’s 2015 McEldowney interpretation clarified that a certificate holder may provide for an extended period of time to complete distance learning and a flightcrew member may complete the training outside of a rest period, or voluntarily during a rest period. Putek clarifies that the question of whether a flightcrew member has a real opportunity to complete distance learning outside of rest periods in any given timeframe will be assessed on a case-by-case basis. If the flightcrew member is scheduled such that he or she cannot complete the distance learning training outside of a rest period, then the completion of the training during a rest period would not be voluntary and would act to interrupt the rest period.
47 Schnaubelt II 4/28/2017 Fitness for Duty – FAR 117.5 – The FAA responded to a request to clarify its Schnaubelt I interpretation (4/4/16) by explaining that fitness for duty requires a crewmember’s “individual determination” based upon a “multitude” of factors including time awake, time of day and self-knowledge of how he or she reacts to fatigue. It found that the requirement for pilots to self-assess fitness for duty is mitigated by fatigue education and awareness training. The FAA concluded that FAR 117.5 does not, and was not intended to, establish a single objective limit as to the maximum number of hours a pilot could be awake and remain fit for flight duty.
46 Snieder (1/5/2017) On January 5, 2017, the FAA issued a legal interpretation clarifying the two-hour consecutive rest requirement in the second half of an FDP that has multiple flight segments for Augmented Crews applies only to the flight crewmember who is at the controls during the final landing. (See Snieder 01/05/17.) FAR 117.17(c)(1) requires for augmented flights that two consecutive hours in the second half of the FDP are available for inflight rest for the flight crewmember flying the aircraft during landing. The FAA has advised that augmented flights with more than one scheduled landing within a single FDP only require the two-hour rest for the “pilot at the controls” during the final scheduled landing. FAR 117.17(c)(2) requires that the flight crewmember performing secondary monitoring duties on the flight deck during the final landing have 90 minutes of in-flight rest.
45 Johnson Clarification (11/10/2016) On August 5, 2016, the FAA issued a legal interpretation clarifying the definition of "flight time" in 14 C.F.R. § 1.1 under four fact-specific scenarios including diversions to an alternate airport. (See Johnson 08/05/16.) The FAA stayed the effectiveness of that interpretation for the purpose of collecting additional information. (See Berg-Johnson 09/06/16—Termination of Flight Time—FAR 1.1.) The FAA has now issued a policy clarifying that interpretation. In its November 10, 2016 clarification, the FAA found that when an aircraft diverts to an alternate airport, the flight must end so that pre-flight planning and preparation for the subsequent flight segment to the final destination can begin. (See Johnson 11/10/16-Clarification.) Therefore, the FAA concluded, as a matter of policy, that flight time accrual ends when the aircraft shuts down at its parking location at the diversion airport, and recommences when the aircraft moves under its own power again for the purpose of flight to the final destination. This policy supersedes the stay of the August 5, 2016 flight time legal interpretation. The guidance as to when flight time ends for aircraft landing at the destination airport remains in effect.
44 Berg-Johnson 9/6/2016 The Federal Aviation Administration (FAA) has temporarily stayed—until October 6, 2016—its August 5, 2016, legal interpretation clarifying the definition of "flight time" in 14 C.F.R. § 1.1 under four fact-specific scenarios (Berg-Johnson 09/06/16—Termination of Flight Time—FAR 1.1). On September 1, 2016, Airlines for America (A4A) requested that the FAA withdraw the August 5, 2016, interpretation. The FAA indicated that it decided to issue the stay to allow the agency time to consider information provided by industry and ALPA concerning the four scenarios. ALPA President Tim Canoll expressed ALPA's disappointment with the FAA's decision; however, ALPA recognizes that many airlines have been handling termination of flight time differently, which complicates the industry's recognition of a common standard under the FARs. ALPA will continue to work with the FAA to timely end the stay and to guard against any adverse effects on safety. The FAA's stay is not a withdrawal or cancellation of the August 5, 2016, interpretation. Also, prior legal interpretations involving related or similar flight-time issues are not impacted by the stay and remain in effect.
43 Johnson (8/5/2016) Flight Time; Definition of "Flight Time" - FAR 1.1 - Clarification as to whether flight time continues to accrue in the following circumstances: (1) Flight diverts to an alternate because of weather intending to continue to original destination. The aircraft is parked at a remote ramp, no doors are opened, APU is operating with engines shut down. Flightcrew supervision was required; (2) Same scenario as (1) above but air stairs are briefly brought to the aircraft and some passengers deplaned; (3) Flight lands at intended destination, aircraft is parked, engines shut down, APU operating, no doors are opened, waiting for a gate; and (4) Aircraft lands but remains stationary for several minutes after exiting the runway with the parking brake set. In each of the scenarios, the aircraft has not come to rest after landing and flight time would continue to accrue in each scenario until the aircraft comes to rest.
42 Amaya 8/5/2016 The effect of an FDP extension on FAR 117.25(b) 30 consecutive rest in 168 hours and PIC responsibility when a flight attendant crewmember has exceeded the duty limits of FAR 121.467. The 30-hour consecutive rest requirement in 168 hours must be satisfied at the moment an FDP begins and it cannot be subsequently violated by extending the FDP longer than initially anticipated. If a PIC has knowledge that a flight attendant, in Part 121 operations, exceeded the duty limits in FAR 121.467, the PIC cannot be charged with a violation of 121.467. However, a PIC is responsible for the overall safety of his flight, including passengers, crewmembers, cargo and the aircraft, and for making sure the flight is in compliance with all applicable regulations. Thus, the PIC cannot initiate an aircraft operation if the PIC knows that certain safety regulations, including flight attendant duty and rest rules, would be violated.
41 Anderson 8/5/2016 (1) Is a flightcrew member required to report rested only for the known assigned FDP or must he/she be rested for the maximum FDP that could have been assigned? The flightcrew member's responsibility is to report rested for the known FDP that was assigned and not what could have been assigned. If a longer PDP should occur, the flightcrew member must reassess his/her fitness for duty. (2) Could company policy require a flightcrew member to be sufficiently rested for the entire length of the FDP that could have been, but was not, assigned originally? Yes, but policies may not authorize conduct that would be a violation of FAA regulations.
40 Schnaubelt I 4/4/2016 Fitness for Duty – FAR 117.5 – A slight amount of fatigue that appears at the end of an FDP will not always render a flightcrew member unfit for duty. Time awake is one factor to consider in determining fitness for duty; Part 117 does not categorically prohibit a person from being awake 16 hours. Fitness for duty must be reassessed prior to each flight segment. Until a carrier decides that an FDP extension is necessary a flightcrew member's fitness for duty determination is based on the assumption that the FDP will not be extended. If an airborne flightcrew member determines he is too fatigued to safely continue and land at the intended destination, and there are no non-fatigued flightcrew members on board to take over, then he should land at the nearest suitable location to avoid accumulating additional fatigue.
39 Slater 11/17/2015 Passenger-carrying revenue flights conducted under Part 121 supplemental rules must meet applicable Part 117 flight and duty limitations. A Part 91 ferry flight at the end of the passenger revenue flights could not be conducted if it would exceed the flight time limitations. Flight time limits can only be exceeded for unforeseen operational circumstances that arise after takeoff. In this scenario, the flight crew could not conduct the Part 91 ferry flight until they received 10 hours rest as required by 117.25(e).
38 Duncan 9/10/2015 Rest Period; Deadhead Compensatory Rest– FAR 117.25 (b) and (g) - Deadhead transportation solely by aircraft begins when the deadheading pilot boards the aircraft and it begins moving and ends when that pilot exits the aircraft. If a deadhead assignment exceeds Table B limits FAR 117.25(g) requires that a rest period be given that is equal to the length of the deadhead but not less than 10 hours. To determine Table B limits for purposes of 117.25(g) a pilot must use scheduled time of start and the number of deadhead segments flown. If a pilot is required to remain on board while an aircraft is towed that pilot's rest period does not begin until he or she exits the aircraft and completes post-flight duties. The 30-hour rest period specified by FAR 117.25(b) is not required before a training or deadheading assignment.
37 Nelson 9/3/2015 In-Flight Rest Break; Augmented Flight – FAR 117.17(c) – The in-flight rest breaks for augmented flightcrew members specified by FAR 117.17(c) must actually be taken. The carrier must make available and the individual flightcrew member flying the aircraft during landing must take an actual in-flight rest break consisting of at least two consecutive hours during the second half of the FDP to comply with FAR 117.17(c); so long as at least two consecutive hours is taken it is not necessary to take the full amount of a scheduled break to meet the rule. Additionally, the carrier must make available and the individual flightcrew member monitoring the landing must take an actual ninety-minute in-flight rest break during the course of the flight.
36 Schnaubelt 8/12/2015 Fitness for Duty; Rest Period; Augmented Flight - FAR 117.5; 117.25(e) – (1) A flightcrew member remains responsible for advising a certificate holder that he or she cannot perform his or her assigned duties without regard to whether the disruption to fitness for duty was caused by external or physiological factors; (2) At the time a pilot on an augmented flight reports that he or she is fit for duty the affirmation cannot be conditioned upon obtaining rest or sleep during a flight segment. (3) So long as a flightcrew member obtains at least 10 consecutive hours of rest with a minimum of 8 uninterrupted hours of sleep opportunity immediately before beginning an FDP, the burden of determining fitness for duty rests on the individual flightcrew member.
35 White 8/6/2015 Fitness for Duty; Augmented Flight; FRMS – FAR 117.5; 117.7 – A fitness for duty affirmation is required before commencing each flight segment. The FRMS approval process authorizes a carrier to collect data to demonstrate an alternative method of compliance is equal or superior to other provisions of Part 117.
34 Bonner 4/14/2015 Drug Testing After Completion of FDP – FAR 117.3 - Time spent to undergo random drug and alcohol testing after completion of an FDP is not part of the FDP nor is it a part of a rest period since the flightcrew member is not free from all restraint by the certificate holder.
33 McEldowney 3/13/2015 Rest; Completion of Distance Learning during Required Rest Period – FAR 117.25 – Distance learning may be voluntarily completed during a required rest period if the pilot had an opportunity to complete the learning outside of the required rest period, but chose not to do so. The FAA emphasized FAR 117.5 requires a pilot to notify the carrier if activity voluntarily conducted during a required rest period renders that pilot too fatigued to safely operate an aircraft.
32 Johnstone 2/3/2015 Other Commercial Flying – FAR 117.23 – Ground instruction for compensation incident to flight instruction not performed for a certificate holder or 91K Program Manager is not included in Part 117, or Part 121, cumulative limits.
31 Wykoff 2/3/2015 Unforeseen Operational Circumstances; FDP extensions – FAR 117.3; FAR 117.19 - There are two distinct components that must be taken into consideration in reading the definition of "unforeseen operational circumstance:" (1) an unplanned event that has actually occurred; (2) of insufficient duration to allow for adjustments to schedules. The question of whether an unplanned event has occurred and whether it is long enough to allow for an adjustment to schedules is a fact-specific determination.
30 Fowler 1/29/2015 FDP; Rest; Reassignment of Deadhead as FDP– FAR 117.25(g) – If 117.25(e) required rest has been given prior to a deadhead only assignment, a carrier does not need to place the flightcrew member into another rest period prior to using that flight crewmember for a flight assignment; the FDP will start at the time the flightcrew member reported for the deadhead, not at the time the flightcrew member is notified of the change or when a flight segment actually starts.
29 Wykoff 1/20/2015 FDP Extensions; Cumulative FDP Limitations; Fitness for Duty; Requirement to Check Schedule after Deadhead – FAR 117.5; 117.19; FAR 117.23 – 1. A carrier may not preapprove an FDP extension; the concurrence between a PIC and a carrier required to extend an FDP must take place when the need for an extension is known. 2. Time spent waiting for a second segment that is eventually canceled counts towards a pilot's cumulative FDP limits. 3. Time spent by a reserve pilot between block in and performing a required schedule check prior to release counts towards the cumulative FDP limits. 4. Where no further flying is assigned after a deadhead, the time spent in deadhead transportation does not count towards the cumulative FDP limits. 5. Time spent complying with carrier's policy to standby after a canceled flight for a possible further flying assignment counts towards the cumulative FDP limits.
28 Yu-Southwest 12/12/2014 Record of PIC Concurrence for FDP Extensions Required – FAR 117.19; 117.5 – The PIC must give an affirmative concurrence for an FDP extension at the time the PIC is made aware of the need for an extension. There must be a record of the concurrence but the carrier and PIC have flexibility in the type of record. It could be the fitness for duty certification if the extension is 30 minutes or less but over 30 minutes it must be separate from the fit for duty certification. It could also be part of the dispatch release or if the aircraft has pushed back awaiting take off it could be an ACARs message.
27 McEldowney 11/13/2014 Rest Periods; Disrupted Sleep Opportunity – FAR 117.25(e) and (f) – A pilot is required by 117.25(f) to notify the carrier if he determines that he will be unable to obtain an 8-hour uninterrupted sleep opportunity. That notification requires that the pilot be provided with a new uninterrupted 8-hour sleep opportunity. Because the notification requirement is imposed by Part 117 and not the carrier, it is not duty and does not otherwise interrupt rest.
26 Adams-Events Air Cargo 11/6/2014 Applicability of Part 117; Common Carriage – FAR 117.1 – Part 117 prescribes flight and duty limitations for all flightcrew members and certificate holders conducting passenger operations under Part 121. A carrier's public offering of parabolic "weightless" passenger experiences in an aircraft with more than 30 passenger seats is engaged in common carriage and Part 121 air transportation subject to Part 117 flight and duty limitations.
25 Edwards 11/5/2014 Reserve Consecutive night duty periods; Scheduling; WOCL – FAR 117.27 – No certificate holder may schedule more than three consecutive flight duty periods that infringe upon the window of circadian low (WOCL). A realistically scheduled non-WOCL infringing FDP will interrupt a chain of consecutive nights under FAR 117.27, even if the schedule actually operates into the WOCL.
24 Wykoff-ALPA 11/5/2014 Cumulative Limitations; Flight Time; Other Flying for Compensation or Hire – FAR 117.23 – Flying for compensation or hire that is not performed for a certificated air carrier, part 119 operator, or 91k Program Manager is not required to be included in the cumulative flight time limitation calculations required by FAR 117.23
23 Breckeen-ExpressJet Airlines 8/26/2014 Reserve Pilots; Short-call; Long-call; FDP Extensions; Rest Required – FAR 117.3; 117.19(a); 117.21(c)(3) and (4); 117.29 – 1. A short-call reserve pilot's maximum flight duty period plus reserve availability limit (FDP + RAP) under FAR 117.21(c)(3) and (4) may be extended up to two hours under the provisions of FAR 117.19(a)(1) and 117.29. 2. No rest is required prior to being assigned long-call reserve phone availability, however, once an FDP is assigned a pilot must receive the rest required 117.25 before beginning the FDP.
22 Anderson, Douglas 8/18/2014 FDP Extensions; Reserve Pilots; Short-call – FAR 117.19(a); 117.21(c)(3) - A short-call reserve pilot's maximum flight duty period plus reserve availability limit (FDP + RAP) under FAR 117.21(c)(3) may be extended up to two hours under the provisions of FAR 117.19(a).
21 Anderson-Teamsters 357 8/12/2014 Part 117 Limitations; Applicability; Check Pilots – FAR 117 - The FAA's "long standing" interpretation addressing when flight time limitations apply to check pilots will continue under Part 117. If a check pilot sitting in a jump seat has requisite "control, authority and responsibility regarding the safe operation of the flight," then the check pilot's flight and duty time will count under Part 117.
20 Hryniw 8/8/2014 RAP and FDP; Discussed and Explained – FAR 117.3 - The differences between a reserve availability period (RAP) and a flight duty period (FDP) are discussed and explained.
19 Johnson 8/8/2014 Flight Time; Waiting for Gate – FAR 1.1 - Time spent waiting on the ramp for a gate counts as "flight time" for purposes of Part 117 so long as the aircraft subsequently moves under its own power to the gate.
18 Anderson-Teamsters 357 7/11/2014 FDP Extensions; Anderson Rule - PIC Explanation of Non-Concurrence with FDP Extension Not Required by FARs, however, Carrier May Require as a "Management-Labor" issue – FAR 117.19 – Part 117 "neither encourages nor prohibits" an airline from "requiring a PIC to state the reason for refusing to concur with an FDP extension." Although a PIC would not "violate part 117" by refusing to concur in an FDP extension "for reasons other than fatigue," the FAA concluded "management-labor issues" "are beyond the scope of part 117" and FAR 117 "does not prohibit" an air carrier investigation, or disciplinary action, to address employee behavior.
17 Garciglia 7/8/2014 FDP Extensions; 5-Minute ATC Delay; Delays of Relatively Short Duration Not Sufficient Justification; PIC Refusal of FDP Extension as Compliance with Part 117 – FAR 117.19 - Unplanned events of relatively short duration, such as a 5-minute air traffic delay, are not unforeseen circumstances that will justify an FDP extension under 117.19. Both the PIC and the carrier must concur with an FDP extension and "the PIC would be in compliance with part 117 if he or she does not concur with an FDP extension and does not fly the flight segment for which the FDP extension is necessary."
16 Phelan-PPA Global Energy 7/8/2014 Required Duty; Prohibition on Performing During Part 117 Rest; Checking Calendar During Rest – FAR 117.25(a) - Requiring a pilot to review an online company calendar for flying assignments constitutes "duty" for purposes of Part 117. (Follows McFadden).
15 Rives-AmeristarAirCargo 6/16/2014 Reserve Pilots; Drug & Alcohol Testing - FAR 117.21 – Part 117 does not change the employer's duty to follow the notification requirements of Part 120 concerning drug and alcohol testing. Random tests must be unannounced and an employee notified of selection should proceed to the testing facility immediately. In usual practice, the FAA expects that a long-call reserve pilot will be notified to report for random testing immediately upon reporting for a flight or just after completing the flight.
14 Tutt 6/16/2014 Fitness for Duty; Accepting Additional Assignments after Completing Assigned Flying - FAR 117.5 – Until an FDP ends a pilot who has finished his scheduled flying but has FDP time remaining may: (a) pick up a trip from open time; or (b) operate a trip at the request of the carrier.
13 Anderson – Teamsters 357 5/13/2014 FDP Holdover and Additional Flying Assignments; Standby Duty After Completion of Assigned Flying - FAR 117.25 - A carrier may keep a pilot on an FDP under Part 117 after block in on the last scheduled flight (if the pilot has FDP left). The additional standby time counts toward cumulative FDP limits. The rest requirement of 117.25(e)(10 hours) is not triggered until the FDP is terminated and a new FDP or reserve is contemplated.
12 Foltz 5/13/2014 Reserve Pilots; Short-Call; Table B may limit Maximum Duty to less than 16 hours - FAR 117.13; 117.17; 117.21 – The short-call reserve limits of 117.21(c) apply in addition to the FDP limits of 117.13 and 117.19. An unaugmented short-call reserve pilot may have a maximum total time on duty (RAP + FDP) limit of less than 16 hours – check the FDP limits under Table B.
11 McFadden 5/13/2014 Required Duty; Prohibition on Performing During Part 117 Rest; Checking Schedule During Rest; FDP Extension and Fitness for Duty Certification - FAR 117.19; 117.25 – 1. 117.25 - If a contract requires a pilot to check a schedule during Part 117 rest, it isn't a legal rest; 2. 117.19 - If a pilot's last leg is delayed after signing the fitness for duty certification, any subsequent FDP extension (even less than 30 minutes) must be affirmatively coordinated with the Company.
10 Borozenets 5/13/2014 Split-Duty Assignments After Report - FAR 117.15 - Pilots who have already reported for airport standby can be assigned to split-duty (aka CDO).
9 Wykoff & Mullen 3/20/2014 Acclimation; Deadheads; Fitness for Duty; Carrier's Designation of FDP Start Time for Series; FDP Holdover and Additional Flying Assignments; Split-Duty Rest and Extensions; Voluntary Assumption of Duty During Rest - FAR 117.3; 117.13; 117.15; 117.17; 117.19; 117.23; 117.25 – 1. 117.3; 117.13 -Acclimation is based on actual time (36 hrs. required), not scheduled time in theater; 2-3. 117.13 - Deadheads that occur after or not as part of an FDP do not cause a change in theater; 4. 117.19 - Fitness for duty certification may suffice for FDP extension up to 30 min.; 5. 117.13; 117.17 - Carrier must designate (local or home base) time for FDP start, typically in writing, which applies until next 30-hour rest; 6. 117.13; 117.17 - A 30-hour rest break triggers new opportunity for carrier to designate time zone for FDP start. Once a pilot is re-acclimated (36 hrs. required) to his or her home base theater a carrier can choose local or home base time for FDP series start, but if the carrier does not designate home base time local time applies. Specifics of designation are up to each carrier; 7. 117.13; 117.17 - A pilot may be held over with FDP clock running if the carrier is unsure whether it will use that pilot to fly another segment; 8. 117.13; 117.17 - A deadhead may be assigned after an FDP; 9. 117.23 - Cumulative limits are non-retroactive (answered on Nov. 26, 2013); 10-11. 117.15 – The 14-hour split-duty limit of 117.15 (f) is distinct from FDP limits; mid-duty rest that does not meet split-duty rest requirements counts as FDP; Table B limits apply to split-duty FDP time, which may be extended under 117.19. 12. 117.15 – Split-duty rest actually received may not be less than scheduled; 13. 117.25 - Voluntarily assuming a duty during a rest period does not violate 117, but could cause pilot to become fatigued.
8 de Cubas 2/21/2014 FAR 117 Table B Segments; Diversions – FAR 117.13; 117.17 – Diversions do not count as additional segments; but planned fuel stops do
7 Healy 2/14/2014 Reserve Pilots; Long Call; Notice of Operation into WOCL - FAR 117.21(d) – A 12-hour notice of change to the FDP start time is only required when FDP begins before and operates into WOCL, not for an FDP that begins in the WOCL.
6 Edwards 2/12/2014 Fitness for Duty Certification - FAR 117.5(d) – A separate written fitness for duty certification must be made for each segment. ACARs could be an acceptable method of compliance.
5 Schneider 12/27/2013 Rest Requirements; Non-retroactivity - FAR 117.25(b) – Part 117 is not retroactive, but the 30-hour rest look back requirement does apply at 117 implementation. (Historical interest only).
4 Wykoff and Mullen 11/26/2013 Cumulative Limits; Non-retroactivity - FAR 117.23 – Part 117 is not retroactive. The cumulative limits start anew with 117 implementation.
3 Cohn 10/23/2013 Part 117 Limitations; Applicability; All-Cargo and Intrastate Operations - FAR 121.470(b); 121.480(a) – Explanation of Part 117's exclusion of all-cargo airline operations and certain intrastate passenger airline operations conducted under Part 121.
2 Hughes 9/30/2013 Cumulative Limits are Hard Limits; Three Exceptions - FAR 117.23; 117.11(b); 117.19(b); 117.29(b) – A flightcrew member cannot take off knowing cumulative limits will be exceeded. The cumulative limitations may be exceeded only as provided by the three exceptions set forth in 117.11(b), 117.19(b) and 117.29(b).
1 A4A 11/30/2012 Theater and Acclimation; Discussed and Explained - FAR 117.3; 117.13(b); 117.17(b); 117.25(b) – Explanations of Theater and Acclimation: A FDP departure point is the location at which a flightcrew member begins a series of FDPs. If a flightcrew member becomes unacclimated, the unacclimated provisions of 117.13(b) and 117.17(b) apply until the flightcrew member becomes reacclimated.
A Other  Silverberg (2014) Slater (2012) Laurion (2012) Johnson (2000, 1992) Kania (2004)

Time spent de-icing an aircraft counts as "flight time" if the aircraft taxied to the pad under own power (Silverberg; Slater; Johnson (2000)). "Flight" refers to the time after an aircraft has left the earth's surface it is not synonymous with the definition of "flight time" for purposes of the the flight and duty regulations (Laurion). Time spent in taxi and performing required cockpit duties after aircraft moves under its own power followed by "flight" counts as "flight time" -- even in the case of a return to the gate and an equipment change (Kania). "Flight time" and "block-to-block time," compared and discussed (Johnson 1992).

B Other Ewing (2014); Robinson (2011) Required Duty for Air Carrier; Prohibition on Performing During Required Rest; Home study – A pilot may not perform work assigned by the certificate holder (e.g., distance learning) during a rest period required by the flight and duty regulations.
If you have any questions about Part 117 interpretations, please contact ALPA's Legal Department at or by phone at (703) 689-4326.