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Newsflash from ALPA International

ALPA’s FTDT Comparison: New FAR vs. Existing Rules
December 23, 2011
As was mentioned in Thursday’s FastRead, we have developed the following matrix comparing the newly released FAA flight/duty regulations (FAR Part 117) to the existing regulations contained in FAR Part 121. The purpose of this FastRead is to give a quick-glance comparison of the FAA’s new FAR with the existing rules. Undoubtedly, there will continue to be questions on implementation and exactly how these provisions will be applied. Your FTDT Committee and ALPA’s professional staff will continue to get further clarifications and we will be posting examples on how to apply different sections of the FAA’s new regulation.

Remember, while this is a final rule, the new FAA regulations will not take effect for two years, allowing the airlines time to adjust bid and scheduling software, and develop Fatigue Risk Management Programs.

Please be on the lookout early next week for more information and specific examples.

Item   “New” FAR Part 117   Current Rule FAR Part 121
Applicability   Applicable to all types of passenger operations - scheduled and non-scheduled, domestic and international.   Different rules for scheduled, non-scheduled, domestic, supplemental and international Part 121 operations.
Flight Duty Periods (FDP)   Limits the length of the FDP based on the time of day the pilot starts the FDP and number of landings the crew is to perform. See table below.   Currently there are no limits in the regulations. The 16-hour limit was obtained through a legal interpretation and does not take into account the time of report and is not adjusted for the number of flights scheduled in the FDP.
Minimum Rest   Minimum rest is 10 hours, which begins when the crew is released from duty. This is designed to ensure an 8-hour sleep opportunity. The crew will be required to notify the company if the rest break needs to be extended to achieve the 8-hour sleep opportunity.   9 hours reducible to 8 hours that starts when the crew is released from duty and ends when the crew reports for duty. Does not factor in a sleep opportunity.
Reduced Rest   Not applicable.   Reducible to 8 hours rest.
Maximum Flight Time Limits, Unaugmented   Hard limit, not extendable. See Table below.   8 hours scheduled that can be extended due to “unforeseen circumstances.”
Cumulative Limitations  

Cumulative fatigue protections are measured in terms of flight hours…
• 100 block hours in any 672 consecutive hours (28 days)
• 1,000 block hours in any 365-day period … and duty hours:
• 60 flight duty period hours in any 168 consecutive hours
• 190 flight duty period hours in any 672 consecutive hours.  

Limits flight hours on the basis of weekly, monthly and yearly basis dependent on type of operations flown and type of equipment operated (e.g. domestic, international or supplemental).
Flight Duty Period - Split Duty   Applied to night operations between the hours of 2200 and 0500 and requires a 3-hour rest in a suitable accommodation during the FDP.   No current limits.
Reserve   -Defines short-call and long-call reserve.
-Airport/standby reserve (as defined in Part 117) is part of the pilot’s FDP.
-Maximum short-call reserve availability period is 14 hours.
-Maximum amount of time spent on reserve and FDP is the value in the Table B FDP table plus 4 hours or 16 hours, whichever is less, as measured by the start of the reserve availability period.
- May be shifted from long-call to short-call only if pilot receives a legal rest period (10 hours).  
Reserve not defined in current FAR.
FDP Extensions   FDP may be extended by 2 hours with concurrence of PIC. Extension beyond 30 minutes can only occur once before receiving a 30-hour rest period. Any extension cannot violate the cumulative duty limit. Strict reporting requirements on all extensions beyond 30 minutes.   No current rule for extensions or reporting. Everything is based on scheduled operations and flight time.
Fitness for Duty   Joint responsibility between the pilot and the airline for ensuring the pilot is fit for duty. The pilot must sign that he or she is fit for duty to take the flight. If a pilot reports fatigue, he or she must be removed from the flight.   Current FAR is vague in regards to fitness for duty.
Fatigue Risk Management Systems   Provides an option to develop an FAA-approved FRMS.   No current option.

Maximum Flight Time Limits—Unaugmented Operations

Time of Report (Acclimated) Maximum flight time (hours)
0000-0459 8
0500-1959 9
2000-2359 8

Maximum Flight Duty Period Limits—Unaugmented Operations

Time of Start
(Acclimated Time)

Maximum Flight Duty Period (hours) for lineholders
based on number of flight segments 

1   2   3   4   5   6   7+
0000-0359   9   9   9   9   9   9   9
0400-0459   10   10   10   10   9   9   9
0500-0559   12   12   12   12   11.5   11   10.5
0600-0659   13   13   12   12   11.5   11   10.5
0700-1159   14   14   13   13   12.5   12   11.5
1200-1259   13   13   13   13   12.5   12   11.5
1300-1659   12   12   12   12   11.5   11   10.5
1700-2159   12   12   11   11   10   9   9
2200-2259   11   11   10   10   9   9   9
2300-2359   10   10   10   9   9   9   9

In the next FTDT FastRead: How to apply specific sections of the FAA’s new regulation to our schedules.

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