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FDP Extension Concurrence / Refusal and Fatigue under 117.19

The FAA posted a clarification regarding 117.19 FDP extensions.

  • Certificate holder / PIC Concurrence
  • PIC Refusal
  • Fatigue

Anderson-Teamsters357 -1- (2014) Legal Interpretation

FAA Clarifications 08-Jul-2014

The FAA dealt with the following topics:

Definition of Unplanned events.

Mandatory concurrence with FDP Extension.

Company requirement to check schedule during an assigned rest period.

Garciglia – (2014) Legal Interpretation

Phelan-PPA Global Energy – (2014) Legal Interpretation

 

Keeping the FDP clock running

The FAA released another letter of interpretation 16-Jun-2014.

This letter addresses volunteer flying by a FCM, and conversion from DHD.

Tutt – (2014) Legal Interpretation

 

Examples for FCM kept on FDP after arrival.

I have created a series of examples to aid in explanation of the following FAA letters of clarification:

Anderson-Teamsters357 – (2014) Legal Interpretation and A4A – ALPA full letter final (4) (Question 7).

 

Assumptions applied to the examples:

  • The Flightcrew Member (FCM) is in an acclimated state.
  • The FCM was not assigned via any reserve process.
  • The FDP operates with 2 FCM.
  • The Times depicted are in Local Time.
  • The Cumulative FDP limits and Cumulative Flight Time limitations in 117.23, will not be exceeded.
  • The preceding rest period is 48:00.

 

Example #1

Report 7:00

Scheduled FDP

Elapsed FDP
Flight Dep Arr Block Table B
1 LGA 8:00 DCA 9:00 1:00 14:00 2:00
2 DCA 10:45 LGA 11:45 1:00 14:00 4:45
3 LGA 12:30 DCA 13:30 1:00 13:00 6:30
4 DCA 14:15 LGA 15:15 1:00 13:00 8:15
Report 15:30

 

The FCM is scheduled within all the limitations of FAR 117 (117.11, 117.13).

 

Example #2

Report 7:00

Re-Scheduled FDP

Elapsed FDP
Flight Dep Arr Block Table B
1 LGA 11:00 DCA 12:00 1:00 14:00 5:00 Delayed
2 DCA 12:45 LGA 13:45 1:00 14:00 6:45 Delayed
5 LGA 17:00 BOS 18:00 1:00 13:00 11:00
6 BOS 18:45 LGA 19:45 1:00 13:00 12:45
Report 20:00

 

Since the FCM is unable to operate the last two flights in Example #2, the FCM is now re-scheduled to operate Flights 5 and 6. This is legal, since the crewmember is within the schedule limitations under 117.13. It should be noted that the re-computation of the FDP limits in 117.13 due to the re-schedule is required.

 

 

Example #3

Report 7:00

Flightcrew member kept on FDP

Elapsed FDP
Flight Dep Arr Block Table B
1 LGA 11:00 DCA 12:00 1:00 14:00 5:00 Delayed
2 DCA 12:45 LGA 13:45 1:00 14:00 6:45 Delayed
FDP LGA 13:45 LGA 17:00 13:00 10:00
Release 17:00

 

In this case again, due to the delay of the first two flights the FCM will not be able to operate the last two flights as depicted in example #1. The FCM is instructed to remain on FDP until 17:00 to await further assignment. At this time the FCM is still accumulating FDP time, this time will be required to be applied towards any further Cumulative FDP limits as stipulated under 117.23 (c) for FDP assignments in the future 168:00 and future 672:00.

 

Example #4

Report 7:00

Flightcrew member kept on FDP

Then Scheduled Further Flights

Elapsed FDP
Flight Dep Arr Block Table B
1 LGA 11:00 DCA 12:00 1:00 14:00 5:00 Delayed
2 DCA 12:45 LGA 13:45 1:00 14:00 6:45 Delayed
FDP LGA 13:45 LGA 17:00 13:00 10:00
5 LGA 17:00 BOS 18:00 1:00 13:00 11:00
6 BOS 18:45 LGA 19:45 1:00 13:00 12:45
Report 20:00

 

The further assignment of flight time (flights 5 and 6) behaves just like example #2. This is legal, since the crewmember is within the schedule limitations under 117.13. It should be noted that the re-computation of the FDP limits in 117.13 due to the re-schedule is required.

 

 

Example #5

Report 7:00

Flightcrew member kept on FDP

Then Scheduled Further Flights

Elapsed FDP
Flight Dep Arr Block Table B
1 LGA 11:00 DCA 12:00 1:00 14:00 5:00 Delayed
2 DCA 12:45 LGA 13:45 1:00 14:00 6:45 Delayed
FDP LGA 13:45 LGA 17:50 13:00 10:50
5 LGA 17:50 BOS 18:50 1:00 13:00 11:50 Delayed
6 BOS 19:20 LGA 20:20 1:00 13:00 13:20 Delayed
Report 20:35

 

Flights 5 and 6 are also delayed, at this point, the crewmember is exceeding the limitations under 117.13, however due to the extensions permitted under 117.19, the continuation of the assignment is legal, as the FDP is permitted to be extended to 15:00.

 

Example #6

Report 7:00

Flightcrew member kept on FDP

Then Scheduled Further Flights

Elapsed FDP
Flight Dep Arr Block Table B
1 LGA 11:00 DCA 12:00 1:00 14:00 5:00 Delayed
2 DCA 12:45 LGA 13:45 1:00 14:00 6:45 Delayed
FDP LGA 13:45 LGA 17:30 13:00 10:30
7 LGA 17:30 DCA 18:30 1:00 13:00 11:30
8 DCA 19:15 LGA 20:15 1:00 13:00 13:15 Illegal
Report 20:30

 

Unlike examples #2 and #4, this FCM has been assigned flights that fall outside the limitations of 117.13. While the FCM could operate flight #7, the FCM could not be scheduled to operate flight #8. This differs from example #5 because in example #5, the FCM was first schedule legal as depicted in example #4, and then was extended under 117.19.

 

FAA Interpretations 13-May-2014

The concern as to the limitations of RAP/FDP

Foltz – (2014) Legal Interpretation

Continuation of FDP to add on Flights

Anderson-Teamsters357 – (2014) Legal Interpretation

Split Duty assigned to ASB

Borozenets – (2014) Legal Interpretation

Requirement to Check Schedule

McFadden-UAL – (2014) Legal Interpretation

 

ALPA FTDT Chairman Capt.Wykoff discuss the interpretations with ALPA members in the attached video:

ALPA Video 15-May-2014

 

EASA FTL – Effective 2016

Those operators under EU-OPS and the various NAA regulations within the European Union should consult this site.

I have prepared a sister site to aid in understanding the new regulations.

http://understandingeasa2016ftl.wordpress.com/

De-Icing / Anti-Icing procedures and its impact on Flight Time.

The FAA has just clarified its interpretation concerning the the proper accounting of flight time with respect to De/Anti-Icing procedures.

Silverberg-Silverberg, Goldman & Bikoff

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