FAR 117 being re-worked?

Christ guys, the FAA puts out legal interpretations every month. Just because you haven't been paying attention doesn't mean that ALL the rules aren't constantly being massaged. How about the one recently that explained AGAIN when flight time starts? Or what holding out is?

This is a normal part of the process that is constantly happening, you just didn't realize it until part 117 came out.

Well, ALPA is doing a better job of distributing the interpretations now, I guess. How's the weather up there anyway?
 
How about you give me that website with the interpretations!?

No honestly, can you give me some site for the update? All this talk about people having trouble makes me think I should learn something about it. I just use the chart.

Well, ALPA is doing a better job of distributing the interpretations now, I guess. How's the weather up there anyway?

http://www.faa.gov/about/office_org.../agc/pol_adjudication/agc200/interpretations/

It's the top four hits on Google if you search "FAA chief counsel legal interpretations." This is not, has never been, and never will be proprietary data.
 
No, there is no conference to discuss changing the regs. Industry stakeholders get together to talk about things all the time, however. I'm sure a normal meeting is just being blown out of proportion. If anything, the recent UPS sunshine hearing will create added pressure to get rid of the cargo carve-out. The regs aren't going anywhere or getting changed. Just some interpretations here and there to clear up any ambiguity.
 
http://www.faa.gov/about/office_org.../agc/pol_adjudication/agc200/interpretations/

It's the top four hits on Google if you search "FAA chief counsel legal interpretations." This is not, has never been, and never will be proprietary data.
...never said was proprietary, but a lot of us don't know what the hell a chief counsel is or to look for it. Went through the recent ones and I don't see much about 117, saw one thing about flight time definition, but not much else.

Theres this : http://www.faa.gov/about/office_org..._adjudication/agc200/Part117/Part117_General/
But I cant see much there

I'm not asking you to teach me here, but it doesn't look like much is out there overriding the majoirty of that advisory put out by the FAA or the ALPA guidline sheet from a couple months back. Am I dense and missing so something painfully obvious?
 
Sorry man, but you're full of it, Holmes. Down here, reduced rest overnights were a goal. There's no way sleeping 5 hours a night for a four day was safe.

I've been seeing this a lot on here lately and it's been bugging me. I'm gonna go out on a limb and say, I don't think East LA gangsters are referring to their friends by the name of some fictitious English detective's name. It's homes as in homie. Just saying.
 
I've been seeing this a lot on here lately and it's been bugging me. I'm gonna go out on a limb and say, I don't think East LA gangsters are referring to their friends by the name of some fictitious English detective's name. It's homes as in homie. Just saying.
Trust me, I've tried correcting him on that more than once. He just does it more.
 
From the people I've spoken with, this rule has helped a lot of regional pilots who's schedules often included reduced rest overnights and such. The other upside would be the increased quality of rest facilities on heavies. Otherwise this doesn't help cargo, and many major and regional pilots that had good schedules originally have commented that this has made their schedule worse, their commute harder, etc. Seems like on average it requires at least a day more of work to accomplish the same monthly credit. One legacy pilot I spoke with who is a senior domestic 737 guy said he's never been as tired as he has been since the new rules came into play. The point here is the mileage may vary but there are definitely some improvements that could be made. The number one detriment I see is the absolute hard requirements for onboard crew rest. They now dictate who rests when and I can personally attest to the fact that every person is different as far as what works best for them. If I depart on an international flight that leaves at 10pm from my home airport and is 10 hours long I would prefer the first break because I know I could sleep the best, but the new rules do not allow for that, you do not get the choice. I think that is much more dangerous than allowing the crew to sort it out. Hopefully some of these issues can be addressed.
 
I've been seeing this a lot on here lately and it's been bugging me. I'm gonna go out on a limb and say, I don't think East LA gangsters are referring to their friends by the name of some fictitious English detective's name. It's homes as in homie. Just saying.

Holmes, as in Sherlock; the greatest detective to ever live.

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From the people I've spoken with, this rule has helped a lot of regional pilots who's schedules often included reduced rest overnights and such. The other upside would be the increased quality of rest facilities on heavies. Otherwise this doesn't help cargo, and many major and regional pilots that had good schedules originally have commented that this has made their schedule worse, their commute harder, etc. Seems like on average it requires at least a day more of work to accomplish the same monthly credit. One legacy pilot I spoke with who is a senior domestic 737 guy said he's never been as tired as he has been since the new rules came into play. The point here is the mileage may vary but there are definitely some improvements that could be made. The number one detriment I see is the absolute hard requirements for onboard crew rest. They now dictate who rests when and I can personally attest to the fact that every person is different as far as what works best for them. If I depart on an international flight that leaves at 10pm from my home airport and is 10 hours long I would prefer the first break because I know I could sleep the best, but the new rules do not allow for that, you do not get the choice. I think that is much more dangerous than allowing the crew to sort it out. Hopefully some of these issues can be addressed.
As far as when we're allowed to take inflight breaks, 117 says "Two consecutive hours in the second half of the flight duty period are available for in-flight rest for the pilot flying the aircraft during landing."

I take that to mean that as long as the PF has the option of taking last break (i.e., it's available), that's good enough. If he prefers middle break like most of us, that's allowable as long as the last break was made available. I don't know...that's just how I choose to see it. I'm sure the FAA will come out with some LOI that shoots that all down. :)
 
...never said was proprietary, but a lot of us don't know what the hell a chief counsel is or to look for it. Went through the recent ones and I don't see much about 117, saw one thing about flight time definition, but not much else.

Theres this : http://www.faa.gov/about/office_org..._adjudication/agc200/Part117/Part117_General/
But I cant see much there

I'm not asking you to teach me here, but it doesn't look like much is out there overriding the majoirty of that advisory put out by the FAA or the ALPA guidline sheet from a couple months back. Am I dense and missing so something painfully obvious?

Well, a few things.

First, there aren't a ton of interpretations on part 117, and you won't find more than what ALPA has been sending out in their FastRead's, because they've put every single part 117 interpretation in there as far as I can see. So if you're looking for more, they don't exist.

Second, the majority of part 117 was pretty easy to understand and apply, so you're not going to need interpretations on the majority of the rule. Take the chart that explains how long you can be on duty; do we REALLY need an interpretation to explain to us what 1 leg is? No, it's obvious enough.
 
For what it's worth this website is pretty good, I've spoken with the guy who puts it together and he's sharp. It's not an "official" APLA publication but the power point walkthrough is pretty good as are the flow charts, it looks like he has some kind of app now too. To be fair I haven't looked or worried about this type of stuff in a year much since I changed jobs but this is a good place to start.

http://far117understanding.wordpress.com/daily-limitation-tools/
 
Maybe they will decide the guys that fly all night all the time should be included in the reg.....

I actually ran into one of your coworkers on a deadhead from SBN to ORD. Somehow the topic came up and he said he was against it as it would affect productivity. After that I just assumed he was a management pilot.

In the middle of the night 117 would limit most of your domestic stuff to 9-11 hour duty days. I know it's a different animal, but I've been flying more since 117, they've just had to be more efficient trips. My company still has the 30 in 7 metric up on our schedules and I'm very often around 30-33 hours...plus I can see straight on my drive home from work. Win win.

I view 117 the same way I do the passenger's bill of rights. It's making our company plan ahead and be proactive to avoid problems.
 
As far as when we're allowed to take inflight breaks, 117 says "Two consecutive hours in the second half of the flight duty period are available for in-flight rest for the pilot flying the aircraft during landing."

I take that to mean that as long as the PF has the option of taking last break (i.e., it's available), that's good enough. If he prefers middle break like most of us, that's allowable as long as the last break was made available. I don't know...that's just how I choose to see it. I'm sure the FAA will come out with some LOI that shoots that all down. :)

Think it depends too on how the airline and captain interpret it. I would agree with you but many folks I've talked to feel like they were not given a choice in the matter.
 
Think it depends too on how the airline and captain interpret it. I would agree with you but many folks I've talked to feel like they were not given a choice in the matter.

The defining factor will be when there is an accident and it comes out that the pilot landing didn't take the last rest break, does the FAA go after them for that or not.
 
The defining factor will be when there is an accident and it comes out that the pilot landing didn't take the last rest break, does the FAA go after them for that or not.
Sadly, you're probably right. I've always felt the worst if I land after the last break, though. You roll up into the cockpit at the top of descent still half asleep. For all this talk about sleep inertia, they didn't really think that one through.
 
Sadly, you're probably right. I've always felt the worst if I land after the last break, though. You roll up into the cockpit at the top of descent still half asleep. For all this talk about sleep inertia, they didn't really think that one through.
Do some jumping jacks.
 
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