FAR 117 being re-worked?

[Seggy]

Blinker on? 100%? "Can you hear me now?"

You might have missed it as I edited it after you responded, but it is enraging to see folks misrepresenting what FAR 117 is and does.

I am also sick and tired as well as enraged about being talked down to by some folks on here who don't have a clue what the process of implementing 117 entailed, but are eager to share their opinion on it.

 

[Autothrust Blue]

You might have missed it as I edited it after you responded, but it is enraging to see folks misrepresenting what FAR 117 is and does.

My employer views it as something of an annoyance. It wasn't a smooth transition, but it also was not the industry-ending calamity everyone thought it was going to be. (I'm not sure why people thought it would be industry-ending—it's not like regulations haven't changed before—but maybe I'm more apt to just say no to adding another leg at 0200 than a lot of folks are.)

I'm in favor. I think it's sort of silly I can't do more than three consecutive AM shows, being that really irritating morning person, but I don't feel nearly as worn most of the time as I used to.

I am also sick and tired about being talked down to by some folks on here who don't have a clue what the process of implementing 117 entailed, but are eager to share their opinion on it.

Someone on the Internet is wrong!

 

[Screaming_Emu]

Incidentally, regarding UPS: It was my understanding that they would have been legal even under Part 117, as they had their two hour nap.

Everyone likes to confuse safety with legality. They're not the same thing. They're nowhere near the same thing. You can have an operation that's perfectly safe and completely illegal, and you can have a perfectly compliant operation that is ridiculously unsafe. The bottom line under 121Q (etc.) and 117 are still the same: if you think you're fatigued you don't go. (I'm not even close to 60, but I've got no problem calling in fatigued when the situation demands it.)


Ah yes, the minimum days off for minimum monthly guarantee discussion that never ends. Of course, you can also be frighteningly efficient under Part 117. @Screaming_Emu has flown 35+ hours in 7 days which was impossible under the old world order. A failure to adapt to the regulatory landscape is...unfortunate.

I've been working my ass (you can totally say ass on here) off under 117. But it's been incredibly efficient and I've been well rested for it. 117 is a home run as far as I'm concerned.

Reserve rules seem a bit complicated, but I'll admit to the fact that I've only looked at them for about 3 minutes.

 

[SlumTodd_Millionaire]

Are you going to do that before or after you accept the fact that I don't give a damn about your opinion?

Careful, wookie, one of the angry malcontents is going to suggest that you need "counseling."

If you're not careful, you're going to steal my title as the most hated guy around here.

 

[Cherokee_Cruiser]

Oh, I am the only one doing the insulting here?

Maybe I missed it. All I've seen is you and ATN telling other pilots they cannot have any opinion on the validity/effectiveness of 117 rules because it is based on science and pilots aren't qualified to make statements in that subject.

 

[Autothrust Blue]

Reserve rules seem a bit complicated, but I'll admit to the fact that I've only looked at them for about 3 minutes.

Yeah, I don't think we've done as good a job explaining things as we could (should) have, personally.

But I just work here.

 

[Screaming_Emu]

One of the best tools given to us for 117 is a little card of cliffs notes that is hanging on my lanyard. Much helpfulness. Lemme know if you guys have the same. If not I'll grab one and send it to you.

 

[Autothrust Blue]

One of the best tools given to us for 117 is a little card of cliffs notes that is hanging on my lanyard. Much helpfulness. Lemme know if you guys have the same. If not I'll grab one and send it to you.

Since we get whatever it is you get*, I have one too. It's not hard to figure out, at least for domestic work, when you time out, and so on.

* ha ha ha

 

[Screaming_Emu]

Since we get whatever it is you get*, I have one too. It's not hard to figure out, at least for domestic work, when you time out, and so on.

* ha ha ha

Did they just scribble out the ALPA logo with Sharpie?

 

[jtrain609]

One of the best tools given to us for 117 is a little card of cliffs notes that is hanging on my lanyard. Much helpfulness. Lemme know if you guys have the same. If not I'll grab one and send it to you.

I've got logten pro programmed to do the work for me. Input my flights, put in the duty times, and it tells me how much FDP I have left for the week or the month, and then also tells me how long my day is going to be. Cross reference that against the duty time table and this is a lot easier than figuring out compensatory rest, whitlow rest and determining what transport is local in nature.

 

[Dan208B]

Well, let's step back and look at the discussion @Dan208B and I were having about inflight rest breaks. If you read it strictly, it does appear that the flying pilot is meant to take the last rest break in augmented ops (though I have a different opinion of what "available" means, I'm no lawyer).

Now, I'll be honest: Because of sleep inertia, nobody takes the last rest break. I've done it once, and it wasn't fun showing up to fly at the top of descent bleary-eyed. Everyone takes the middle break; you can get your sleep in and still be wide awake for landing. While I'm certainly no sleep scientist, I am a long-haul pilot who knows how it works. My opinion is extremely valid, as are the opinions of professional pilots everywhere who have to operate under these rules.

I see 2 problems. While our employer/pilot group may be relaxed about it, I've talked with folks at at least one legacy carrier in particular that has adopted that as uninterpretable law. They take rest breaks at the times they are supposed to and are pretty well held to it by the other guys. I can understand the frustration by them. The other problem is simply what you mentioned. I am not a sleep scientist either. However, I'll say it again... Everyone is different. I know a regulation can't account for that, but I can tell you the professionals came up with something that does not work for me and many other people I know. It's that simple. The science behind it got too involved and it was assumed that it will work for everyone and every circumstance. Hard to argue with that.

 

[Autothrust Blue]

Did they just scribble out the ALPA logo with Sharpie?

I'm pretty sure our people actually put this one together. Although we should compare notes.

 

[SteveC]

Of course they can be questioned....

Then we are in agreement since that is the only point I was trying to make.

...by people who are qualified to do so. That ain't you.

Irrelevant to our discussion since I have not voiced an opinion on the rule itself.

 

[SteveC]

I'm not entirely sure if you're trying to be cute or serious, but let me approach this as if you're being serious. Mark, I believe, is likely treating you like you're being cute and hence, I believe this is why you're getting the attitude from him. Being that I can't tell what your intent is, I can't exactly blame him (or said another way, maybe you could try to be a little more clear cut and a little less laconic).

I am being serious. He made a statement that I disagree with, so I have been trying to succinctly say why I disagree.

If you're saying that people's opinions should be supplanted for hard metrics that have been found out through the rigors of the scientific method, then I can't agree with you. Opinions, as you know, are like , and I have no intention for these rules to stick.

Nope, not saying that at all. I'm just saying that science based policy is not above being disagreed with.

If you're even arguing that opinions vary on whether these rules should be implemented due to variance in opinions, then again, I still think that stinks.

It stinks because we're talking about a fiduciary responsibility to the public for our industry to behave like adults, not academic points to be argued over beers.

But frankly, Joe likely just made the point most succulently; opinions don't supplant scientific rigor.

No, not saying any of that. Just saying that the validity of science does not automatically give Policies or Rules that are based on science a free pass and are unassailable.

 

[DE727UPS]

The pairing UPS 1354 was flying would not have been compliant with 117 had it been flown to completion towards the end of the week.

Here is pic of the crew rest facility on a 767.

117 will cost money for the freight haulers. Things like quiet private rest areas during the night sort and a jumpseat that reclines nearly horizontal with a foot rest. The Seoul-Shenzen-Clark-Taipei thing (13+05 scheduled duty) will probably have to go.

Cherokee says highly paid UPS pilots should have known what they are getting into and just deal with it. What about the corporation that made 4.4 bil last year? Wouldn't want to burden them.....

 

[jtrain609]

Nope, not saying that at all. I'm just saying that science based policy is not above being disagreed with.

No, not saying any of that. Just saying that the validity of science does not automatically give Policies or Rules that are based on science a free pass and are unassailable.

Alright, Steve, then let's extend your arguments in some other realms.

We use V1 as a decision speed on departure, and it's based on determining whether you'll have enough runway to stop, or enough performance to continue to climb. That's based on science, do you think it's reasonable to disagree with that? Do you think that if somebody disagreed with takeoff performance analysis that they'd be a reasonable person? Or said another way, if somebody tossed all the numbers and said, "We're not likely to lose an engine, so let's just go," do you think that person would be safe? Do you think that person would have a valid point?

Because I think takeoff performance data is beyond reproach, and I think anybody that came on here trying to make an argument about how V1 calculations were little more than an opinion would be dismissed out of hand.

I do the same with your views on this issue, and you've tried the patience of people that have to live with this rule. I think you're being cute with an issue that multiple people in this thread lobbied to get through the congress, and I think that your caviler attitude toward how these rules came about is degrading.

 

[dasleben]

The pairing UPS 1354 was flying would not have been compliant with 117 had it been flown to completion towards the end of the week.

Here is pic of the crew rest facility on a 767.View attachment 28883


117 will cost money for the freight haulers. Things like quiet private rest areas during the night sort and a jumpseat that reclines nearly horizontal with a foot rest. The Seoul-Shenzen-Clark-Taipei thing (13+05 scheduled duty) will probably have to go.

Cherokee says highly paid UPS pilots should have known what they are getting into and just deal with it. What about the corporation that made 4.4 bil last year? Wouldn't want to burden them.....

We have the same configuration on our -300Fs. I don't know what you're complaining about. You can go into the galley and do jumping jacks to wake up anytime you want.

 

[DE727UPS]

We have the same configuration on our -300Fs. I don't know what you're complaining about. You can go into the galley and do jumping jacks to wake up anytime you want.

Hey, that was actually part of our FAA approved Fatigue Risk Management Plan.

 

[jynxyjoe]

Hey, that was actually part of our FAA approved Fatigue Risk Management Plan.

The rest you get tomorrow makes you untired now.

 

[Autothrust Blue]

Alright, Steve, then let's extend your arguments in some other realms.

We use V1 as a decision speed on departure, and it's based on determining whether you'll have enough runway to stop, or enough performance to continue to climb. That's based on science, do you think it's reasonable to disagree with that? Do you think that if somebody disagreed with takeoff performance analysis that they'd be a reasonable person? Or said another way, if somebody tossed all the numbers and said, "We're not likely to lose an engine, so let's just go," do you think that person would be safe? Do you think that person would have a valid point?

Because I think takeoff performance data is beyond reproach, and I think anybody that came on here trying to make an argument about how V1 calculations were little more than an opinion would be dismissed out of hand.

I do the same with your views on this issue, and you've tried the patience of people that have to live with this rule. I think you're being cute with an issue that multiple people in this thread lobbied to get through the congress, and I think that your caviler attitude toward how these rules came about is degrading.

I think it is too, as long as:
(1) The airplane weighs what we say it does, the temperature is what we say it is, and they're new airplanes with new engines and all the various bits are in fact functioning roughly like new, and
(2) The only eventualities we're considering are events that do NOT render the airplane unsafe or unable to fly above V1.

Every manual that I've ever read includes something to the effect of, "It is conceivable that a situation will arise outside the procedures and circumstances herein; in such cases, the Captain shall rely upon his or her judgment and experience in determining the safest and most prudent course of action."

Rules and science are important, but they will not cushion the sudden meeting of metal and mountains...as you know.

To tie this back to the thread, fatigue is a subjective and individualized phenomenon, and the bottom line remains "if you're fatigued, do not work." It's up to you to make this determination, unless you are so visibly fatigued that I can call someone for you. (I'm much more likely to just tell you that you should call out, though.)