The New FAR Part 117

[Seggy]

It's way more complicated than the 135 duty rules I'm accustomed to working with - and on top of that it doesn't address anything other than passenger airline pilots.

Part 135 rules and cargo rules definitely need to be included in the new Part 117.

That doesn't mean that Part 117 is complicated though. You basically use your finger to follow a chart, rest IS rest, and none of this legal to start, legal to finish crap.

 

[ppragman]

Part 135 rules and cargo rules definitely need to be included in the new Part 117.

That doesn't mean that Part 117 is complicated though. You basically use your finger to follow a chart, rest IS rest, and none of this legal to start, legal to finish crap.

I can appreciate that, however, in my perfect world, my rule would be "no longer than 12hr duty days, no more than 8flt hrs in that time for domestic flights. On international trips, if the flight is longer than 8hrs, then you need multiple crews and they those that don't fly initially need to have a place where they're able to lie down and sleep, after a trip that takes more than 12hrs, you need to have a full 24hrs off - this applies to all crewmembers on the flight." If that has an impact on economics, then so be it.

 

[L-16B]

Yes and the answer is no, days off really don't suffer because of these rules. At first airlines may overreact and schedule huge buffers, but they will go away quickly. If anything, I think the biggest downfall will be a lot more canceled flights at the regional level as the duty limits are hard and the mainline partners will cancel the RJs to get the bigger planes to where they need to go. As a matter of fact you may get MORE days off as you can fly up to 9 hours which opens up more productivity.

Domestically look for 11 hour duty days with 7:30 to 8:30 of flying when all the dust settles. Not to much with change for the food and movie critic flying @Derg does. Ultra Long Haul things will change moreso.

While I'll agree with u for senior guys doing long turns up to 9 hours, a certain French friend of ours disagrees. What about standups?

 

[Seggy]

I can appreciate that, however, in my perfect world, my rule would be "no longer than 12hr duty days, no more than 8flt hrs in that time for domestic flights. On international trips, if the flight is longer than 8hrs, then you need multiple crews and they those that don't fly initially need to have a place where they're able to lie down and sleep, after a trip that takes more than 12hrs, you need to have a full 24hrs off - this applies to all crewmembers on the flight." If that has an impact on economics, then so be it.

Explain the science to back up your 'perfect world'. Especially how circadian rhythm plays into this. Because in your 'perfect world' two pilots can show up in LAX at midnight, fly to JFK, sit for a few hours, and then fly down to Orlando.

If your finger can follow a chart, you can easily see that is NOT possible with Part 117.

 

[Seggy]

While I'll agree with u for senior guys doing long turns up to 9 hours, a certain French friend of ours disagrees. What about standups?

I got plenty of turns being extremely junior that were close to 8 hours...

He also needs to pay more attention to other parts of the rules.

 

[ppragman]

Explain the science to back up your 'perfect world'. Especially how circadian rhythm plays into this.

Nothing scientific - but anecdotally in the years I've spent on the back side of the clock, I've found that anything longer than 12hrs exhausts me and anyone I've ever worked with, any flying longer than 8hrs tends to seriously exhaust me and anyone I've ever worked with. Whether I started working at 2 in the morning, or 2 in the afternoon I've found that this has been the case for me. I I'd be interested in learning more about the science for sure though.

 

[higney85]

Yes and the answer is no, days off really don't suffer because of these rules. At first airlines may overreact and schedule huge buffers, but they will go away quickly. If anything, I think the biggest downfall will be a lot more canceled flights at the regional level as the duty limits are hard and the mainline partners will cancel the RJs to get the bigger planes to where they need to go. As a matter of fact you may get MORE days off as you can fly up to 9 hours which opens up more productivity.

Domestically look for 11 hour duty days with 7:30 to 8:30 of flying when all the dust settles. Not to much with change for the food and movie critic flying @Derg does. Ultra Long Haul things will change moreso.

In the regional model, it's about a 10% hit in productivity. Meaning 1-2 days off for line holders and a 8-9% higher total staffing model required.

 

[Seggy]

In the regional model, it's about a 10% hit in productivity. Meaning 1-2 days off for line holders and a 8-9% higher total staffing model required.

Eh, do you guys still have min day? Wouldn't that offset any productivity hits....

 

[higney85]

Eh, do you guys still have min day? Wouldn't that offset any productivity hits....

You are kidding right? Average block:duty tends to be 5-5:30 per period (mixing 200/900). Take 10% off min. 4 hours a day would end up @ 19 working days a month to hit 75 credit. Currently it's 12-14ish working days to hit 75 credit. I know we are in slightly different "realms" but 117 will be hurting days off... Although we may be more rested during trips and not "spent" after the last block in.

 

[Nick]

If anything, I think the biggest downfall will be a lot more canceled flights at the regional level as the duty limits are hard and the mainline partners will cancel the RJs to get the bigger planes to where they need to go. As a matter of fact you may get MORE days off as you can fly up to 9 hours which opens up more productivity.

Domestically look for 11 hour duty days with 7:30 to 8:30 of flying when all the dust settles.

I have to somewhat disagree here, depending on the type of fleet you are talking about.

A fleet that is thin and spread out over a number of bases will be hit hard with these new rules, whereas I believe a fleet that has hundreds of flights out of one hub per day will have ample 'pieces to the puzzle' to avoid unproductive workdays.

I think where I work, a lineholder who bids around 60-80% will lose 3-5 days off per month when these new rules come out, because the flying is so spread out.

Perhaps in time though, the carrier that schedules the flights may end up concluding that small fleets ought to be a bit less spread out so as to avoid unproductive workdays.

 

[ASpilot2be]

Or any 135 for that matter. I can fly up to 1400hrs in a year with only 13 days off per quarter...

Yeah. I couldnt even imagine timing out in the 135 world. Working 72-84 hours per week for three weeks straight is exhausting.

 

[ppragman]

Yeah. I couldnt even imagine timing out in the 135 world. Working 72-84 hours per week for three weeks straight is exhausting.

I've come close.

 

[ASpilot2be]

I've come close.

Ouch! Thats crazy.

 

[eightballfreight]

I think they missed the chance to take the good work they did and simplify it.
-12 hour duty days max
- keep the current flight hour/day max, kill the 30 in 7, keep the yearly.
- 30 hours consecutive rest per week
- stands-up duty day doesn't get a cut out.

Done.

 

[Seggy]

You are kidding right? Average block:duty tends to be 5-5:30 per period (mixing 200/900). Take 10% off min. 4 hours a day would end up @ 19 working days a month to hit 75 credit. Currently it's 12-14ish working days to hit 75 credit. I know we are in slightly different "realms" but 117 will be hurting days off... Although we may be more rested during trips and not "spent" after the last block in.

No I am not kidding.

While I agree with you that on a TEMPORARY basis, you may lose a day off per month until the company figures out how to increase the productivity, the 5-5:30 per period credit will increase to hover around the 6:30 to 7:00 mark. Carrying 8-9% extra staffing is going to be increasingly difficult at the regional level so regional management will need to learn to be more efficient with their operation to compensate.

 

[Seggy]

I have to somewhat disagree here, depending on the type of fleet you are talking about.

A fleet that is thin and spread out over a number of bases will be hit hard with these new rules, whereas I believe a fleet that has hundreds of flights out of one hub per day will have ample 'pieces to the puzzle' to avoid unproductive workdays.

I think where I work, a lineholder who bids around 60-80% will lose 3-5 days off per month when these new rules come out, because the flying is so spread out.

Perhaps in time though, the carrier that schedules the flights may end up concluding that small fleets ought to be a bit less spread out so as to avoid unproductive workdays.

While I love you man, I can't say I agree with your assessment of losing an addition 3 to 5 days off per month. I can buy that, TEMPORARILY, some will lose a day off here and there until regional management can figure out how to increase the productivity in the pairings. But to lose 3 to 5 days off per month increases hotel, per diem, and staffing costs which management will want to counter.

Plus you and @amorris311 are being contradictory over y'alls flying. He says 'it is nice'. (inside joke here, this sentence has nothing to do with the thread and EVERYTHING to do with busting Andrew's balls.)

In all seriousness, speaking at length over the last few years to the ALPA Rep on the Aviation Rule making Committee with Part 117, the ARC feels the way I do here. Well, actually I have formulated my views based on their work. Yes, it will take them a few bid periods to figure it out, but efficiency will be increased, it needs to. If not, crews will be timing out all over the place.

 

[Seggy]

I think they missed the chance to take the good work they did and simplify it.
-12 hour duty days max
- keep the current flight hour/day max, kill the 30 in 7, keep the yearly.
- 30 hours consecutive rest per week
- stands-up duty day doesn't get a cut out.

Done.

Unfortunately, to properly create proper flight time duty time regulations, it can't be simple to do it right.

 

[pete2800]

From Bad Reglion's "Infected"- You're as clear as a heavy lead curtain

A Bad Religion reference!

You know, you're alright Derg. This is for you.

 

[kellwolf]

My company just finished an eval on how our schedules would be affected. To echo Seggy, the answer wasn't much. The airbus schedules saw next to no change. The E190 saw only a 2% loss in days off for similar credit, mainly because the 190 does a lot of 3 leg with occasional 4 leg day. Airbus guys cry when they get 3 legs.

 

[Baronman]

My company just finished an eval on how our schedules would be affected. To echo Seggy, the answer wasn't much. The airbus schedules saw next to no change. The E190 saw only a 2% loss in days off for similar credit, mainly because the 190 does a lot of 3 leg with occasional 4 leg day. Airbus guys cry when they get 3 legs.

I cry when they call me to work!