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Old 12-21-2011, 01:19 PM
  #84061  
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Originally Posted by RonRicco
I wonder why that hasn't been the case at Delta then already? We have had much tighter duty days etc than the FAR's and many other carriers.. Yet we haven't been forced to change. (just making the point that it is not an absolute)

The other thing to look at when it comes to flight time, it is a HARD time. That means if you have yet to take off and you are now projected to go over due to a long taxi time, you must go back to the gate. As it stands now the company can schedule for 7:59 and have no fear if it goes over. If they push it that close now say on a SXM turn and you go over 2 minutes, you can not take off for the return flight. Same with a 2 man crew that "may" be legal to go to Europe blocked at 8:45.. 15 minute delay in JFK and they are toast. Is it worth the risk to try this with a two man crew?

Not saying that a company wont try anything, but my guess is there will have to be a heavy buffer between scheduled and what is legal or they will run a huge risk of getting planes stuck in places they do not want them, or a lot of gate returns. Doesn't take to many xled flights to make up for the cost of a third pilot.
That is an excellent point.
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Old 12-21-2011, 01:25 PM
  #84062  
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Originally Posted by DAL 88 Driver
If the FAA is serious about safety, they need to be taking a very hard look at what has happened to this profession over the past decade. Same goes for ALPA or any other pilot's union that claims safety as its number one priority.
Bingo! They won't ask the question because they know the answer.
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Old 12-21-2011, 01:36 PM
  #84063  
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Originally Posted by DAL 88 Driver
That is an excellent point.
Except that the SXM turn now gets 9 hours which makes it a 1 crew turn everyday.

Last edited by vprMatrix; 12-21-2011 at 01:37 PM. Reason: s
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Old 12-21-2011, 01:55 PM
  #84064  
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Originally Posted by Milehighrabbi
From 117.25:
Read it carefully. Commuting just got a whole lot more interesting.
I don't see anything new. All it says is we must have 10 hours rest before/between assignments. Sounds like what we already have.
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Old 12-21-2011, 01:58 PM
  #84065  
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Originally Posted by 1234
I am not following you. How do you get that commuting will get more interesting from that reference.
I hope I'm wrong, but the way I read it is this:

Prior to duty, a crewmember must have a rest period as defined by 117.25(e):

(e) No certificate holder may schedule and no flightcrew member may accept an assignment for any reserve or flight duty period unless the flightcrew member is given a rest period of at least 10 consecutive hours immediately before beginning the reserve or flight duty period measured from the time the flightcrew member is released from duty. The 10 hour rest period must provide the flightcrew member with a minimum of 8 uninterrupted hours of sleep opportunity.
This defines a rest period as 10 consecutive hours free of duty, of which, 8 must consist of an uninterrupted sleep opportunity. A ride on a jumpseat is not likely to be considered an uninterrupted sleep opportunity. Remember: this 117.25(e) rest period must take place immediately before beginning the reserve or flight duty period. Pilots tend to forget that rest requirements are to take place prior to duty, not after duty. The reference measured from the time the flightcrew member is released from duty means that the ten hours prior to duty can not consist of any duty time, not just flight time (in our case, 30 minutes after block in).

Stated more simply: When you go off-duty, you must be able to look back and identify a ten-hour rest period, eight of which must be an uninterrupted sleep opportunity, that took place immediately prior to signing in for duty.

And on top of that, we have to report if we don't get it (117.25(f)):

(f) If a flightcrew member determines that a rest period under paragraph (e) of this section will not provide eight uninterrupted hours of sleep opportunity, the flightcrew member must notify the certificate holder. The flightcrew member cannot report for the assigned flight duty period until he or she receives a rest period specified in paragraph (e) of this section.
Add to that 117.5(d):



(d) As part of the dispatch or flight release, as applicable, each flightcrew member must affirmatively state he or she is fit for duty prior to commencing flight.
I sincerely hope that this get interpreted by the FAA to apply only to layovers, but there is nothing in this language to suggest that this is the case.

One thing is for certain: It will take a while to find out how the various players interpret these new regulations, and there's going to be some battles.

We live in interesting times.
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Old 12-21-2011, 02:01 PM
  #84066  
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I still only read it as saying we must be scheduled for 10 hours rest.
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Old 12-21-2011, 02:16 PM
  #84067  
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Cargo exclusion : despicable, if not criminal........
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Old 12-21-2011, 02:21 PM
  #84068  
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It is all about the context of what they are discussing.

in the NPRM commuting and rest was addressed specifically. I do not see it addressed specifically in the rule making like it was in the NPRM. Suffice to say more of that stuff was study and report back. Because of that language in the NPRM, if they try to apply this to commuting, the majority position should be that there was no study and no report ergo it does not apply to the time before your original report for duty.

If for some reason it does, the ATA will have a bird because there was no way for them to message their contracts with their labor groups. I see both sides not wanting to touch commuting with these FAR's. Of course Johnso, it depends on how the FAA "interprets" each little nugget they dropped in this new FAR.
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Old 12-21-2011, 02:22 PM
  #84069  
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Originally Posted by FedElta
Cargo exclusion : despicable, if not criminal........
Agreed, and I expect to see some strong words etc from those groups. I have talked to a few of their reps today, and mad does not even begin to describe how they feel.

They were asked to come to DC next week......
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Old 12-21-2011, 02:25 PM
  #84070  
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The company may have to make pairings that report at 10AM or 12 noon with a scheduled rest period then your first flight is 8pm or 10 PM. That lets guys commute in and get rest on the co dime while in the crew room sleep area.
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