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FAA FNPRM Compliance: Pilot Flight/Duty Time Limitations and Rest Requirements

Learn about the FAA's Final Notice of Proposed Rule Making (FNPRM) on pilot flight/duty time limitations and rest requirements. Find out when airlines must comply, what they need to do, and the major changes in scheduling concepts.

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FAA FNPRM Compliance: Pilot Flight/Duty Time Limitations and Rest Requirements

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  1. Introduction • What is the FNPRM? • The FAA published the FNPRM (Final Notice of Proposed Rule Making) on • 04Jan2012 in the Federal Register. • The regulations establish: • Pilot - Flight / Duty Time Limitations and Rest Requirements. • When do the Airlines have to comply? • Simply put, 04Jan2014, this date is two years since the publication date. • What do the Airlines have to do to comply? • Develop scheduling policies. • Develop training programs. • Update their Operations Specification (OPSPEC). • Upgrade crewmember scheduling software, including crew planning and crew tracking software.

  2. Intent of this presentation • To summarize the following sections of the FNPRM. • 117.1 Applicability. • 117.3 Definitions. • 117.11 Flight time limitation. • 117.13 Flight duty period: Un-augmented operations. • 117.15 Flight duty period: Split duty. • 117.17 Flight duty period: Augmented flightcrew. • 117.19 Flight duty period extension. • 117.21 Reserve status. • 117.23 Cumulative duty limitations. • 117.25 Rest period. • 117.27 Consecutive nighttime operations.

  3. Not included in this presentation • The following sections of the FNPRM. • 117.5 Fitness for duty • 117.7 Fatigue risk management system • 117.9 Fatigue education and training program • 117.29 Emergency and government sponsored operations

  4. Major Changes • Applicability: • Part 121 passenger operations must apply FAR part 117 for all operations conducted under - • Domestic (subpart Q) or • Flag (subpart R) or • Supplemental (subpart S) • Part 121 All cargo operations • may still operate under FAR 121 subparts Q, R or S

  5. Major Changes • New scheduling concepts include: • Flight Duty Period (FDP) • Acclimatization • Window of Circadian Low (WOCL) • Part 91 Flights • are now considered the same as Part 121 Flights when conducted during a series of FDP operating under 117. • Note: clarifying questions to the FAA have been made concerning the required separation between Part 91 and Part 121 to qualify specific Part 91 flights not to be subject to FAR Part 117 .

  6. Major Changes • Accumulative Limitations for: • Flight Duty Period • Flight Time (Block) • Extended Flight Duty Periods • Consecutive Night Duty

  7. Does not include at this time • Part 135 operations • Part 91 Subpart K operations • Part 121 Flight Attendants • Airlines may elect to apply these rules to FA’s

  8. Basic Definitions Calendar day means a 24-hour period from 0000 through 2359 using Coordinated Universal Time (UTC) or local time (Base time). Duty means any task that a flightcrew member performs as required by the certificate holder, including but not limited to flight duty period, flight duty, pre- and post-flight duties, administrative work, training, deadhead transportation, aircraft positioning on the ground, aircraft loading, and aircraft servicing. Report time means the time that the certificate holder requires a flightcrew member to report for an assignment. Rest period means a continuous period determined prospectively during which the flightcrew member is free from all restraint by the certificate holder, including freedom from present responsibility for work should the occasion arise.

  9. Basic Definitions Scheduled means to appoint, assign, or designate for a fixed time. Sleep opportunity means a period of time when a crewmember is provided and allowed to be in a suitable accommodation to rest in. Suitable accommodation means a temperature-controlled facility with sound mitigation and the ability to control light that provides a flightcrew member with the ability to sleep either in a bed, bunk or in a chair that allows for flat or near flat sleeping position. Suitable accommodation only applies to ground facilities and does not apply to aircraft onboard rest facilities. Unforeseen operational circumstance means an unplanned event of insufficient duration to allow for adjustments to schedules, including unforecast weather, equipment malfunction, or air traffic delay that is not reasonably expected.

  10. Augmentation • The use of Augmentation is restricted under the following conditions: • At least one flightcrew member with a PIC type rating must be present and alert on the flight deck at all times. • A limitation of 3 flight segments in any FDP. • Ninety consecutive minutes are available for in-flight rest for the pilot performing monitoring duties during landing. • The flightcrew member who will be landing the aircraft on the final leg of the FDP is required to have 2 hours of uninterrupted rest in the second half of the FDP.

  11. Augmentation • Rest facilitymeans a bunk or seat accommodation installed in an aircraft that provides a flightcrew member with a sleep opportunity. • Class 1 rest facilitymeans a bunk or other surface that allows for a flat sleeping position and is located separate from both the flight deck and passenger cabin in an area that is temperature-controlled, allows the flightcrew member to control light, and provides isolation from noise and disturbance. • Class 2 rest facilitymeans a seat in an aircraft cabin that allows for a flat or near flat sleeping position; is separated from passengers by a minimum of a curtain to provide darkness and some sound mitigation; and is reasonably free from disturbance by passengers or flightcrew members. • Class 3 rest facilitymeans a seat in an aircraft cabin or flight deck that reclines at least 40 degrees and provides leg and foot support.

  12. Augmentation Applied Flightcrew Member Schemes All operational flights contained within a FDP shall be evaluated to determine the minimum applied scheme as follows: • This is consistent with current FAR interpretations, to avoid circumvention of Flight Time / Flight Duty Time Limitations and Rest Requirements. • FDP with more than 3 legs scheduled, must apply • 2 Pilot Schemes (Un-augmented).

  13. Flight Duty Period (FDP) Release Time ReportTime DutyTime Arrive Time FDP Note: Difference between Duty Time and FDP 121 121 91 DHD Block Flight Time Between Rest Periods Flight Time between rest periods - is the sum of the Block for all legs contained within the duty period.

  14. Acclimatization A Theater is a zone 60 degrees wide, relative to the departure station of the duty period. JFK 073 deg West SFO 122 deg West CDG 002 deg East JFK to SFO is in the same Theater. 49 deg difference JFK to CDG Exits the Theater. 75 deg difference

  15. Acclimatization • A crewmember is deemed to be acclimated whenever that individual has either: • At least 36 hours continuous rest within a specific theater • or • has remained in a specific theater for at least 72 hours. • Otherwise the individual is NOT acclimated. JFK - CDG CDG – ATH - CDG CDG - JFK Rest < 36 Rest >= 36 Time in Theater < 72 Theater 1 acclimated Theater 2 un-acclimated Theater 2 acclimated Crewmember will remain un-acclimated until the 36 hour rest period has been received.

  16. Acclimatization • The FAA issued a letter of interpretation on 30-November-2012 • The revised final rule states that theater is the geographical area in which the distance between the FCM's departure and arrival point differ by no more that 60 degrees. • You could have a scenario where a pilot starts a series of FDPs and heads west 60 degrees, lays over, flies east to the point of origination, lays over and then continues going east 60 degrees. • In this case, the FCM is still within a theater that is technically 120 degrees wide.

  17. Acclimatization • Acclimatization effects: • Daily FDP Limitations • Daily Flight Time Limitations • Rest Requirements • Application of WOCL Rules • Application of Night Duty Rules

  18. WOCL Physiological night’s rest means 10 hours rest that encompasses the hours of 0100 and 0700 at the crewmember’s home base, unless the individual has acclimated to a different theater. If the crewmember has acclimated, the rest must encompass the hours of 0100 and 0700 at the acclimated location. Window of circadian low means a period of maximum sleepiness that occurs between 0200 and 0559 during a physiological night.

  19. Split Duty Period • Duty Break: • Is a span of time in which an individual is in a suitable accommodation (Hotel) for no less than 3:00 and not more than a required rest period. • A duty break must occur between 22:00 and 05:00 • A duty break is NOT considered a rest period. • A duty break is scheduled prior to the start of the FDP. • The actual duty break given must be no less than the scheduled duty break. • Split Duty: • Is a duty that contains a duty break. Check-In Time Duty Break Check-Out Time Ground Time Arrival Time Depart Time

  20. Split Duty Period • Split Duty: • The Total of the FDP’s Before and After the Duty Break – must not exceed the limits in Table B. Check-In Time Duty Break Check-Out Time Ground Time Arrival Time Depart Time FDP – Before Break FDP – After Break

  21. Split Duty Period • Split Duty: • The Total of the FDP’s Before and After the Duty Break – must not exceed the limits in Table B.

  22. Split Duty Period • Split Duty: • The Combined FDP and Duty Break may not exceed 14:00 Check-In Time Duty Break Check-Out Time Ground Time Arrival Time Depart Time Combined FDP’s and Duty Break FDP – Before Break FDP – After Break

  23. Night Duty • Night Flight Duty Period (NFDP): • Is a Flight Duty Period which infringes upon any portion of the WOCL. 6 2 4 5 3 1 WOCL • Consecutive NFDPs are those which occur during the WOCL on consecutive calendar days. • A duty break is a period in which a Flightcrew member is given a sleep opportunity in a suitable accommodation of at least 2 hours between 22:00 and 05:00. • Note: A sleep opportunity greater than or equal to 2 hours but less than 3 hours will not qualify a FCM to operate under Split duty limitations (FAR 117.15)

  24. Night Duty • Night Flight Duty Period (NFDP): • A flightcrew member is not allowed to be assigned to more than 3 consecutive NFDPs – unless the following conditions are met … 2 4 5 6 3 1 WOCL • All of the NFDPs must contain a duty break. • The Flightcrew member may be assigned a maximum of 5 consecutive NFDPs.

  25. Rest in a suitable accommodation Suitableaccommodation: Shall only be applied to ground facilities and not to aircraft onboard rest facilities. Example – Hotel Rest Period:Sleep opportunity: Measured from Release to Report. Measured from Hotel Check-in to Hotel Check-out. Check-In Sleep Opportunity Check-Out Report Release Rest Period

  26. Rest Requirements • Minimum Rest before a FDP or Reserve: • Rest Period of 10:00 and • Sleep opportunity of 8:00 • (117.25(e) refers) • Minimum Rest after a DHD that exceeds The FDP limit in table B: • Rest Period of max of DHD time or 10:00 • (117.25.(g) refers) • Required Rest in 168:00 all operations: • At least one rest period of 30:00 must be found in the previous 168:00 measured from the scheduled (expected) arrive time of an operating flight. • Required Rest at Base after a change in Theater for a series of FDP that exceed 168:00: • 3 Physiological night’s rest with a minimum rest period of 56 hours. A sleep opportunity must be able to guarantee 8 hours of un-interrupted rest (117.25(f) refers)

  27. Rest Requirements 1 2 3 4 5 6 7 8 9 Restperiod > = 30 30hr 168 hour lookback from end of each opnl leg - legal 168 hour lookback from end of each opnl leg - illegal Duty Period Rest Period FDP Application of 30 hour rest period in any 168 consecutive hours.

  28. Daily Flight Time Limitations • Un-Augmented Operations: • Limited to flight time limitations in Table A for that duty period. • The start time is relative to the Report time of that duty period. • Augmented Operations: • Limited to 13:00 scheduled flight time for that duty period for 3 pilot flight crew • Limited to 17:00 scheduled flight time for that duty period for 4 pilot flight crew TableA

  29. Daily Flight Time Limitations 117.11 Flight time limitation. No certificate holder may schedule and no flightcrew member may accept an assignment or continue an assigned flight duty period if the total flight time: Will exceed the limits specified in Table A of this part if the operation is conducted with the minimum required flightcrew. Will exceed 13 hours if the operation is conducted with a 3 pilot flightcrew. Will exceed 17 hours if the operation is conducted with a 4 pilot flightcrew. (Currently under 121 Regulations this is a scheduled flight time limit) Total scheduled flight time 8:40 4:20 4:20 Total flight time 9:01 (due to late arrival on leg 1) 4:41 4:20

  30. Daily FDP Limitations • Un-Augmented FDP: • Based upon • the Time of Report and • the number of (operational) flight segments • The scheduled FDP may not exceed the limits in Table B. • Non-Acclimated FDPs shall reduce the limits in Table B by 0:30 Table B

  31. Daily FDP Limitations • Augmented FDP: • Based upon: • the Time of Report and • the number of flight crew and • the type if in-flight rest facility on board, • The scheduled FDP may not exceed the limits in Table C. • Non-Acclimated FDPs shall reduce the limits in Table C by 0:30 Table C

  32. Daily FDP Limitations • Un-Augmented FDP: • May be extended up to 2:00 • Augmented FDP: • May be extended up to 2:00 • FDP extensions beyond 0:30 may not occur more than once in any 168:00 period unless an intervening rest period of 30 hours may be found. • FDP extensions beyond the Daily Scheduled Limitation in table B/C are further limited should the extension exceed the Cumulative FDP Limitations in FAR 117.23.(c).

  33. Daily FDP Limitations Application of FDP extensions greater than 0:30 in any 168 hour period

  34. Daily FDP Limitations FDP on day 8 is illegal if it is extended more than 0:30 beyond the scheduled FDP limit

  35. AccumulativeLimitations Today Day 7 Day 1 Day 2 Day 3 Day 4 Day 5 Day 6 Day 8 Day 9 Is a Lookback from point of evaluation Uses Actual values for previously performed activities. Scheduled values for activities to be completed

  36. AccumulativeLimitations • Flight Time Limitations: • May not exceed 100:00 in 672:00 • May not exceed 1000:00 in 365 Calendar Days (Base Time) • Two checks required for legs that cross midnight • FDP Limitations: • May not exceed 60:00 in 168:00 • May not exceed 190:00 in 672:00 • Extended FDP before takeoff may NOT cause a violation of • Cumulative FDP Limits(117.19 (a)(3) refers) Lookback is from arrival time of leg or Midnight. Lookback is from arrival time of leg.

  37. Reserves • Airport Standby (ASB): • Occurs when a crewmember reports for flight duty at a specific location to await assignment to a trip. • Is considered duty as well as flight duty period. • Is subject to flight duty limitations. • Is subject to rest requirements • Short Call Reserve (SC): • means a period of time in which a crewmember does not receive a required rest period following notification by the certificate holder to report for a flight duty period. • Is subject to flight duty limitations when assigned to a FDP. • Is subject to rest requirements • Long Call Reserve (LC): • Is NOT considered duty OR flight duty period. • Will require an intervening rest period prior to being assigned to a Reserve or FDP when a flightcrew member is notified by the certificate holder to report for duty.

  38. Reserve Limitations Report Arrive Time FDP Airport Reserve • FDP for Airport Reserve (ASB): • Is measured from Report of the Reserve to the later of Release from the Reserve or the last operating Flight in the 1st FDP. • FDP Limits: • Is from Table B, using the Report time of the Reserve and the number of flights, If the ASB is not assigned a trip the FDP shall be limited using 1 Flight.

  39. Reserve Limitations • FDP for Short Call Reserve (SC): • Is measured from start of the reserve to the later of release from the reserve the last operating Flight in the 1st FDP. Applied FDP Limit Arrive Time Start of SC Report of Trip FDP Short Call Reserve • FDP Limits Un-Augmented Operations: • Is the lesser of: • 16:00 • Table B + 4:00 using the start time of the reserve • Use the Start Time of the SC to find the FDP limit from Table B.

  40. Reserve Limitations • FDP for Short Call Reserve (SC): • Is measured from Report of the reserve to the later of Release from the reserve or the last operating Flight in the 1st FDP. Applied FDP Limit Start of SC Arrive Time Report of Trip FDP Short Call Reserve • FDP Limits Augmented Operations: • Is the lesser of: • Table C + 4:00 using the start time of the reserve • Table C using the report time of the trip • Use the Start Time of the SC to find the FDP limit from Table C.

  41. Reserve Limitations RAP – 14:00 Start of SC Arrive Time Report of Trip FDP Short Call Reserve • Reserve Availability Period(RAP): • Is 14:00 maximum • this is the time frame that an air carrier may contact, require a flightcrew member to report to a trip. Trips assigned outside the RAP require a minimum rest period of 10:00 with a minimum sleep opportunity of 8:00.

  42. Reserve Limitations WOCL Release from (Endof)LC ReportofTrip Long Call Reserve Rest Period • Required Rest period after Long Call Reserve (LC): • Is 10:00 if assigned to a Trip, SC reserve, ASB reserve. • Is 12:00 if the following Flight Duty Period Operates Into the WOCL.

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