FAR Part 117 Essentials for AA Pilots

Transcription

1 FAR Part 117 Essentials for AA Pilots Introduction On January 4, 2014, new Flight Time and Duty Time regulations (FAR Part 117) will take effect. Without a doubt, these rules are far more complex than those to which we are accustomed. However, they represent a significant leap forward in terms of applying current fatigue science regarding physiology and circadian rhythms to Flight Time and Duty Time regulations. These new rules reflect the reality of 24-hour, global airline operations and the fact that a one size fits all approach is not appropriate for preventing pilot fatigue. Several guides to these new regulations have already been published and are readily available on the Internet. However, most of these guides contain extensive detail. The enclosed Essentials package is designed to give pilots a quick overview of the new regulations and how they apply in day-to-day operations. Beginning in January, most of the current APA contractual provisions related to flight time, duty time and rest will be replaced by FAR 117. Where contractual provisions still exist, the limitations contained in this document reflect the more restrictive of FAR 117 and the APA Collective Bargaining Agreement (CBA), as they apply to AA operations. Because some sequences and duty periods fly through from December into January and start before January 4 but continue until or past January 4, the FAA has approved a phased implementation during that period. Any sequence that starts in December will operate entirely under FAR Part 121. Any sequence that starts January 1 or later will operate under new FAR Part 117. Additionally, the FAA has ruled that all cumulative limitations under FAR Part 117 will start with no look-back their value will initially be zero. They will then be in effect going forward. Because of the complexity of this new regulation, we will publish this guide in five digestible installments. Additionally, it will be updated as necessary based on FAA clarifications and interpretations. Definitions for key terms are provided throughout and noted with a symbol. 117 Essentials Section 1 Initial Issue 1 11/21/13

2 Overview In general terms, FAR 117 represents the following changes: General Requirement for each pilot to declare fitness for duty before each leg. Elimination of separate "international" and "domestic" rules. The same set of rules applies to every pilot. Ø INT reserves will now have RAPS. Ø DOM flights can be operated with FBs. Ø No more twice the flying time off after international ops. Ø International rest is the same as domestic rest. Concept of the Window of Circadian Low (WOCL) is used to adjust some limits. Flight Duty WOCL: Home Base Time (HBT) New term Flight Duty Period (FDP), by definition, does not include debrief. New weekly and monthly cumulative FDP limits. Flight and FDP limits are based on sign-in time and Ø number of scheduled legs (2 pilots) or Ø quality of in-flight rest seat/bunk (3 or 4 pilots). Flight Time Flight limits are based on sign-in time and number of pilots. 2-pilot crews can fly for up to 8 or 9 hours, based on sign-in time. 3-pilot crews can fly for up to 13 hours. 4-pilot crews can fly for up to 17 hours. Flight time (as well as weekly and monthly FDP) limits are hard limits. Ø No more legal to start, legal to finish. No more 30- or 32-in-7 flight time limits (but monthly and annual limits are now based on rolling hours and calendars). Rest No more reduced/compensatory rest. All rest periods must be at least 10 hours and must include an 8-hour, uninterrupted sleep opportunity. The old 24 hours off in 7 days is upgraded to 30 hours off in 168 hours (7 days). No more rest based on duration of flight time. Late-Night and Early-Morning Operations New restrictions on multiple, consecutive WOCL operations. 117 Essentials Section 1 Initial Issue 2 11/21/13

3 Fit for Duty FAR defines fit for duty as being physiologically and mentally prepared and capable of performing assigned duties at the highest degree of safety. FAR 117 requires each pilot to affirmatively state his or her fitness for duty before each leg. If you are fit for duty: The procedure for declaring yourself fit for duty is similar to that for signing the Flight Plan. You may do so by any of the following: 1. CCI buttons: Ø PIC: Sign Flt Plan/Fit for Duty (one click for both actions) Ø FO/FB/FC: Confirm Fit for Duty (one click) 2. ACARS entry: Ø MISC 22 or Ø FTM 3. FOS Personal Mode entry: Ø HIFIT/flt#/date/city Load closeout is inhibited until all pilots have confirmed fitness for duty. NS - * on first leg of FDP/"F" on subsequent legs next to name indicates declaration of fitness for duty is complete. If you are not fit for duty: If at any point you feel you are not fit for duty, immediately contact Crew Scheduling or Tracking, as appropriate. Once a pilot states, I am fatigued, the company is obligated to remove the pilot. For more information on Fitness for Duty, refer to FAA AC Essentials Section 1 Initial Issue 3 11/21/13

4 Flight Duty Period Limits FAR 117 limits flight duty by: 1. Individual FDP limits 2. Cumulative FDP limits Flight Duty Period (FDP): A period that begins when a pilot is required to report for duty with the intention of conducting a flight or series of flights and ends when the aircraft is parked after the last flight with no intention for further aircraft movement by the same pilot. Note: As per the FAR definition, FDP does not include debrief. However, debrief is included in the AA/APA CBA definition of duty period. Also, debrief is not part of a rest period. FDP limits by individual FDP: At the core of the new Flight Time/Duty Time rules are two tables used to determine how long a pilot may be scheduled for an FDP. The table values may be exceeded in actual operations by a maximum of two hours (with certain restrictions, discussed in the Delays and Extensions section), but only with concurrence of dispatch and the PIC. Table B is used for 2-pilot crews. Table C is used for 3- and 4-pilot (augmented) crews. 117 Essentials Section 1 Initial Issue 4 11/21/13

5 FAR 117 Table B and Table C FDP Limits These tables are not only for planning purposes. Before any takeoff (including from a diversion airport), it must be verified that the flight can be completed within the FDP limit for each crew member (including any extension agreed to by the PIC). Table B: 2-Pilot Crews To determine the maximum FDP, enter the chart with the scheduled sign-in time, based on HBT. (If you are more than 60 longitude from home base, see Acclimation on the next page.) Find your maximum FDP listed under the number of scheduled flight legs. Flight Duty Period Limits: 2 Pilots* Number of Scheduled Legs in the Duty Period (not counting diversions or deadhead legs) Scheduled Sign-In Time *PIC may agree to extend up to 2 hours. Extension of >30 minutes permitted only once until a 30-hour rest period is received. NOTES: 1. If a pilot is assigned an FDP consisting of both augmented and un-augmented flying, the most restrictive rules apply. 2. The Company plans to apply buffers by scheduling to less than the table values to minimize operational disruptions. 117 Essentials Section 1 Initial Issue 5 11/21/13

6 Table C: 3- and 4-Pilot (Augmented) Crews Augmented crews are limited to 3 legs per FDP. (DH and diversions don t count as legs.) Augmented crews FDP limits are a function of sign-in time and quality of the in-flight crew rest facility. To determine maximum FDP, enter the chart with the scheduled sign-in time, based on HBT. (If you are more than 60 longitude from the previous FDP starting point, see Acclimation below.) Find your maximum FDP limit listed under the type of in-flight crew rest facility on your aircraft (e.g. Class 1 777, Class 2 B w/curtain, Class 3 B and 757 European configuration, w/o curtain). FDP Limits: More Than 2 Pilots* Class 1 Rest Facility Class 2 Rest Facility Class 3 Rest Facility Minimum Incline Flat Flat or Nearly Flat 40 w/leg Support Separation Wall Curtain None Light Control Pilot Controlled Darkness Via Curtain No Noise/Disturbance Isolation Yes Reasonable No Scheduled Sign-In Time 3 Pilots 4 Pilots 3 Pilots 4 Pilots 3 Pilots 4 Pilots *PIC may agree to extend up to 2 hours. Extension of >30 minutes permitted only once in a Duty Period. NOTES: 1. If a pilot is assigned an FDP consisting of both augmented and un-augmented flying, the most restrictive rules apply. 2. The Company plans to apply buffers by scheduling to less than the table values to minimize operational disruptions. 117 Essentials Section 1 Initial Issue 6 11/21/13

7 Acclimation: The following applies to both Table B & C FDPs. Theater: The geographic area where the difference between departure point and final arrival point of an FDP does not exceed 60 longitude. Acclimated: When you have either 1) remained in a theater for 72 hours or 2) been given at least 36 consecutive hours rest in a theater, then you are considered acclimated to that theater per FAR 117. When you have changed theaters and are commencing a subsequent FDP in that new theater: 1. If you are not acclimated to the new theater: Ø Enter Table B or C based on your HBT. Ø Reduce the limit values in Table B or C by 30 minutes. 2. If you are acclimated to a new theater: Ø enter Table B or C based on HBT or local time (still under discussion; see note below) and Ø use limit values as listed in Table B or C (no reduction). NOTE: The relationship between HBT and acclimation per # 2 above is still under discussion by the Company and APA. The exact application of this provision will be communicated to pilots when the issue is resolved. See definitions section for additional information on acclimation and theater. 117 Essentials Section 1 Initial Issue 7 11/21/13

8 FDP Limits by Cumulative Limits Cumulative FDP Limits Per rolling 168 hours (7 days) 60 hours Per rolling 672 hours (28 days) 190 hours Take-off is not permitted if you will exceed any of these limits. This table is NOT solely for planning purposes. Unlike the Table B & C-based FDP limits, the cumulative FDP limits can be extended only when unforeseen operational circumstances occur after takeoff. Before every takeoff (including from a diversion airport), it must be verified that the FDP can be completed within all of the above FDP limits (including any agreed-to Table B or C extensions). 117 Essentials Section 1 Initial Issue 8 11/21/13

9 Flight Time Limits FAR 117 limits flight time based on both sign-in time and the number of pilots. Flight Time Limits (Hours) Per FDP Time of Report (HBT or Acclimated) 2 Pilots 3 Pilots 4 Pilots * 17* *Max 3 Legs If Any Duty (Sign In to Debrief) Touches the WOCL ( HBT) CBA 15.5.a.2 8 Per rolling 672 hours (28 days) 100 hours Per rolling 365 days 1000 hours Take-off is not permitted if you will exceed any of these limits. This table is NOT solely for planning purposes. Before every takeoff (including from a diversion airport), it must be verified that the flight can be completed within all of the above flight time limits. The flight time limits within an individual FDP and/or the cumulative totals may not be exceeded. The only time the limits may be exceeded is when unforeseen circumstances occur while airborne on the last leg of an FDP. What this means: These are hard limits. No more legal to start, legal to finish. You are not allowed to take off on a leg where the scheduled flight time (including taxi-in time) will exceed any flight time limit, even if just by a minute. A 2-pilot crew that is legally scheduled for three 3-hour legs (9 hours flight time) but overflies on the 1 st and 2 nd legs (6:01 total flight time) may not depart on the 3 rd 3-hour leg. NOTE: If a pilot is assigned an FDP consisting of both augmented and un-augmented flying, the most restrictive rules apply. 117 Essentials Section 1 Initial Issue 9 11/21/13