As of today, the company s automated tracking of FAR legalities has several holes which have reduced the ability of the company and pilots to ensure FAR 117 compliance. Unfortunately, the company s inability to get their systems to a basic level of usability makes it imperative for pilots to track flight time, flight duty period, and rest using all tools available. By cross-checking the company s scheduling tools, you will reduce the chance of an FAR violation. Please be careful of non-official sources of information as we have had reports of bad advice (i.e. something that would get you violated) from CPO personnel. Only the company s and ALPA s subject matter experts should be trusted when your license is on the line. The ALPA FAR 117 team and Answer Hotline are in place to handle time-critical PDRs and the company s FAR 117 experts can be reached through the FODM. If you have any questions or problems with FAR 117 please file a report using the ALPA Pilot Data Reporting system. If you discover after the fact that you have violated the FAR 117 duty or rest limitations you must FILE AN FSAP to both protect yourself from certificate action and so we can capture the important data needed to correct the problems. ALPA cannot file the FSAP for you; you must file it yourself even if you submit a PDR. Cumulative Clocks - Cumulative Limits per FAR 117.23 FAR 117.23 (b) No certificate holder may schedule and no flightcrew member may accept an assignment if the flightcrew member s total flight time will
exceed the following: (1) 100 hours in any 672 consecutive hours or (2) 1,000 hours in any 365 consecutive calendar day period. (c) No certificate holder may schedule and no flightcrew member may accept an assignment if the flightcrew member s total Flight Duty Period will exceed: (1) 60 flight duty period hours in any 168 consecutive hours or (2) 190 flight duty period hours in any 672 consecutive hours. The company has automated the tracking of the cumulative flight hour and flight duty period clocks and updates these each day. The validity of this data is good for the scheduled operation but is has not been fully tested yet in the actual operation. These clocks started at zero on Dec 30 th for all United pilots, but now that we are into the sixth day of operation under the new rules, the cumulative clocks may start to trigger. You may access a report showing your cumulative flight time and flight duty period limits via this link: Flying Together Home>Departments>Flight Operations FAR 117 Summary Data. The reports are listed by category in a large PDF file (use the search function to find your file number.) From the company web page: These FAR 117 data files mirror CMS and allow a pilot to monitor compliance with FAR 117 'accumulation clocks' (both block and flight duty period (FDP) times). FAR 117 data files will be updated and posted each morning. Per FAA directive, FAR 117 accumulation clocks were reset to zero at the cutover time (12/30/31 0330Z). FAR 117 accumulation clocks began accumulating block and FDP time at 12/30/13 0331Z. The FAR 117 accumulation clocks on these reports are measured from the end of the pilot's next scheduled
duty period. If a pilot does not have a scheduled duty period in the next few days, the FAR 117 accumulation clocks on these reports are measured from the time the data report was executed. The specific time used is shown on the report. FAR 117 FDP accumulation clocks are also shown on these reports with the assumption that the scheduled duty period runs four hours late. If an FAR 117 FDP accumulation clock does not increase by four hours, this means that the pilot is "dropping off" FDP time at the start of the accumulation period (168 or 672 hours from the end of the accumulation period). If you have any question about the accuracy of this report contact the FODM, a sample is shown below: Changing Report Time and FAR 117.25 (e) Legality FAR 117.25 (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.
The FAR legality blind spot regarding changing report times continues to be a problem. Crews are cautioned that there is no automated backup at the crew desk for monitoring legality of changes that are done incorrectly. Unless given 10 hours notice of a new report time, pilots must be sure to use their original, scheduled report time when calculating the maximum flight duty period using FAR 117 Table B or C. Although the crew may physically report to the airport late due to a delayed departure, the FDP start time used for entering Table B/C can only change if given proper 10 hour notice. To properly reset a FDP report time there must be two-way confirmation at least 10 hours before the new report time. Without such notice, you will not have the FAR 117.25(e) required 10 hours free from duty immediately prior to beginning a FDP. Therefore, if the departure time of the first leg of the day is delayed but you are not given notice 10 hours prior to the new report time you must use the original report time when calculating your maximum FDP using Table B or C. Multiple PDRs have been received indicating the company has tried to change the scheduled FDP start time without proper notice. Although they can change the report time for the day, the FDP start time can only be changed with the proper notice described above. If you have a delayed report time, be sure to check your pairing using the actual tab in CCS Pairing Info and verify the correct FDP report time is shown. If the report time in the pairing does not match your originally scheduled FDP start time, or the properly reset (with 10 hours of notice) FDP start time, then the duty time shown on the pairing will be incorrect. Example 1: Legal to change report time: A crew blocking in on their last leg of the day at 2300, with a scheduled report time the next day of 1130, is sent an ACARS informing them that their outbound leg is delayed and will now depart 3 hours late. They are given a new report time of 1430 and acknowledge the ACARS. Because the crew had two-way communication of the change and it was more than 10 hours prior to the new report time this is a LEGAL report reset. When determining their FDP start time the next day they may use the new 1430 report time (adjusted for local base time change if needed).
Example 2: Illegal to change report time: A pilot discovers an expired Visa upon reporting for the original trip at 0900. A crew swap is made with a trip going to a different country which reports later that same day at 1200. Because the pilot s report time was not reset with 10 hours of notice, the original scheduled report time of 0900 must be used to determine FDP start time, not the report time of the new trip the pilot is flying. Example 3: Legal change to report time on layover: The inbound aircraft is delayed 2 hours and the crew desk calls the pilot on layover at 2230 to inform him of a new departure time of 1330 the next day. The pilot answers the phone (or returns the message) to complete two-way communication. Because proper notice was given more than 10 hours prior to the new report this is a LEGAL report reset. If the pilot did not establish two-way verification this would not be a legal reset.