Submission - Independent Pilots Association

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Amend (c)(1) to read:§ 117.19(c)(1)(amended) The final segment provides a minimum of 2consecutive hours available for in-flight rest for both flightcrew membersoccupying a control seat during landing. (This would require a minimum segmentlength of 6 hours for a 3 pilot crew and 3:45 for a 4 pilot crew to achieve therequired rest.)§ 117.19(c)(3) deleted§ 117.19(d)(modified) No certificate holder may assign and no flightcrewmember may accept an assignment involving more than three two flight segmentsunder this section unless the certificate holder has an approved fatigue riskmanagement system under §117.7§ 117.19(f)(1)(modified) The pilot in command and certificate holder mayextend a flight duty period beyond the scheduled flight duty period up to 3 2 hours.§ 117.19(f)(2)(modified) An extension in the scheduled flight duty periodexceeding 30 minutes may occur only once in any 168 consecutive hour period.**Any FDP that includes total flight time in excess of 12 hours shall requirea minimum of a Class 1 rest facility aboard the aircraft.38
*As an administrative matter, we have pointed out in our clarifyingquestions on the docket that Table C as published in the NPRM has anincorrect heading. The table heading needs to match Table B and the“Time of Start” should include home base or acclimated local time.117.21 Reserve StatusDue to overly complex language, we propose to rewrite section 117.21(c) as follows:(c)For short call reserve,(1) The maximum reserve duty period for un-augmented operations isdefined as:Table E—Short Call Reserve Duty PeriodTime ofStart ofRAP(Home BaseorAcclimatedLocal Time)Maximum Flight Reserve Duty Period (hours) Based on Numberof Flight Segments1 2 3 4 5 6 7+0000-0359 13 13 13 13 13 13 130400-0459 14 14 13 13 13 13 130500-0559 15 15 15 15 14 13.5 130600-0659 16 16 16 16 15 15 14.50700-1259 16 16 16 16 16 16 151300-1659 16 16 16 16 15.5 15 14.51700-2159 15 15 14 14 13.5 13 132200-2259 14.5 14.5 13.5 13.5 13 13 132300-2359 13.5 13.5 13 13 13 13 13(2) All time within the reserve availability period is duty.(3) The maximum reserve duty period (to include phone availability and/orflight duty period assignments) is determined by the earlier end point of(a) the start of the RAP time plus value in Table E or(b) the Flight Duty Period limitation in Table B as measured from theFDP time of start (home base or acclimated local time).39
Page 1: Submission of Comments on Flightcre
Page 4 and 5: BEFORE THEU.S. DEPARTMENT OF TRANSP
Page 7 and 8: their reporting for flight duty. Su
Page 9 and 10: The purpose of any FRMS is to ensur
Page 11 and 12: (1)(modified) The carrier’s entir
Page 13 and 14: II. We propose that Table A which s
Page 15 and 16: IPA Proposes:Flight Duty Period: Ex
Page 17 and 18: AcclimationIPA Proposes:I. Definiti
Page 19 and 20: II.Acclimated Local Time - means th
Page 21 and 22: Revised Table D—Flight Duty Perio
Page 23 and 24: mitigate fatigue. This is especiall
Page 25 and 26: Note: For example: If the RAP start
Page 27 and 28: 117.25 Rest PeriodIPA Proposes:I. N
Page 29 and 30: Table F - Number of Local Nights fo
Page 31 and 32: Consecutive Night Duty Period - mea
Page 33 and 34: 24-Hour LayoversWhile the IPA is su
Page 35 and 36: 117.7 Fatigue Risk Management Syste
Page 37: 117.19 Flight duty period: Augmente
Page 41 and 42: 117.25 Rest Period(c)(deleted) No c
Page 43 and 44: 117.27 Consecutive nighttime operat
Page 45 and 46: As currently proposed the regulatio
Page 47 and 48: 8) Is a 36-hour break from duty suf
Page 49 and 50: data available to certificate holde
Page 51 and 52: 17) Should some level of credit be
Page 53 and 54: is more difficult than nighttime sl
Page 55 and 56: 31) The FAA seeks input on the appr
Page 57 and 58: IPA’s Response to Questions Posed
Page 59 and 60: 9) The FAA seeks input on a circums
Page 61 and 62: BEFORE THEU.S. DEPARTMENT OF TRANSP
Page 63 and 64: sleep according to a desired clock
Page 65 and 66: Rationale: The term “nighttime fl
Page 67 and 68: We would recommend a process set up
Page 69 and 70: FRMS must be based on a partnership
Page 71 and 72: Table A—Maximum Flight Time (Bloc
Page 73 and 74: 117.19(c)(3) deleted.117.19(d)(modi
Page 75 and 76: Table E—Short Call Reserve Duty P
Page 77 and 78: departures. The pilot could then be
Page 79: No certificate holder may schedule

Submission - Independent Pilots Association

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