Submission - Independent Pilots Association

(4) If all or a portion of a reserve flightcrew member’s reserve availabilityperiod falls between 0000 and 0600, the air carrier may increase themaximum reserve duty period in table E by one-half of the length of the timeduring the reserve availability period of 0000-0600 in which the air carrierdid not contact the flightcrew member, not to exceed 3 hours; however, themaximum reserve duty period may not exceed 16 hours. If the flightcrewmember is contacted for an assignment prior to 0000 hours the reserveduty period would not be extended.Note: For example, RAP starts at 2200 hours, pilot called at 0300 for flightassignment, the RAP may be extended by 1.5 hours. If the pilot was called prior to0000 hours there would be no extension.Rationale: The short call reserve section is complex and we are concerned that there willbe misunderstanding by flight crewmembers, schedulers and management officials with thesection as written. Consistent with other limitations in the proposal, we believe a chart is a betterway to set forth the short call reserve limits expressed in the proposal. We urge that the chartthat sets forth the short call reserve limits be adopted. In both the ARC and the NPRM preamble,the intent was expressed that RAP extension credit is to be made available for not contactingreserves between 0000 and 0600 whose RAP’s touch that time period. However, the proposedlanguage in 117.21(c)(4) (iv) and 117.21(c)(5)(iii) neglects this distinction, providing credit forany period of non-contact. This error in the language has been corrected in our revised languagein (4) above.(5) No certificate holder may schedule and no reserve flightcrew member onshort call reserve may accept an assignment of a flight duty period that beginsbefore the flightcrew member’s next reserve availability period unless theflightcrew member is given at least 14 hours rest. This provision may be usedonly once in a rolling 168 hour period.Rationale: The need for this provision is best illustrated by real world examples. A pilot isscheduled and adjusts his rest schedule for a series of RAPs beginning at 0400. If the operatorcontacts the pilot at 0600 (after the morning bank of departures) and releases the pilot for a 14hour rest period, the pilot could then begin a RAP at 2000 to cover the late evening bank of76