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Delta Mec: Quick Reference Guide FAR 117
Delta Mec: Quick Reference Guide FAR 117
March 2018
ALPA Scheduling Committee Contact Information
Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Our current PWA incorporates the most recent Part 117 FAA regulations
with added buffers to ensure scheduled times and company-mandated
duty times past block-in are protected. Generally speaking, the Delta
PWA scheduled duty times are :30 less than the FAA FDP times.
Duty time, rest time, and flight time must all be considered when deter-
mining legality for each duty period and flight leg.
FAR rest does not begin until company duties are completed. While an FDP
ends at block-in, rest does not begin until 30 minutes after block-in.
“Legal to start, legal to finish” has been eliminated. At takeoff, you must
be able to complete your flight (ETE plus taxi-in time, as stated on the
flight plan) within the prescribed flight duty period (plus any legal exten-
sion) and flight-time limits, or you cannot depart.
Duty Time
PWA Duty: PWA duty period limit (with the exception of FRMS) is the
same as the FDP table, with the exception that the maximum scheduled FDP
is 30 minutes less than the table value. This number is the maximum sched-
uled PWA duty day. You cannot be scheduled in excess of this PWA duty
limit.
The allowable length of the PWA duty period depends on a variety of fac-
tors, including the report time of the rotation, type of flying, and augmenta-
tion, among others, and is contained in Section 12 D. of the PWA.
FAR 117 Duty: A flight duty period (FDP) is from report to block-in* of the
last flight segment (not DH segment), with no further expectation to fly.
Duty required by the Company that is not part of an FDP (training, dead-
heading, etc.) is not restricted by FAR 117 (but is restricted by the PWA
Section 12 D. 4. for DH, and Section 11 F. for training); however, any duty
required by the Company is not considered rest.
* “Block-in” means “last intent to move an aircraft.”
Short-Call Reserves: The FDP limit for short-call reserves is somewhat non-
intuitive. The FDP limit is based on the report time of the rotation assigned
(as derived from Table B or C). The period of time between the start of
the short-call period and the report time of an assigned FDP is called the
reserve availability period (RAP).
The total RAP plus FDP duty limit for a short-call reserve is the FDP limit
(based on the report time of the rotation) plus up to four hours of RAP to
the FDP limit in “Table B” or “Table C.” This time limit is measured from
the start time of the short-call period. Duty does not start until sign-in. In
unaugmented operations, max RAP + FDP is 16 hours.
Note: A recent FAR 117 interpretation by the FAA of FAR 117.5(a) which
requires a flightcrew member to “report for any flight duty period rested
and prepared to perform his or her assigned duties” applies only to duties
that are assigned (a flight duty period), not duties that could be assigned (such
as an FDP extension). Thus a flightcrew member’s fitness-for-duty determination
(including pre-FDP rest) is based on the assumption the FDP will not be extended
and/or operated as assigned.
Limit: You cannot extend an FAR FDP more than 30 minutes if you have
already extended a FDP more than 30 minutes, unless you have had a
prospective 30-hour rest period between the two extensions. If the last leg
of the duty period is a deadhead, it is not an FDP extension.
Tip: You may rescind the decision to extend your FDP at any time, even
just after signing the FDRA.
Note: Pre-takeoff FDP extensions cannot cause the exceedance of any cu-
mulative limits (such as 60 hours cumulative FDPs in a rolling 168-hour
period).
Deadheads
Deadhead-only periods
The FAA does not consider a “deadhead only” day to be a FDP. The PWA
does consider a deadhead-only day to be a duty period (Section 12 D. 4.)
and is subject to some limitation.
If you are deadheading after flying (or as a DH-only event) and exceed the
Table B FDP limit, the post deadhead rest period must be no less than 10
hours or the spent time in deadhead transportation.
Rest Periods
PWA Rest: The time between duty periods under the PWA is called
“break in duty,” and is measured from release to report. This means 30
minutes after block-in to report in for the next duty period.
FAR 117 Rest: This is the same as the PWA, but it’s not worded the same
way. The FAA considers block-in on the last leg as the end of the FDP, but
rest does not start until you are “released from duty,” including the comple-
tion of any deadhead legs.
PWA “break in duty” and FAR rest does not begin until 30 minutes after
block-in.
Read this!: With the minimum FAR required “rest” of 10 hours prior to
report for an FDP, these PWA break-in-duty limits less than 10 hours
are legal only prior to “deadhead only” duty periods. If you have less
than 10 hours of rest preceding a DH-only day, you cannot be rerouted
into flying until you have received 10 hours of rest.
You cannot be rerouted (i.e., rescheduled) to less than the minimum PWA
scheduled break in duty (rest).
With FAR 117, the minimum rest period before any FDP is 10 hours.
Period. This time cannot be reduced or waived. It is inviolate.
Note: Reserve pilots with availability remaining transition back into long-
call status at their release time. There is no requirement for “rest after
release” unless a 56-hour rest is triggered (see rest summary on next page)
or a deadhead that exceeds the Table B limit. Rest is only required prior
to the next FDP.
As “deadhead only” periods are not considered an FDP under the FARs, the 10-
hour minimum rest does not apply, but the PWA requirements do.
Due to delays, the actual minimum break in duty can be 8:15 for sur-
rounding duty periods of 20 hours or less and nine hours for surrounding
duty periods greater than 20 hours.
Prior to a transoceanic duty period (in base or away from base), the PWA
requires :
• 13-hour scheduled break in duty following duty periods of 13 hours
or less
◊ Reducible after delays to 11 hours, or
◊ Eight hours after a non-ocean crossing DH duty period.
Following a transoceanic duty period away from base, the PWA requires:
• 13-hour scheduled break in duty for duty periods of 13 hours or less
◊ Reducible after delays to 11 hours, and
• 18-hour scheduled break in duty for duty periods of more than 13
hours
◊ Reducible after delays to 14 hours
Further, if the required rest is interrupted for any reason, that rest period
must be reset. Noise, climate, and phone calls are examples of factors that
may be considered. The pilot is the sole authority over whether or not the
rest was interrupted.
For transoceanic flights, the PWA limits flight time to eight hours sched-
uled with a two-pilot complement, 12 hours scheduled with a three-pilot
complement, and no restriction with a full relief crew.
FAR 117 Flight Time: The FARs limit unaugmented flight time during a
FDP to eight or nine hours, depending on the time of report. Augmented
flights have a limitation of 13 hours for a three-pilot complement, and 17
hours for FDPs with a relief crew. There are no block limits for FRMS flights.
Note: “Legal to start/legal to finish” no longer applies for either duty time
or flight time. Prior to takeoff, you must ensure you can complete the
flight segment within both the FDP and the flight-time FAR limitations.
If you have a smartphone or tablet with either the Android or iOS operat-
ing system, there are a few apps that you can download to assist with this
task. ALPA has an app that works on both platforms; search for “ALPA
FAR 117” in your app store.
If you have a favorite 117 tracking application, let us know and we’ll be
happy to include it in our next revision.
If the extension is known and required when the FDRA is signed, this sig-
nifies that each pilot has accepted the extension for that flight segment. If
the extension becomes required after pushback, FAR 117 requires the PIC
to notify the certificate holder if the extension is acceptable. Good CRM
dictates the PIC speak with all crewmembers before responding to the
Company. Extensions of the FAR 117 FDP, by any amount, always requires
concurrence of each pilot. If the decision is made to extend, it is up to each
pilot how much to extend, and this may rescinded or modified at any time.
Crew Tracking, with pilot concurrence, may reduce the subsequent duty
period’s report time by up to 30 minutes to ensure FAR required rest is
achieved.
To meet a FAR legality issue, Dispatch can also adjust the flight plan to meet
either an FDP limit or flight-time limit, with the concurrence of the PIC.
The PIC must concur that any such adjustments are reasonable and
prudent, given the conditions that exist, or are expected to exist. Such
changes must have some basis in reality (no Mach 2.0 cruise speeds or
7,000 foot cruise altitudes).
Any FAR legality issues must be resolved prior to takeoff. Any LATT
and Block concerns must be resolved prior to takeoff.
Fatigue is a “current event.” If you are at the gate, and cannot continue
because you are physically exhausted, for example, that would be a case
of fatigue.
On the other hand, if you are OK right this minute to depart, but due to
anticipated conditions at the departure, en route, or destination and/or
length of the duration of the flight you feel that you may be fatigued at
some time in the future, then that is a “fitness for duty” consideration. If
you feel that this is the case, you still cannot depart, as FAR 117 provides
for a “fitness for duty” check prior to any departure. Both fitness for duty
and fatigue have the same PWA application and implications.
The FAA has determined that fitness for duty determination is specific
to the assigned duties. For example, a pilot may determine he is rested and
fit to fly DTW-MSN, but not fit to fly DTW-SEA. The FAA has also deter-
mined that a pilot’s obligation is to be rested and fit for the assigned duties,
not necessarily for those duties which may be assigned (reroute, change
in crew complement, etc.). Delta policy, however, states that pilots report
rested for the entire possible FDP per table B or C (no extensions), a situa-
tion that may not be possible under all circumstances.
“Not fit to continue” is not the same as a fatigue call. You are not required
to say you are fatigued to refuse an FDP extension, only that you are “not
fit to continue.”
Sample Statement
“After evaluating the conditions and circumstances of the flight segment, out of an
abundance of caution, I cannot certify my fitness for duty for the extended flight
duty period, and therefore decline to concur with the FDP extension:”
If you are in a position where Crew Tracking insists that you speak to
another party (besides the OCC duty pilot or Crew Accommodations) or
insists that you declare you are fatigued, simply inform them that you
are not required to do so, that you are not fit to continue, and you’ll be
happy to discuss any required clarification with your base chief pilot after
your designated FAR rest period. Note that your FAR rest period does not
begin until your company tasks (including any interaction with Crew Tracking)
are concluded.
Each month, the FRB will meet to review each report. The FRB is com-
posed of two ALPA and two Company representatives. It is important to
note that the pay treatment defaults to “paid” unless the FRB determines the
situation differently.
Domestic Pilots
A pilot who is acclimated to his or her base when reporting for a rotation
and does not change theaters during the rotation will remain acclimated
and continue to use the local time at his or her base to determine his or her
limits throughout the rotation. A domestic category pilot is not likely to
change theaters because none of the 48 contiguous states are separated by
more than 60 degrees of longitude.
The short version is, for most cases, domestic pilots use their base re-
port time to compute FDP and block limits.
International Pilots
• A pilot beginning a new series of FDPs who is not acclimated to a the-
ater encompassing that FDP starting point should use the local time
at the location where he or she most recently began a series of FDPs
while acclimated to a theater encompassing the FDP starting point of
that series.
For example: If you are based in ATL and fly to CDG, but do not accli-
mate, you still use ATL time to compute limits. You’ll need to convert the
CDG report time to ATL time.
• A pilot continuing a series of FDPs should use the local time at the lo-
cation where he or she most recently began a series of FDPs while accli-
mated to a theater encompassing the FDP starting point of that series.
For example: If you are based in ATL, and fly to CDG, but do acclimate,
you would then use the CDG time zone, as that is the place where accli-
mation occurred.
Remember: DH segments prior to a flying leg count toward the FDP, but
not as a flight segment for FAR purposes. They do count for PWA purpos-
es. DH after the last flying leg does not count for FDP or segments, either
for the FARs or PWA. This does not include DH-only duty. That has its
own rules (see Deadheads). Deadhead-only duty periods are not FDPs
under the FARs, but they are duty, and they cannot be considered rest.
When there is a change of your rotation report time within 10 hours of the
originally scheduled report, an “Airport Report Time” will be displayed
on your rotation below “Pay/Actual Report Time” as noted above.
This will require some mental math on your part. In essence, your origi-
nal “Actual Report Time” represents the beginning of a pseudo-RAP and
the “Airport Report Time” represents the report time for the rescheduled
FDP.
To figure out your new FDP limit (the lesser value is most restrictive):
• Convert your “Airport Report Time” to your last acclimated city, and
enter table B or C with the number of flight segments.
• Your FDP must end at the new report time (“Airport Report Time”)
plus the FDP (from table B or C)
• And determine:
Unaugmented: The original report time (IE “Actual Report Time”) Ta-
ble B value + four hours (not to exceed 16 hours)
Augmented: The original report time (IE “Actual Report Time) Table
C value + four hours.
Exception: If the FDP intrudes into the pilot’s window of circadian low,
the company must provide 12 hours’ notice, not 10, to use “long call”
rules.
Note: The company is free to disregard the above, and keep the report at
the original scheduled time. All flying must be done within the original
FDP limit. Reference FAR 117.21.d.
Diversions
Segments flown due to a diversion do not count as an “extra” segment,
nor do they cause a recalculation of the FDP if you continue to the original
destination. You must, however, still finish within the original FDP limits,
with any extensions applied, provided that each crewmember determines
they are fit to extend.
Additional Legs
The FDP must be recalculated using the original report time and the new
total number of legs during the FDP.
Deleted Legs
The FDP must be recalculated using the original report time and the new
number of legs.
Deadheads
You cannot be rerouted into a flying leg during a deadhead-only duty pe-
riod. If you have had 10 hours of rest prior to report, you can be rerouted
to fly as long as you are contacted no later than report. After report you
may not be rerouted to fly. Once the flight departs, you cannot be rerouted
to fly.
You cannot be rerouted into a flying leg from a DH leg after the block-in
of the last flying leg, unless you were notified prior to your FDP ending.
You can be rerouted into a flying leg from a DH leg if the DH leg is prior to
a scheduled flying leg. Any change in the number of flying legs requires
recalculation of the FDP limits.
Unscheduled Augmentation
The FDP limits cannot be changed after report time by augmenting the
crew.
Because of this, we need to know when is the latest time we can depart
and still remain within these two limits. That time is known as the latest
allowable takeoff time, or LATT.
There are two different kinds of LATT, one for duty time, and another
for flight (block) time. After block out, the earliest LATT controls!
FDP LATT
To compute your LATT to remain within your FDP, there are four num-
bers you need to know: Your report time, your allowable flight duty peri-
od, your estimated time en route, and your taxi-in time.
The ETE and taxi-in time can be found on the release for your flight. These
are the only times that can be used for LATT calculations. If they change, a
new flight plan is required.
From this LATT, you can apply any legal extensions, as determined by
your individual situation.
The first line indicates the LATT with the basic FDP limit applied. The sec-
ond line indicates the LATT with the maximum legal extension (up to two
hours) applied, which requires pilot concurrence. Depending on fitness,
the pilot may choose to reduce the extension applied, or not concur with
any extension at all.
Example: Out at 1500z + 9:00 fight-time limit – 4:00 hours already flown –
3:30 ETE – 0:05 taxi-in = flight-time LATT of 16:25z
ACARS Notification
If it is determined that any required crewmember has a computed LATT,
flight time (block), or max extended flight duty period (FDP) within 30
minutes of the current time, an ACARS message will be automatically
sent to the aircraft providing the LATT time and the employee number of
the affected crewmember.
The message will include the employee number, date, LATT (in zulu) and
if the LATT is an FDP or block limit. FDP limits will note if any extension
is applied.
If not assigned any of the above, the pilot transitions back to long-call status
at their release time. There is no automatic “rest after release” unless some
compensatory rest is required.
Long-Call Reserve
Coming off a non-fly day other than vacation (X-Day, etc.):
The requirement to perform a schedule check coming off a non-fly day
has been eliminated. The earliest report that can be assigned is 1000 (as-
suming on-call day began at 0000 + 10 hours mandatory prerotation rest),
provided the assignment is made nine hours prior to the end of the last
non-fly day.
Trip Assignments
Long-call trip assignment notification is 12 hours to report. There is no
longer a requirement to acknowledge any long-call reserve assignments.
You are expected to notify Crew Scheduling if you cannot report or are
unfit for duty at least three hours prior to report.
(Both of these limits are extendable by up to two hours with PIC concur-
rence)
• PWA scheduled duty day limits, which begin at FDP report time
Scheduled Block/FAR
Max Block
B
C
D
E
F
Important Numbers:
A: This is your scheduled and actual report time (check-in time for first
day). These numbers may be different due to rest requirements.
B: Layover city, scheduled rest, hotel and total block
C: PWA data for “A” pilot. Top line represents scheduled FDP (12:09),
max scheduled PWA FDP (13:30), and max extended FDP (16:00).
D: FAR data for “A” pilot. Bottom line represents the max FAR unex-
tended FDP (14:00), max FAR extended FDP (16:00) and max block time
(9:00). This line also shows last acclimated city and rest facility class on
which the FDP is based.
E: PWA and FAR FDP data for “B” pilot.
Note: Crewmember limits may be different, and might not be able to
extend the full two hours, depending on their own circumstances.
F: Report time for subsequent day. Pay and actual report times may be
different due to rest circumstances. “Actual Report” represents actual
report time. “Airport Report Time” appears if you were rescheduled
within 10 hours of report (See Rescheduling, Reroutes, and Changes to
Report Times). If these values have been changed by Crew Scheduling,
they will be prefaced by “New.”
Cumulative Limits:
Flight Time
- 100 hours in rolling 672 hours (~28 days)
- 1,000 hours in rolling 365 calendar days
Flight Time:
• No more than eight hours flight time (PWA restriction)
• Limited to two segments (PWA restriction)
• FAR 117 flight-time limits (from Table A):
◊ 0000–0459 and 2000–2359 acclimated report time, eight hours
max flight time
◊ 0500–1959 acclimated report time, nine hours max flight time
FDP Limits
REPORT TIME 1–2 LEGS
00:00–03:59 9
04:00–04:59 10
05:00–05:59 12
06:00–06:59 13
07:00–11:59 14
12:00–12:59 13
13:00–16:59 12
17:00–20:59 12
21:00–21:59 12
22:00–22:59 11
23:00–23:59 10
FDPs are report in to block-in.
PWA scheduled maximum duty is 30 minutes less.
Rest
Before any FDP or short-call RAP:
• 10 hours’ rest, including eight-hour uninterrupted sleep opportunity,
prior to beginning any rotation or short-call period. (not required pri-
or to rotation assigned during a short-call period). Cannot be reduced!
• 30 hours’ rest in the past 168 rolling hours (~7 days)
• DH after flight is not part of the FDP, but is part of the PWA duty pe-
riod and is not rest
• DH before flight is part of the FDP
• DH only is not a FDP, but determines acclimation status
• After DH that exceeds Table B Flight Duty Period: Rest = DH length or
10 hours (greater)
• Rest is free of duty, and begins at release (30 minutes after block-in),
except for reserves who transition to long call.
Cumulative Limits:
Flight Time
- 100 hours in rolling 672 hours (~28 days)
- 1,000 hours in rolling 365 calendar days
Flight Time:
• No more than 12 hours scheduled per duty period (PWA restriction)
• Limited to two segments (PWA restriction)
• FAR 117 limit of 13 hours per duty period
Changing Augmentation
• An FDP cannot be extended by modifying the augmentation (e.g., add-
ing a third pilot to a delayed flight).
• An FDP can be reduced if the augmentation is changed (e.g., third pilot
calls in sick with no reserve available, and trip is legal for two-pilot ops).
• An FDP can be modified or recalculated if the rest facility is changed
(e.g., a MEL is fixed, taking the rest facility from a Class 3 to a Class 2).
• If an FDP is modified due to changing the augmentation, a pilot is ex-
pected to be able to fly a legal segment but, as always, changing condi-
tions and circumstances warrant a self-evaluation on fitness to fly.
Cumulative Limits:
Flight Time Flight Duty Period Hours
100 hours in rolling 672 hours 60 FDP hours in rolling 168 hours 1,000
hours in rolling 365 calendar days 190 FDP hours in rolling 672 hours
168 hours = ~7 days, 672 hours = ~ 28 days
Flight Time:
No more than 17 hours in an FDP (FAR 117 limit)
Changing Augmentation
• An FDP cannot be extended by modifying the augmentation (e.g., add-
ing a third pilot to a delayed flight).
• An FDP can be reduced if the augmentation is changed (e.g., third pilot
calls in sick with no reserve available, and trip is legal for two-pilot ops).
• An FDP can be modified or recalculated if the rest facility is changed
(e.g., an MEL is fixed, taking the rest facility from a Class 3 to a Class 2).
• If an FDP is modified due to changing the augmentation, a pilot is ex-
pected to be able to fly a legal segment, but as always, changing condi-
tions and circumstances warrant a self-evaluation on fitness to fly.
Cumulative Limits:
Flight Time Flight Duty Period Hours
100 hours in rolling 672 hours 60 FDP hours in rolling 168 hours
1,000 hours in rolling 365 calendar days 190 FDP hours in rolling 672 hours
168 hours = ~7 days, 672 hours = ~ 28 days
March 2018 Delta MEC Quick Reference Guide FAR 117 • 33
FAR Part 117 Augmented (Four-Pilot Crew) FRMS
Certain B-777/350 flights operate under FRMS rules, with four-pilot
crew complement (see bid package).
Pre-Rotation Rest
Further, pilots operating under FRMS must have pre-rotation rest as
follows:
PLANNED/MINIMUM
FRMS OPERATION PRE DUTY RES*
ATL-JNB 24/18 hours
JNB-ATL 48/40 hours
0700–1659L from U.S. 24/13 hours
1700–0659L from U.S. 24/20 hours
Anytime to the U.S.
24/20 hours
(except from JNB)
*Note: Planned rest must be prospectively scheduled. Reduced rest
cannot be scheduled, even for reserves. Minimum rest only applies be-
tween two previously scheduled trips that experience delays.