FAA throws a wrench in FAR 117 interpretation.


Well-known member
APDL Beta Team
May 26, 2009
The following is from Alpa's March 2015 Magazine. What I find interesting is how they now determine time spent after block in, is part of the FDP. However, the article only references a reserve pilot. Is this an oversight, are regular line holders not included in this interpretation? And what if your airline stipulates 30 minutes instead of 15, post flight duties? It sounds like the FAA pulled a number out of thin air to tack onto the FDP for additional duties.

FAA Issues New Part
117 Interpretations
The FAA recently released
new Part 117 (flight and duty
limitations) interpretations.
The January 29 Fowler
interpretation clarifies that
a pilot who reports for a
deadhead-only assignment
may be legally reassigned
to flight duty without being
put back into rest. The pilot
must have received the 10
hours? preflight rest required
by 117.25(e). In that case,
the pilot?s flight duty period
will start at the time he or she
reported for the deadhead,
not at the time the pilot was
notified of the change to
flight duty or at the time the
flight segment actually starts.
The January 20 Wykoff-
ALPA interpretation clarifies
that an airline may not ?preapprove?
a flight duty period
(FDP) extension. The FAA
explained that the joint concurrence
required to extend
an FDP must take place when
the need for an extension is
The interpretation also
discusses how time spent
after block in, but before
release from all obligation
for further flying duty,
is treated under Part
117. The FAA
found that
time spent
by a pilot
waiting at an
airport for a
second flight
segment that
is eventually canceled counts
toward that pilot?s cumulative
FDP limits under FAR
Likewise, the FAA concluded
that 15 minutes spent by
a reserve pilot after blocking
in?but before performing a
required check with scheduling
before being released
from all responsibility for
further flying?counts toward
the cumulative FDP limits. The
FAA also concluded that time
spent by a pilot complying
with an airline?s policy to
stand by at an airport for up
to five hours after a canceled
flight for a possible further
flying assignment counts
toward the cumulative FDP
limits. The FAA also clarified
that requiring a pilot to check
a schedule after a deadhead
leg does not cause the
deadhead to count as part
of a prior FDP if no further
flying is assigned after the