FDP Manipulation

raysalmon

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When we are on reserve and we are given a trip to fly, my company routinely extends our FDP beyond the end of the last leg up to the legal maximum for the day. For example I duty on at 0418, and fly 3 legs, blocking in on the last leg at 1257. The maximum FDP for that day would require me to be off at 1418, so the company extends my FDP from the normal end at 1257 to 1418 in case they want to use me up to 1418.

APDL does not seem to allow me to extend the FDP like this. Without the ability to do that, my cumulative FDP calculations will be off. Is there a way to do this that I am missing?
 

minearsm

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Inside the trip on the day in question,
tap the DUTY line,
verify the lock is unlocked in the upper left, select the lock to unlock it if need be,
you can then adjust the "duty off" appropriately.
 

raysalmon

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Changing the duty off time doesn't seem to change the cumulative FDP time showing on the legality page though?
 

AJNegron

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Your company may keep you on duty until 1418, but if the your last flight blocks in at 1257, that is the end of the FDP. That is clearly defined in 117.3 Definitions.
 

raysalmon

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Well in the Anderson interpretation, the FAA clearly states the certificate holder can keep you on duty "with the FDP clock running" after you block in, in case they have more flying for you to do. So my question is how to keep the FDP clock running in APDL past the end of the last segment.
 
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Andy Adams

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I don't read that anywhere in the Anderson interpretation. It seems to me to be referring to an FDP extension for additional flying. Not "just in case" additional flying happens to come up later.
 

raysalmon

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In a recently-issued interpretation, the FAA stated that the termination of an PDP requires "an affirmative intent for no further aircraft movement. The FAA elaborated that:

This affirmative intent is lacking when the certificate holder is unsure whether there will be another flight or further aircraft movement. As a result, if the certificate holder intends or may intend to use the flightcrew member for another flight or further aicrcraft movement, the certificate holder may do so by holding the pilot on duty with the FDP clock running, making necessary adjustments based on any assignments to ensure that the pertinent FDP limits are not violated.'

The words "unsure" and "may intend" certainly sound very similar to your "just in case"
 

Andy Adams

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raysalmon

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It's also in an interpretation written to Don Wykoff on March 20, 2014. The Anderson interpretation is actually partially a quote of the Wykoff one.
 
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AJNegron

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Raysalmon, can you provide the actual FDP values your company is using in your lookback? Mods, can we move this to Peer Discussion?
 
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raysalmon

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I would be happy to, but I am not sure I understand exactly what you're looking for. The company adds a fake DH segment after the last flight that they call FDP to push the FDP out further. It looks like they push it out to whatever the current max is from Table B. Having said that, it is also common for a pilot to be able to call and get released from the FDP (much like getting released from reserve), part the way through that "FDP" segment when it appears that he/she will not be used.

It would be helpful to be able to adjust the ending FDP time like you can adjust the duty time, by plugging in a different time than what it defaults to.
 

AJNegron

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Well, as you know, a tail-end DH (fake or real) does not count towards FDP. So in essence they are manipulating your duty day, not your FDP. A company may keep you on duty (with your FDP clock running) after your last segment, insisting that they do not have an affirmative end of scheduled flying assignments for you. But when you are finally released from duty, and your last flight segment was xx hours ago, that last block in officially ends the FDP. Company duty ends (and rest begins) at release time. None of the interpretations change this. Some one please correct me if I am wrong in this understanding.

In order for us to help you, either in the understanding of APDL or in 117, what we need to look at is if your company really is using the max FDP every day.
How does your company provide you with a FDP lookback?
What is your current 60/168 and 190/672 lookback?
 

Kwest

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My airline does something similar. I usually just extend the duty time to match. The FDP only becomes an issue if they assign flying.

Edit for spelling
 
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raysalmon

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On 11/30 I dutied on at 0418, flew 2 segments and blocked in at 1257 after the second segment. My FDP was then extended to 1418. My cumulative time report from Crew Trac shows an FDP of 10 hours for the day, reflecting the inclusion of the extension in calculating cumulative limits even though no additional flying was actually assigned.
 
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rmcgrath

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Ray,
Just to throw my two cents in, as I understand the regs, your FDP ends with the block in of your last flight segment. Any duty time after that is not FDP and is not rest, just duty time. If another flight assignment (or any aircraft movement) takes place, then the period in between becomes FDP again until the end of movement of the added assignment. If that is wrong or I misunderstand, someone please correct me but that is the way I learned it.
Rob
 

Andy Adams

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Posts 14 and 17 make the most sense to me. If they are correct, which I suspect they are, and you do as Kwest has done in post 15 where you just extend your duty time to match, APDL will be accurately representing all of your legality and lookback at the end of the day.

If the above comments are wrong and your company is in fact able to count the entire period as FDP, and you do as described in post 15 where you extend your duty to match, everything will be tracked correctly in APDL EXCEPT the FDP lookback values. Rest is not affected by duty vs FDP so the beginning of rest will be the same either way. Additionally, if your company is able to consider the entire thing FDP then I would expect they are probably causing themselves problems by running into more cumulative FDP lookback limit issues than necessary.

The development team's understanding of the definition of FDP is as described above in posts 4 and 14. As a result, it is not currently possible to modify the FDP manually beyond the end of your last flying segment. Before moving forward with anything on this topic, I would be interested to see if you can find out something official from your company on exactly what they are considering this extension period, after you are released, "FDP" or "Duty", in the event that you DO NOT fly another leg.
 
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raysalmon

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Hi Andy,

I'm not sure what you would consider to be official, but I know for a fact they consider it "FDP". That is what they call it in Crew Trac. The flight number on the phantom segment is listed as "FDP" That is the term they use on the phone. That is the way we were taught in ground school. They even referred to the interpretation I linked to above during ground school. The extension period is also included in the cumulative time report in Crew Trac as FDP and it increases the cumulative FDP times. This all occurs when there is no additional flying. I would copy and paste an example Crew Trac entry in here but the formatting gets all messed up. Any idea how I could post that?

When I read the interpretation I quoted from and linked to above, I cannot see at all how the FDP end time snaps back to last block-in retroactively if there is no additional flying. It really reads like the FDP ends when the company says "ok, no more airplane moving for you today." Until that time the FDP clock runs. Once the company says "no more airplane moving" the FDP clock stops right there. That interpretation does not conflict at all with the original definition. It may conflict with what we all thought it meant to begin with, before the interpretations, but that's another story.

In the end, my company is acting more conservatively by counting it as FDP, so in the end they will tell me I am illegal when I may be legal per APDL. I would much rather that scenario than for them to tell me I am legal and APDL is saying I am not. Yes, they may run into more time-out issues, but if they don't keep me on FDP, then I am useless to them until I get 10 hours of rest. They would rather keep me available on an extended FDP and potentially run into time-out issues than release me and need me later that day. It's all about putting out today's fires. Tomorrow's fires don't matter until tomorrow. That's the mentality.



 
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rmcgrath

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That works out well for you and, like you said, only makes their FDP numbers more conservative. The way we were taught 117, even a deadhead at the end of a day is not considered FDP. A deadhead is considered FDP if there is another aircraft movement assignment after it. I don't see how they can say that extending your duty time is extending your FDP but as long as your APDL is accurate and their numbers are more conservative you'll be safe, legally. The only problem you might run into is if you try to pick up extra flying (legal by actual FARs) and they say you aren't legal to do it.
 
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