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Some new FAA interpretations


APDL Beta Team
Sep 3, 2013
The FAA recently released a new Part 117 (flight and duty limitations) interpretation. The January 20, 2015, Wykoff-ALPA interpretation clarifies that a carrier may not "preapprove" an FDP extension. The FAA explained that the joint concurrence required to extend an FDP must take place when the need for an extension is known. The interpretation also discusses how time spent after block in, but prior to 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 117.23(c). Likewise, the FAA concluded that 15 minutes spent by a reserve pilot after blocking in?but a prior to 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 a carrier'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. Finally, the FAA 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 deadhead.
If you have any questions about Part 117 interpretations, please contact ALPA's Legal Department at Legal@alpa.org or 703-689-4326.