As you are aware, American Airlines is beginning service to Sydney, Australia (SYD), from Los Angeles on Dec. 17, 2015. We can all agree that this is new wide-body flying and the type of growth that we would like to see more of in the future. As we take delivery of more 777 and 787 aircraft, we will see an increase in stage length and will operate closer to the edges of the aircraft’s performance, as well as human performance. The new crew rest rules under FAR 117 are two years old and still experiencing growing pains. It is worthwhile to take a moment to review some key aspects of FAR 117 that apply to the SYD operation.
Contrary to expectations, this flight will initially be operated under the published FAR 117 Table C limits with no exceptions. While this may change in the future, it is important to understand how this applies to the operation initially.
The following graphic shows the scheduled footprint of the pairing. This will be crewed with one captain and three first officers and operated utilizing the 777-300.
AA company graphic
Please note that the scheduled Flight Duty Period (FDP) is 16:05 with the Table C limit of 17:00 hours. As you can see, this leaves 55 minutes for delay. However, crews are allowed to extend their FDP for two hours for “unforeseen operational circumstances.” From CFR 117.3:
Unforeseen operational circumstance means an unplanned event of insufficient duration to allow for adjustments to schedules, including unforecast weather, equipment malfunction, or air traffic delay that is not reasonably expected.
What does this mean to you? Each pilot must certify “fit for duty” before every segment and each must concur with any FDP extension before it can be granted. With little cushion for delay, it can be expected that crews will eventually be faced with this decision. While the desire and pressure to “complete the mission” will always be present, both the certificate holder and the crew member are responsible for ensuring that it is operated safely and legally.
The key is that it is a decision made jointly by the carrier and the pilot. When considering a request for an extension, keep in mind the following:
- The need for an extension must be due to an unforeseen operational circumstance. Examples can be found in the previous blast, "Is This Assignment Legal?"
- The pilot must be able to certify that they are still fit for duty for the scheduled FDP and any requested extension (maximum of 2 hours).
- The pilot-in-command has the responsibility to coordinate any extension for the crew with the certificate holder (via Crew Tracking).
Should you face an operational delay, take the time to review these criteria carefully. If you are rested and the nature of the delay is appropriate, then you are legal to extend. If either of those conditions is not fulfilled, then a FDP extension is not appropriate.
We are all seasoned, professional aviators well-versed in the management of risk. There have always been competing pressures that need to be balanced. This is no different. The Fatigue Risk Management System program has two very important elements: the mechanism to ensure that an American Airlines pilot never operates an aircraft while fatigued and the tools to help mitigate fatigue. Take the time to evaluate the flight plan, your fatigue mitigation strategies and current alertness levels as you make your decision.
If you have time-sensitive questions or need assistance, please call the fatigue hotline at 682-738-6670. If you have other questions or concerns, please contact the Flight Time/Duty Time Subcommittee at FTDTfirstname.lastname@example.org.