Narrative:

During the 3 days of 5/tue-thu/90, I flew a scheduled 3 day trip. What follows is the scheduled trip: day 1: start at XA30, end at XH55 (on duty 14 hours, 25 mins; 7 hours, 45 mins block time); 9 hours, 25 min layover at ZZZ, us. Day 2: start at XA20, end at XO00 (on duty 14 hours, 40 mins; 7 hours, 25 mins block time); 8 hours, 30 mins layover at ZZZ, us. Day 3: start at XZ30, end at XF25 (on duty 6 hours, 55 mins; 3 hours block time). The trip was flown with no cancellations or additions to the scheduled flts. The following is what was actually flown: day 1: start at XA30, end at XN20 (14 hours, 50 mins duty; 7 hours, 55 mins block); 9 hours, 0 min layover. Day 2: start at XA20, end at XN15 (15 hours, 55 mins duty; 8 hours, 0 mins block); 8 hours, 0 mins layover. Day 3: start at XA15, end at XG20 )7 hours, 5 mins duty; 3 hours, 20 mins block). (Analyst note: day 2, period ended at XO15, for 15 hours, 55 mins duty.) prior to departing on the last flight of day 2, I became concerned about the required crew rest, since we were being delayed by maintenance. I knew that, though we had 9 hours rest the previous night, once we exceeded 15 hours duty time our rest for the 24 hour 'lookback' would be less than normal. My question was this: could I accept reduced rest on the second night, since I was still flying what was scheduled, or did we need compensatory rest because of what was actually flown? I called our company's head of (my aircraft) training and explained about my situation. He stated that, while he felt I needed compensatory rest, repeated discussions with our vp of operations indicated that the company's position was that reduced rest was legal. Based on that, I went with reduced rest. On completion of the trip I talked to our director of operations, who produced a memo from our vp of operations. The memo summarized an FAA ruling dated 7/89 stating (again, as I understand it) that required rest is based on actual flight time and duty time during the previous 24 hours. Commuter airlines routinely use the duty time regulations as a goal to achieve maximum utilization of pilots. Yet, I have not met a single line pilot that fully understands this regulation. As an example, no line pilot I asked knew the answer to my question. Why is this regulation so unnecessarily subtle?

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Original NASA ASRS Text

Title: REPORTER ASKS IF HE CAN ACCEPT A REDUCED REST PERIOD ON SECOND DAY OF SCHEDULED FLYING IN PREPARATION FOR A THIRD DAY OF FLYING (REDUCED REST MEANING LESS THAN 9 HOURS AFTER FLYING LESS THAN 8 HOURS IN 24).

Narrative: DURING THE 3 DAYS OF 5/TUE-THU/90, I FLEW A SCHEDULED 3 DAY TRIP. WHAT FOLLOWS IS THE SCHEDULED TRIP: DAY 1: START AT XA30, END AT XH55 (ON DUTY 14 HRS, 25 MINS; 7 HRS, 45 MINS BLOCK TIME); 9 HRS, 25 MIN LAYOVER AT ZZZ, US. DAY 2: START AT XA20, END AT XO00 (ON DUTY 14 HRS, 40 MINS; 7 HRS, 25 MINS BLOCK TIME); 8 HRS, 30 MINS LAYOVER AT ZZZ, US. DAY 3: START AT XZ30, END AT XF25 (ON DUTY 6 HRS, 55 MINS; 3 HRS BLOCK TIME). THE TRIP WAS FLOWN WITH NO CANCELLATIONS OR ADDITIONS TO THE SCHEDULED FLTS. THE FOLLOWING IS WHAT WAS ACTUALLY FLOWN: DAY 1: START AT XA30, END AT XN20 (14 HRS, 50 MINS DUTY; 7 HRS, 55 MINS BLOCK); 9 HRS, 0 MIN LAYOVER. DAY 2: START AT XA20, END AT XN15 (15 HRS, 55 MINS DUTY; 8 HRS, 0 MINS BLOCK); 8 HRS, 0 MINS LAYOVER. DAY 3: START AT XA15, END AT XG20 )7 HRS, 5 MINS DUTY; 3 HRS, 20 MINS BLOCK). (ANALYST NOTE: DAY 2, PERIOD ENDED AT XO15, FOR 15 HRS, 55 MINS DUTY.) PRIOR TO DEPARTING ON THE LAST FLT OF DAY 2, I BECAME CONCERNED ABOUT THE REQUIRED CREW REST, SINCE WE WERE BEING DELAYED BY MAINT. I KNEW THAT, THOUGH WE HAD 9 HRS REST THE PREVIOUS NIGHT, ONCE WE EXCEEDED 15 HRS DUTY TIME OUR REST FOR THE 24 HR 'LOOKBACK' WOULD BE LESS THAN NORMAL. MY QUESTION WAS THIS: COULD I ACCEPT REDUCED REST ON THE SECOND NIGHT, SINCE I WAS STILL FLYING WHAT WAS SCHEDULED, OR DID WE NEED COMPENSATORY REST BECAUSE OF WHAT WAS ACTUALLY FLOWN? I CALLED OUR COMPANY'S HEAD OF (MY ACFT) TRNING AND EXPLAINED ABOUT MY SITUATION. HE STATED THAT, WHILE HE FELT I NEEDED COMPENSATORY REST, REPEATED DISCUSSIONS WITH OUR VP OF OPS INDICATED THAT THE COMPANY'S POS WAS THAT REDUCED REST WAS LEGAL. BASED ON THAT, I WENT WITH REDUCED REST. ON COMPLETION OF THE TRIP I TALKED TO OUR DIRECTOR OF OPS, WHO PRODUCED A MEMO FROM OUR VP OF OPS. THE MEMO SUMMARIZED AN FAA RULING DATED 7/89 STATING (AGAIN, AS I UNDERSTAND IT) THAT REQUIRED REST IS BASED ON ACTUAL FLT TIME AND DUTY TIME DURING THE PREVIOUS 24 HRS. COMMUTER AIRLINES ROUTINELY USE THE DUTY TIME REGS AS A GOAL TO ACHIEVE MAX UTILIZATION OF PLTS. YET, I HAVE NOT MET A SINGLE LINE PLT THAT FULLY UNDERSTANDS THIS REG. AS AN EXAMPLE, NO LINE PLT I ASKED KNEW THE ANSWER TO MY QUESTION. WHY IS THIS REG SO UNNECESSARILY SUBTLE?

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.