Happy Part 117 Day!

Well, today was the first day of the new Part 117 rest, flight, & duty time regulations, and it's been a long time coming. I frankly didn't think we'd ever see them come to fruition - the airline industry has successfully defeated updated rest regulations several times in the past, and they fought hard against them again this time. I don't think they're completely done fighting, actually. In the last few days I noticed United has been blaming their delays and cancellations on Part 117, conveniently failing to note that the two hubs most affected (IAH & EWR) are home to some 800 rampers about to be furloughed, their jobs outsourced, their pink slips an early Christmas present. No, I'm sure the real problem is being unable to work those lazy pilots 16 hours a day!

The new regs are complicated, but here's the cliff notes version, for domestic unaugmented (2-person) operations:

• Daily maximum flight time is upped to 9 hours (it was 8) if the day's showtime is between 5am and 8pm; otherwise it remains at 8 hours. This is a hard limit, unlike the old "legal to start, legal to finish." In other words, if I'm scheduled for 3 flights at 8.5 hours, and I overblock the second flight by an hour, I am no longer legal for the third flight, wheras I would have been under the old regs. 
• Minimum rest used to be anywhere between 8 and 12 hours. It is now a flat 10 hours, with at least 8 hours of uninterrupted sleep opportunity (i.e., behind the door at the hotel). The crew must also have had a 30 hour rest period sometime within the last 168 hours (7 days) - it used to be 24 hours within the last 7 calendar days.
• Maximum duty time ("Flight Duty Period," or FDP) is now determined by a table according to show time and number of legs for the day. It can be as little as 9 hours or as much as 14 hours. It can be extended for operational delays by up to 2 hours with the concurrence of the dispatcher and the PIC, but only once beyond 30 minutes until the crew gets a 30 hour rest period.
• A crewmember may not exceed 60 hours on duty within a rolling 168 hour (7 day) period, or 190 hours on duty in a rolling 672 hour (28 day) period. A crewmember may not exceed 100 hours of flight time in a rolling 672 hour period, or 1000 hours in the last 365 days. This replaces the old 30 hours in 7 days, 100 hours in a calendar month, and 1000 hours in a calendar year.

Surprisingly, or perhaps not, the majority of my fellow airline pilots aren't crazy about the new regs. I think it's partly airline pilot bitchiness, partly resistance to change, and partly the fact that the average line pilot didn't get worked to FAA maximums very often under the old regs (especially at mainline). One of the main gripes is that Part 117 is too complicated. It's certainly complicated; it's based on the science of sleep and fatigue, and as there are many factors that affect fatigue, it's necessarily complex. I don't expect that anybody will be able to memorize the new regultions as we all memorized and used the old regs. We'll need to refer to tables and cheat sheets often, and will be using smart phone and tablet apps to track our cumulative flight and duty times as the new rolling limits are much harder to track than the old calendar months and days. The fact that these tools are available now is all the more reason to move to a science-based system.

The other complaint is that the new regulations will decrease pilot efficiency and therefore result in more time away from home. This is undoubtedly true. Domestically, the inability to schedule 8 hour overnights will create more 32 hour layovers. Internationally, many 24 hour layovers will become 36 and 48 hour layovers. The Flight Duty Period table will reduce how much flying can be done in a day for anyone doing high-frequency, short-haul flying. Essentially, nearly everybody is going to take a hit in time off so that a minority can have much less fatiguing schedules.

I see that as a worthy tradeoff. Lord knows I love my time off, but I also absolutely hate flying tired. I've written about flying fatigued here before, and there have been quite a few times that I didn't blog about. I can say that over half of the serious mistakes I've seen made on the JungleBus occurred towards the end of a long day or after a short overnight. And my airline didn't even schedule to FAR maximums very often compared to some. Considering the regionals that regularly scheduled their pilots to 15+ hours on duty, it's a miracle we haven't had more crashes. The new regulations put everyone on a level playing field, so that nobody can cut corners on safety to gain a cost advantage. As for our passengers, they ought to rest much easier knowing that their pilots are much less likely to be flying fatigued than before.