FAR 117 and Pilot Fatigue Guide REV 4 Oct 2014

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FAR 117 and Pilot Fatigue Guide

REV 4, Sept 2014
For SkyWest Pilots
SAPA Safety Committee
Table of Contents
FAR 117 and Pilot Fatigue Guide ..................................................................................... 1
For SkyWest Pilots ....................................................................................................... 1
FAA and Fatigue ................................................................................................................................... 1
Fitness for Duty ..................................................................................................................................... 3
Tables A & B ......................................................................................................................................... 4
Split Duty Trips (Standups) .................................................................................................................... 5
FDP Extensions:.................................................................................................................................... 5
Cancelations and Cancelation Standby Status (CSS) .............................................................................. 8
FAR 117 for Reserves ............................................................................................................................ 8
FAQs .......................................................................................................................... 9
Definitions............................................................................................................................................. 9
Flight Duty Period: Unaugmented Operations ..................................................................................... 10
Adjusting the Number of Flight Segments ........................................................................................... 11
Flight Duty Period Extensions .......................................................................................................... 14
Rest Period ......................................................................................................................................... 20
Split Duty ............................................................................................................................................ 21
Reserve Questions: .............................................................................................................................. 22
Deadheads (DH) ................................................................................................................................. 23
Fatigue Reports .............................................................................................................. 24
FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014
ii
FAR 117 and Pilot Fatigue Guide REV 4,

Sept 2014
For SkyWest Pilots
Contained in this guide is information related to fatigue and FAR 117 rest rules. This is not
meant to be comprehensive but rather a reference guide. You will find an FAQ that we hope
will answer many of the questions that continue to surface regarding FAR 117. The final
portion of this guide describes our Fatigue Risk Management Program and the Fatigue
Reports associated with calling in fatigued. Each section is chaptered as well as an FAQ
separated for quick reference. For those seeking the best information on how to fill out a
Fatigue Report that section is at the end of the document.
FAR 117 has a deep-rooted history. After the Colgan crash in Buffalo, NY in 2009 the U.S.
legislature mandated the FAA adopt new rules regarding fatigue. The essence of FAR 117 is
to keep pilots from the controls when they are fatigued.
FAA and Fatigue
What is fatigue?
Fatigue is a general lack of alertness and degradation in mental and physical performance.
There are three types of fatigue: transient, cumulative, and circadian. In aviation,
fatigue may cause a pilot to fall asleep during cruise flight or it may impact alertness during
takeoff or landing. []
Although sleep science is evolving, research has indicated that most people need eight hours
of sleep in 24 hours to perform effectively, and the average person needs in excess of nine
hours of sleep per night to recover from accumulated sleep debt. Most people find it more
difficult to sleep during the day than at night. In addition, the risks of fatigue and making a
mistake increase the longer a person has been awake and working on a task.
Types of Fatigue: The FAA recognizes three distinct types of fatigue for pilots, transient,
cumulative, and circadian. As defined by the FAA: 1
Transient is acute fatigue brought on by extreme sleep restriction or extended hours

awake within 1 or 2 days. (pilots will find this after flying subsequent stand-up trips
and not getting adequate rest during the days between trips)
Cumulative fatigue is fatigue brought on by repeated mild sleep restriction or
extended hours awake across a series of days. (This is the most typical fatigue at
SkyWest due to the nature of PBS and our bidding cycles awarding many pilots
flying that covers more than five consecutive days without a break.)
Circadian fatigue refers to the reduced performance during nighttime hours,
particularly during an individuals WOCL typically between 2:00 a.m. and 6:00
a.m. (30hr layovers where pilots arrive on one night and depart on the first flight two
days later are the greatest contributor.)
Acknowledging that a person can be fatigued at any time of the day, depending upon that
persons schedule, is paramount in fatigue recognition. The FAA has concluded that what
time of day you begin work, as well as your task saturation at work (for us that means
segments flown and workload), can be categorized such that they created FAR 117 Table A,
which regulates the number of block hours a pilot can fly in a duty period, and Table B,
which determines the amount of time a pilot can spend on an FDP. As pilots we can use
both these tables as guidance to monitor your fitness for duty.
FAA: Fatigue is characterized by
increasingly frequent lapses in performance,

general cognitive slowing, including a lowering of optimum performance,
memory problems,
time on task decrements , and
an increasing inability to maintain the vigilance required to perform the tasks
required.
Even though the entire FAR 117 is designed to mitigate fatigue and keep pilots from
operating flight segments while fatigued, there is no regulation or rule that can eliminate the
risk of fatigue. Hence all flight segments begin with a fitness for duty affirmation. 117.5
Using Table B to determine your maximum FDP requires that you use your domicile time
as your Time of Start. You will also use this chart if the Company has reflowed you and
your original number of segments has been changed. However, if you divert to your
alternate, and then continue to your destination, this is only considered one flight segment.
Similarly, if you are forced to land to refuel because your destination is beyond the aircrafts
endurance this is considered only one segment if you were planned for one segment. You do
not need to recalculate your FDP in these cases. However, if you are planned to have an
intermediate fuel stop due to headwinds, this is considered two segments because it is
planned as two segments despite having only one flight number.
Fitness for Duty
At the heart of the 117 ruling is the pilots responsibility to report for duty rested, be able to
accept the scheduled assignment and subsequent segments associated with the FDP, and
report to the Company any time the pilot can no longer accept such responsibilities due to
fatigue. The Company bears an equal responsibly under 117 to not assign a pilot any
schedule when that pilot has reported fatigued and remove that pilot from any assignment at
that time. This is a non-punitive program and all reports are de-identified prior to
submission into the program.
Each segment requires a separate fitness for duty statement (117.5). When signing the
fitness for duty statement a pilot is testifying he or she is fit to accept the segment associated
with the affirmation of duty. The FAA has also said that pilots may be held on duty if the
certificate holder has another flight pending and that flight could legally be scheduled in the
FDP. So, when testifying to your fitness on the first leg you are also accepting that you are
fit to accept a schedule that goes to the end of your normal Table B FDP limit (this has
changed since the FAAs Tutt legal interpretation, which will be discussed later). It does not
however mean you are accepting any extensions to the FDP; you cannot accept an
extension until you are aware of the need for the extension, the duration of the extension,
and the reason for the extension.
The FAA also stated the reasoning behind using this fitness for duty statement is to
discourage flightcrew-member practices such as pick[ing] up extra hours, moonlight[ing],
report[ing] to work when sick, commut[ing] irresponsibly, or simply not tak[ing] advantage
of the required rest periods.2 Thus, the FAA has now clarified the rule that places the
responsibility on to the pilot to report for duty fit for all legally assignable duties.
If, at any time, the pilot can no longer be fit for duty it is the responsibility of the pilot to
notify the Company and the Company will provide rest for the pilot and/or remove the
pilot from duty until such time that the pilot can return to duty rested. It is the expectation
of SkyWest that any pilot removed from an assignment will return to flying duty, in some
capacity, as soon as they are fit for duty.
Tables A & B
Table A deals exclusively with scheduled block hours. Pilots use Domicile Time to enter
into the table their time of report to determine whether they can fly 8hrs or 9hrs of block.
These time limits cannot be extended.
Table B governs all FDPs, including Split Duty trips. Pilots use Domicile Time to enter into
the table their scheduled time of start, plus the number of scheduled segments, to determine
their maximum allowable FDP. SkyWest shows the scheduled start time as report time
e.g.
, which is always in local time and needs to be converted to Domicile
Time. Each day you will also have a release time e.g.
, which is
shown in local time and needs to be converted to Domicile Time. The time elapsed between
these two times is your scheduled FDP less 15 minutes, unless your day ends with a
deadhead. The scheduled debrief time of 15 minutes per day is not considered FDP time but
is considered duty. Noting the end of duty is important to calculate your legal rest. FAR
117.25 Rest Period says, . . . the flightcrew member is given a rest period of at least 10
consecutive hours immediately before beginning the reserve or flight duty period measured
from the time the flightcrew member is released from duty.
If your last flight of the day arrives early or late, CS will make adjustments to your release
time. If you are required to remain on duty for longer than 15 minutes after the aircraft
blocks in (a MX issue for example), then you should notify crew support if it affects your
ability to receive the required rest.
To calculate your actual FDP time you will subtract the report time from the release time.
Report times cannot change once you have checked-in.
Any additions or subtractions of segments throughout the day will effect your FDP
limitation.
Split Duty Trips (Standups)
Split Duty trips also use Table B. At SkyWest we currently have only Split duty trips that
consist of two segments. Split Duty trips cannot be more than 14hrs of combined FDP and
rest time without an extension. If a pilot cannot get 3hrs of rest between the hours of 2200
and 0500 the trip does not qualify as a Split Duty. Unlike a normal FDP, during Split Duty
assignments time spend debriefing as well as traveling to and from suitable accommodations
is not counted as a rest period and is counted toward the FDP cumulative limits, however
the scheduled rest time is not counted as FDP time.
FDP Extensions:
Note: All references to the use of ACARS can be replaced with signature on manual manifest(s) for
all EMB-120 operations.
The FAA has provided a legal method to have pilots fly beyond your FDP limit. Pilots
cannot be scheduled for more than the Table B limits but can be legally extended to
complete the schedule. There are two types of extensions a pre-takeoff and a posttakeoff.
Pre-takeoff extensions require the PIC to have knowledge of the extension, the duration and
the reason for the extension, and concur the crew will be fit for duty during the entire
extension, what ever amount of time the PIC and OCC agree upon. If any pilot needs a pretakeoff extension, both the PIC and the Company must concur to the extension even if the
PIC is not the crewmember who needs the extension. As of this writing, SkyWest asks
pilots who will knowingly operate within the last hour of their FDP limit to calculate a
wheels-up time for the last segment. When encroaching on that limit pilots need to be
familiar with how much time is available before needing an extension as well as the pilots
cumulative limits associated with all other aspects of FAR 117.23.
When the crew is aware of the need for an extension before ACARS is initialized, the crew
may accept the extension by initializing ACARS. If the crew needs an extension after
initializing ACARS, the PIC is required to call the OCC Supervisor at 435-634-3972 to
document the concurrence to the extension.
Keep in mind that the FOM also states, If the PIC believes that the flight crew is not
capable of completing the maximum FDP extension, the PIC could concur to a shorter FDP
extension that they believe could safely be carried out by the flight crew. (see FOM Chapter
3, Paragraph 2.E.2 h. i) Because FAR 117 is a flight, duty, and crew rest ruling, when you
do not accept the extension, in essence this is the same as saying you are not fit for duty to
complete the flight segment. As a result of this, SkyWest considers this a fatigue call and
you will be entered into the Fatigue Risk Management Plan.
In the event you find yourself needing an extension due to unexpected circumstances that
have increased your time airborne, you are expected to continue the flight normally despite
exceeding your FDP limit. This post-takeoff extension has happened because of unforeseen
circumstances.
Both types of extensions are monitored by the FAA, but the Company only needs to submit
a report of the extensions that exceed 30 minutes. Pilots are not required to submit reports
for extensions however, the Company may contact you for more information if required.
If you have taken an extension greater than 30 minutes, you cannot accept another
extension greater than 30 minutes until you have had 30 hours of rest. Please note, the
FAAs Flight Duty Clarification document from March 2013, specifies that a pilot who has
taken an extension greater than 30 minutes and has another extension greater than 30
minutes prior to receiving 30 hours of rest the pilot would be in violation, regardless of
how the situation transpired. So, if you have taken an extension that is greater than 30
minutes, do not allow yourself to be in a situation where you may have another exceedance
prior to your 30 hours of rest. Because of this ruling the SAPA Safety Committee
recommends that pilots do not accept a second extension following an extension greater
than 30 minutes due to the risk of a pilot violation.
Furthermore, to avoid the possibility of a violation, pilots who are unsure they will be
airborne before needing an extension should call OCC to document the concurrence, due to
the possibility of the need for an extension, to insure compliance.
Example: A crew has an FDP of 12 hours and the scheduled block time of the last leg is 2
hours, if this crew has an OFF time that is greater than 10 hours into their FDP they would
be in violation. If faced with this scenario a preemptive call to OCC to document you
concur with the extension will insure you are legal just in case the taxi out takes longer than
anticipated. NOTE: If you departed before the 10 hour mark in this example and fly greater
than 2 hours of block, you took a post-takeoff extension and are legal.
There are no pre-takeoff extensions for the limitations in Table A. If you know your block time will
exceed Table A you cannot accept that flight segment.
Cancelations and Cancelation Standby Status (CSS)
The FOM addresses a pilots responsibilities are after a flight cancels. There are two types of
canceled segments. A segment that cancels prior to a pilots report time is not considered
part of an FPD because there was no check-in. Segments that cancel after a pilot reports for
duty are covered in the new CSS verbiage and allow a pilot to leave the airport but yet that
pilot continues to accrue FDP time.
FAR 117 for Reserves
A RAP is in essence a notification period that a pilot must be available to the Company.
This is considered duty, but does not count toward your cumulative limits under FAR 117.
The FAA acknowledges that a RAPs duty period will be considered when scheduling an
FDP. For an unaugmented operation, under 117.21(c)(3), the combined number of hours
spent in a RAP and FDP may not exceed the smaller of: (1) FDP limit in Table B plus four
hours; or (2) 16 hours. 4 RAPs cannot be extended beyond 16hrs. 5
Example 1: RAP begins at 4am, CS calls and assigns a trip with four segments and a report
time of noon. Table B says the FDP limit is 13 hours. Add the time spent on the RAP up to
4 hours. The total is 17 hours but the limit is 16 hours. Scheduling beyond 8pm is not
allowed and therefore cannot accept an FDP of 13 hours. In this case, the latest one could
be scheduled would be Noon to 8pm, or an 8 hour FDP.
Example 2: RAP begins at 9am. CS calls and assigns a five leg pairing beginning at 1500.
Using Table B you find your FDP limit is 11.5hrs. Add up to 4hrs of your RAP to that to
find you can only be scheduled for 15.5hr from the beginning of your RAP time or 0030 is
your scheduling limit.
Acronyms
CS Crew Support
CSS - Cancelations and Cancelation Standby Status
FDP Flight Duty Period
OCC - ?
RAP Reserve Availability Period
WOCL window of Circadian Low
FAQs
Definitions
Q: What is the window of circadian low (WOCL)?

A: The WOCL is the period of time between 0200 and 0559 when physiological sleepiness
is greatest and performance capabilities are lowest. 6
Q: Are there limits to scheduling a pilot during the WOCL?

A: Pilots may not be scheduled for more than three consecutive FDPs that occur within the
WOCL, unless those FDPs meet some specific rest requirements in FAR 117. Split Duty
trips meet those rest requirements (and have additional requirements) so a pilot can be
scheduled for more than three Split Duty pairings in a row. 7
Q: What is considered duty and will I be in an FDP every time Im on duty?

A: No, you will not always be in an FDP while on duty. Duty is now classified as any task
that a pilot performs that is required by the certificate holder. This means if the Company
needs you to perform a task you are on duty, even if that means youre at home working on
CBTs or in a RAP. You are not at rest while on duty.
Q: Can you explain the difference of duty and an FDP?

A: Duty is described above. A Flight Duty Period (FDP) is a period that begins when a pilot
is required to report with the intention of aircraft movement, including deadheads that
precede such duty. You must have 10hrs of rest before beginning an FDP.
Q: Am I on duty while on a Reserve Availability Period (RAP)?

A: Yes, but you are not accruing any time towards your cumulative limits in 117.23 while
in a RAP.
Flight Duty Period: Unaugmented Operations
Q: If we have to reposition the aircraft, after or before our flight, does this affect our FDP
limit?
A: If you are repositioning an aircraft you are still considered to be in an FDP. This is not a
segment however and doesnt affect your FDP limit. 8
Q: Are the limitations of FAR 117 applicable to training?

A: FAR 117 governs rest and FDPs. Because pilots who are in training are not at the
controls of a plane, training is not governed by FAR 117. If however, you have been in
10
training, you will need the required 10hrs rest, with an 8 hour sleep opportunity, prior to
being scheduled for an FDP. Or, if you have been in training and want to operate a flight
later that day, all FDP limits and rest limits for FDPs would apply. 9
Adjusting the Number of Flight Segments 10
Q: A crew taxis out for a flight but then is canceled and returns to the gate. Is this a flight
segment? And how does this change your FDP limit?
A: This is not a flight segment because a segment includes a takeoff and a landing. The time
spent doing this does count towards the pilots FDP limitations. Once a flight is canceled a
pilot uses Table B to recalculate the new FDP limit based on the new number of segments
scheduled.
Q: If we have extreme headwinds or need to be rerouted around extreme weather and the
flight is scheduled for an intermediate stop to refuel, does this count as two flight segments?
A: Yes. A scheduled stop is not an unplanned diversion but rather a planned event,
therefore this type of schedule is considered two segments. This has been added since the
Cubas and US Airline Pilots Assoc. legal interpretation of Feb 2014.
Note: Changing the number of segments in an FDP doesnt always change your FDP limit! Example:
If youre report times is between 1200-1259 and you shorten the segments from 4 to 2 that does not
change the FDP limit, which would remain at 13hrs in this case.
Q: I reported for work but my flight is delayed or canceled. Can the Company change my
scheduled FDP start time?
A: Once you have started your FDP the start time for that FDP cannot be changed. If the
pilot has a 6am report time and shows up at 6am, then the FDP has started at 6am and
cannot be changed.
11
Q: Im on an overnight (or at home). The company is trying to notify me of a change to my

start time. Can the Company change my scheduled FDP start time?
A: Prior to the FDP starting, the company can attempt to contact a pilot and modify the
next FDP start time using either a short-call or a long-call reserve provision. Remember this
doesnt really mean that the pilot is on reserve, but the FAA requires that these procedures
be used to modify the FDP start time. 11 If your report time was changed using this
provision you would not be starting your FDP as originally scheduled. Because youve been
notified of this change and your start time was changed it is treated like you were in a RAP.
Here are a couple of examples:
Short-call example: The pilot is scheduled to start an FDP at 6am. The Company may
attempt to call the pilot at 5am and let him know that the first flight is delayed and to show
at 10 am. Technically, the FAA considers that the pilot was placed on short call at 6am.
Then the FDP would start at 10am. This procedure keeps the pilot from accumulating time
towards their cumulative FDP limits.
Long-call example: The pilot is scheduled to start an FDP at 6am. At 10pm the night prior,
the Company attempts to call the pilot to let them know that the flight is late and a new
show time of 10am. IF the pilot answers, they could be immediately released into at least a
10 hour rest prior to the next FDP.
Note: The above procedures are an explanation of the rule described in the FOM, Chapter 3, Paragraph
E.2.f. FDP Modifications.
Q: Im on an overnight (or at home). The company is trying to notify me of a change to my

schedule. Do I have to answer the phone?
A: No. If you are not on an on-call reserve period, you have no obligation to answer the
phone.
However, in some cases, it may be to your benefit to voluntarily answer the phone for a
modification to the FDP start time, or a reflow.
If you choose to voluntarily answer, the FAA does not consider this breaking the rest
period. However, a pilot may notify the company that his or her sleep opportunity has been
interrupted in such cases. Thus, the company runs the risk of interrupting the sleep
opportunity if they try to call during a required rest period.12
12
Q: An earlier question stated that pilots need to recalculate their FDP limit based on
segments that are added or subtracted. Is it true that an FDP start cannot be recalculated?
A: Not exactly. This was described above as well so just to be clear, an FDP start time
cannot be changed once the pilot has checked in, however, the FAA ruled13 that a pilot can
have their report time delayed by being placed in a schedule similar to short-call reserve, if
the need for the FDP start time would be later than originally scheduled. Remember, if you
are on short-call reserve you are on duty but you not in an FDP. In this example, whatever
the new start time is the FDP limit will be calculated using that time, but youll apply
117.21(3) to the limit.
Example: A pilot wakes up for a 5am report time and is notified by the Company the
aircraft didnt make it in the night before. At that point the Company gives the pilot a new
report time and places the pilot in a delayed report time.
Note: The above procedures are an explanation of the rule described in the FOM, Chapter 3, Paragraph
E.2.g. FDP Modifications.
Q: Can an FDP end-time, or release from duty, be modified once the FDP has started?
A: Yes. According to the Tutt legal interpretation (June 16, 2014), if a certificate holder
does not have an affirmative intent for no further aircraft movement at the conclusion of the
flightcrew members last-scheduled segment, then the flightcrew members FDP has not
ended. This means that if you were originally going to DH on a flight you may be asked to
operate it instead. In this case the FDP never terminates and all time spent on that FDP will
count toward the pilots cumulative limits.
Q: Does this mean that I can pick up more flying the same day that I was released from
duty?
A: As of this writing the Company is not providing that to the pilots. However, this is now
considered legal due to the Tutt legal interpretation.
13
Q: We just diverted. Now well have an extra takeoff and landing. Isnt this a new segment,
and wouldnt we have to recalculate our FDP limit based on this?
A: No. The FAA says, [the definition of] flight segments make no mention of a diversion
counting as a separate flight segment. So no, you do not a count a diversion as a new
segment. However, you do count the time spent in an FDP and flight time accrued towards
your cumulative limits. 14
Q: If we taxi out and never takeoff, is this a segment?

A: No. If you taxi out and do not takeoff this is not a segment. This is considered flight time
though because you moved under your own power with the intent of flight. This time would
apply to your cumulative limits.
Q: In Chicago we deice at the gate and never move. If we are canceled and never move, yet
have an OUT and IN time, this isnt considered flight time?
A: No. Because the aircraft never moved under its own power with the intent of flight, this
block time does not count towards the Table A flight time cumulative limits. 15
Flight Duty Period Extensions 16 17 18
Q: If we are scheduled for four legs but know that flying the fourth leg will exceed the limits
in Table A, can we continue the scheduled day?
A: There is no more legal to start legal to finish. There are no pre-takeoff extensions for
Table A cumulative flight time limits. If you know you will exceed Table A prior to takeoff,
you cannot depart. If you can complete leg three it is legal to operate leg three, but not leg
four. 19
14
Q: FAR 117 says if unforeseen operational circumstances arise before or after takeoff, a
pilots Table B limitation can be extended. What is the definition of unforeseen operational
circumstances?
A: 117.3 Definitions: 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 this means is that almost anything can
be categorized as unforeseen operational circumstances. Or, if the Company starts the
operation to fulfill a legal schedule, any disruption to that schedule can be considered
unforeseen operational circumstances.
However, in the preamble to the ruling the FAA stated, insufficient duration to allow for
adjustments to schedules is intended to exclude unplanned events of relatively short
duration. For example, the FAA would not consider a five-minute air traffic delay as an
unforeseen operational circumstance that justifies the need for a two-hour FDP extension.
Because relatively short unplanned events should not be used as a basis for extending an
FDP, the FAA has decided to retain "insufficient duration to allow for adjustments to
schedules" in the definition of unforeseen operational circumstances. At this point SAPA
does not have an official stance on how pilots should be applying this. The Garciglia legal
ruling of July 8, 2014 supported that unplanned events that are short should not be grounds
for an extension. 20
Q: Weve taxied out and didnt need an extension but due to an unusually long taxi we
wont takeoff in time to complete our FDP within our Table B limits. What do we do?
A: You need an extension to continue to operate that segment. You must contact the OCC
Supervisor at 435-634-3972 to have your extension documented. You cannot accept an
extension if you will exceed any of the cumulative limits of 117.23.
Also remember, if you have taken a >30 min Table B extension since your last 30hrs of rest you cannot
accept another extension > 30 min.
Q: Does the FAA consider the Fitness for Duty certification legal if I do this through
ACARs?
A: Only if you are aware of the need for an extension prior to initializing ACARS. 21
15
Q: How many extensions can we take if none go beyond 30 mins?

A: There is no limitation.
Q: So Dispatch can add as many extensions as they want?

A: No, an extension only applies to the last segment of your FDP. You only get one
extension per FDP.
Q: How many extensions can we take if our first extension exceeded 30 mins?
A: You cannot take another extension greater than 30 min until you have received 30hrs of
rest. 22
Q: If Ive taken a >30 min extension and due to unforeseen circumstances we end up taking
a post-takeoff extension >30 mins, this is a violation?
A: Yes. From the FAA: It is irrelevant that the exceedance in this example was caused
by unexpected circumstances because, at the time of the exceedance, the flightcrew
members had each already used up their one over-30-minutes FDP extension.23
Q: If I can fit two segments into the 120 min extension limit can I accept them both?
A: No. An extension can be only used for the last segment of the FDP. The spirit of the
extension rule is to allow the air carrier to complete a segment provided the pilot continues
to be fit for duty. Extensions are not to be used as scheduling tools to add additional flying,
only to complete the flight segment that needed the extension.
Once the flight ends you will not be able to be extended again, even if another flight could
be completed within the 120 min extension limit.
16
Q: How do extensions affect landing at an alternate?

A: If you diverted you can be extended to complete the original schedule only if the
diversion didnt take you beyond your FDP limit; if you divert and it puts you one minute
past your FDP limit you taken an post-takeoff extension and thus you cannot take an
additional extension. You will be spending the night at the alternate unless you are
deadheaded out. 24
Q: What if we land at the alternate and need a Table B extension to continue?

A: If youve diverted and need an extension all normal extension rules would apply.
Q: Can dispatch automatically extend the crew to 120 min every time an extension is
needed?
A: No. The FAA has been clear that both the PIC and dispatch should derive a plan that
allows the flight to be completed within the time that the PIC has determined the crew will
be fit for duty. For example, the PIC can determine that an extension less than 120 minutes
acceptable. 25 26
Q: If we accept the extension will dispatch always plan on a 120 min extension as a buffer?
A: No. The extension will be for the amount of time you are planned to exceed your FDP,
plus the 15 min of duty for post-flight duties.
Example 1: Your FDP limit is 12hrs. You have one leg left to fly SFO MCI, which is 3:28
of block, your planned departure time is 9:30hrs from the beginning of your FDP.
When you add 3:28 to 9:30hrs your planned FDP will be 12:58, or 58 mins past your
Table B FDP limit. When you sign the manifest or enter your password into ACARS
you are attesting to your fitness for flight as well as accepting a 58 min extension.
When you are attesting to your fitness for duty for this leg you are also attesting to
your fitness for the extension because you know of the extension prior to initializing
ACARS. If you cant physiologically complete the flight due to fatigue, call CS or
Dispatch to create a new plan or be removed from the segment for fatigue.
17
Example 2: Your FDP limit is 12hrs. You have one leg left to fly SFO MCI, which is 3:28
of block, your planned departure time is 8:30hrs from the beginning of your FDP.
This only leaves you with 2 minutes of spare time before you need an extension.
Youve blocked off the gate early but have a ground delay that will require you need
an extension. At this point you didnt think you needed an extension when you
initialized the ACARS and therefore that was not concurrence with an extension.
Because you will exceed the spare 2 minutes you will need to call the OCC
Supervisor for an extension.
Q: Does the 15 mins for post flight duties and debriefing count toward my FDP?
A: No. There is no intention for further aircraft movement thus this time is not counted
towards your FDP, unless you are operating a Split Duty trip then this time is counted as
FDP.
Q: If we decline the extension will it be in essence calling in fatigued?

A: Yes. The spirit of the rule is not to schedule you more than you could physiologically
handle. Tables A & B, were designed using sleep and performance studies and have
established parameters to keep pilots from being scheduled without the consideration of
fatigue. Each pilot will have different tolerances to fatigue. As a result fatigue calls will vary
from pilot to pilot and from situation to situation. When you cant accept the extension,
SkyWest deems that you are turning it down because you wont be fit to fly. Please review
AC 117-3. If you decline the extension for any other reason than fatigue it would be a safety
of flight issue using PIC authority to do so.
Q: If I decline the extension will I still be paid?

A: You will not be asked to extend unless you have reached the end of your FPD or the
scheduled flying would exceed your FDP. SAPAs Safety Committee believes that any pilot
who flies to the end of their FDP and is asked to be extended has worked to the extend of
their legal FDP and should be covered for the pay of any missed flying. Each fatigue report
is evaluated individually.
18
Q: If I decline an extension for reasons other than fatigue is that considered grounds for
discipline?
A: The FAA recently stated that pilots who refuse extensions cannot be forced to concur the
any extension, and went on to say that pilots who do refuse to concur are also not covered
under FAR 117s provisions, As with several other issues in this interpretation, we expect
this issue to be addressed as part of the certificate holder and PIC's employer-employee
relationship. The management-labor issues as presented in your scenarios are beyond the
scope of part 117.27
Q: What if we depart legally and end up flying past our legal FDP? Do we need to land
before the FDP limit or can we continue and take an extension in the air? Do we need to
ACARS dispatch in the air for an extension?
A: If you are in the air and have legally departed and exceed your FDP limit, you are taking
a post-takeoff extension due to the unforeseen circumstances that delayed you, it is not
necessary to land before your FDP limit due to this extension. You do not need to contact
dispatch but you cannot be extended once you land, you just took your extension for that
FDP. If your extension was more than 30 mins you cannot accept any additional extensions
greater than 30 minutes until you have 30hrs of rest.
Q: The Pilot Policy Manual states that no pilot will be scheduled for more than 14hrs of
duty without his/her consent. Does this mean I dont have to accept an extension that puts
me over 14hrs?
A: If you are delayed and continuing on your originally scheduled day, the expectation is
that you will do your best to finish the day as assigned. This may mean that an extension
would be necessary to finish your originally scheduled trip. However, if you are reflowed,
the Pilot Policy Manual states that you wont be scheduled past 14 hrs without your
consent.
19
Q: If there is a You must acknowledge this schedule change before proceeding button my
schedule and the proposed schedule exceeds 14hrs, what do I do?
A: If you want to accept this assignment, then click the button. If you dont want to be
scheduled beyond 14hrs, call CS and explain that SP3016.2 restricts the company from
assigning a schedule without the pilots consent and you would like to have a different
schedule.
Rest Period 28
Q: If I need 30hrs of rest in every 168hrs, when does that rest have to begin?
A: The FAA has been clear in saying that the point of reference for the rest requirement is at
the beginning of the FDP or Reserve Availability Period (RAP). This means that in order to
begin a new FDP or RAP a pilot needs to have 30hrs rest within the previous168hrs. Once
you start that FDP or RAP you have complied for the duration of that FDP or RAP.
Q: Does my 30hrs free from duty need to be in my domicile?

A: No, it can be anywhere. 29 But the PPM (SP 3017.7.C.1.b) does provide that PBS cant
schedule you more than six calendar days in a row unless you specifically waive this
parameter in your bid.
Q: Im on an overnight and due to some IROPs my entire next day is canceled. Can this be
considered my 30hrs rest I need in my 168hrs?
A: No. All rest is prospective in nature, meaning that rest has to be scheduled; pilots must
be told in advance of any rest periods and their duration to be considered for FAR 117. 30
20
Split Duty
Q: FAR 117.15 states that the rest opportunity must be between 2200 and 0500 local time
where the rest opportunity will take place. What happens if we get in late and cannot have
rest during that time?
A: This trip is no longer a Split Duty trip if the rest cannot be obtained during the hours
2200 and 0500 local time. This trip is subject to normal FDP constraints. All Split Duty trips
are governed by Table B, however, the time spent in rest under 117.15 Split Duty provides
this time not be considered part of the FDP. 31
Example 1: A pilot is assigned a Split Duty trip with a report time of 2200 and two
segments. Using Table B the max FDP is 11hrs, thus the pilot would need to be scheduled
to block in by 0900 the following day if it was governed only by Table B. However, the
Wykoff and Mullen legal ruling 32 has supported that all time spent in a suitable
accommodation, as described in 117.15, is not considered FDP and therefore the pilot can
subtract the time spent in the suitable accommodation from the FDP time.
Example 2: A pilot is assigned a Split Duty trip with a report time of 2100 and consisting of
two segments. The Table B limit for this trip would be 12hrs. Using the Split Duty rule the
pilot can now block back into base 14hrs after the start time. BUT, if the pilot is unable to
obtain at least three hours of rest between 2200 and 0500 this trip cannot be Split Duty. In
this case the delay is so significant that the total time of the trip would be 12:10. Because of
this the trip is no longer legal unless the pilot flies one segment and then has 10hrs of rest
before flying the second. The reason being is that as soon as the Split Duty provision
becomes invalid the trip is being scheduled to exceed the Table B limit.
Q: Can I be extended while on a Split Duty assignment?

A: Yes. The FAA issued an interpretation document on March 20th (Wykoff & Mullen) that
allows for Split Duty assignments to be extended under the provisions of 117.19
(extensions), provided all other aspects of the Split Duty rules are followed.
21
Q: Is the rest opportunity in local time or domicile time?

A: It is in local time. The FAAs ruling states, . . . in order to determine compliance with
117.15(a), the certificate holder must use local time at the location where the split-duty rest
is being provided regardless of whether the flight crewmember is acclimated to the theater
that encompasses that location. 33
Reserve Questions:
Q: FAR 117 says rest has to be continuous and I need 30hrs free from duty in every 168hrs.
If the Company places an assignment on my schedule during my rest, or period free from
duty, can I legally accept it?
A: Yes. If you choose to accept an assignment while you are at rest that is your choice. You
need to respect the other rules with regard to fitness for duty, but because there is no
obligation for you to check your schedule the Company can ask you to acknowledge an
assignment on your free-time. However, the Company is prohibited from interrupting your
rest.
Q: If I accept a reflow while on a 30hr overnight where can I expect to receive the 30hrs free
from duty in 168hrs?
A: You need to be able to look back 168hrs and find 30hrs free from duty in order to begin a
new FDP or reserve period. If you accept a reflow on a 30hr overnight you must insure you
can look back and find this period of free-time, because what once satisfied your 30hrs is
now a reflow. This may impact your legality for future assigned trips.
Q: If Im on long-call reserve and CS wants to assign me a trip that reports with less than
12hrs notice, can I accept it?
22
A: It depends. First, the Pilot Policy Manual states that you have 12 hours. However if you
want to help out you can accept a minimum 10 hour rest as long as the assignment doesnt
operate in the WOCL. If the assignment operates in the WOCL, the minimum is 12 hours
of notification per the FAA
Q: The Company has modified Ready Reserve into Airport Standby/Ready Reserve. They
also have Cancelation Standby Status. What is the difference, and are we approved to leave
the airport?
A: There are two types of Standby statuses being used by the Company. First is Ready
Reserve, and during Ready Reserve a pilot is not authorized to leave the airport. This can
only be assigned to pilots who are reserve pilots or have volunteered for a reserve day.
Second is Cancellation Standby Status (CSS). This is the standby status the Company may
issue when a flight has been cancelled with a two-hour callout. The pilot may leave the
airport but is required to have a two-hour callout. This is not reserve because FAR 117
requires that any pilot given a reserve status must have 10hrs of rest preceding the on-call
status. All time spent in a CSS is considered both on duty and on an FDP. This practice had
been approved by the FAA within our FOM.
Note: Both of these assignments count toward your FDP daily and cumulative limitations.
Deadheads (DH)
Q: Do DHs not count toward your FDP?

A: DHs preceding a flight segment count towards your FDP. DHs that occur without a
preceding flight segment do not count. However, you are not at rest while on a DH. Any
pilot that has more than one deadhead, without an intervening 10hr rest period could
consider those deadheads as one period. 34
23
Q: When I am determining my FDP limit using Table B, do I use the deadhead as part of
the number of segments?
A: No. In the definitions of FAR 117 it is explained that deadheads are not considered a
flight segment when determining the FDP limit.
Q: Can the Company schedule a deadhead (DH) at the end of my assignment without that
being considered part of my FDP?
A: Yes. Provided there is no intent for you to act as a pilot in the remainder of that day,
there is no limitation on the number of hours you can be on a DH.
Q. Is there a limit to how long they can deadhead me?

A. A DH on the end of a day does not count as FDP. So as long as your FDP limits are
met, the DH could extend several hours beyond that. However, our Pilot Policy Manual
states that no pilot will be scheduled for duty greater than 14 hours without his/her
consent.
Q: Can I call in fatigued for a DH?

A: You can call in fatigued at any time you cant safety perform the duties asked of you as a
crewmember. 35
Fatigue Reports
24
When Congress mandated the FRMP they mandated the pilots have a non-punitive
program where they could report being fatigued. This program at SkyWest has been in place
for over two years. When a pilot reports fatigue it is the responsibility of the Company and
the pilot have the pilot removed from duty and given the needed rest to perform and
subsequent duty; calling fatigued will remove you from the trip but you will be expected to
return to your trip rested, if the opportunity is available. The fatigue report that is required
of the pilot after a fatigue call is adding data to our FRMP in an attempt to design and
overall operation that can best mitigate fatigue. This report is also what the Fatigue Pay
Committee (FPC) uses to evaluate whether to cover the pay of the fatigued pilot.
Documenting what the contributing factors of your fatigue event is important in the
collection of data on fatigue. It is essential that pilots accurately complete the Fatigue
Report Form (FPF) so that SAPA will have the data necessary to argue against policies that
contribute to fatigue.
When reviewing the FPC the first order of buisness is to categorize these reports into three
different root cause categories, Pilot, Operation, or Schedule.
Pilot reports are where SkyWest didnt contribute to event. Typically the pilot complains of
sick family members, inability to sleep, long commutes, etc. These reports are very rarely
paid. Please note crews that have trouble sleeping at overnight hotels due to loud noises or
other disturbances should try to mitigate the problem by calling security or switching rooms
if necessary, or both. The Company has not been sympathetic with crews that do not try to
mitigate problems. When reporting, please insure a detailed report regarding all steps taken
to mitigate the problem.
Operational reports are where the pilot is involved in IROPs and for reasons that are out of
their control the scheduled day becomes too fatiguing. Operational reports arent exclusive
to IROPs but most reports that are Operational are attributed to some sort of IROPs. When
reporting please insure a detailed report of all elements that contributed to the IROPs and
thus fatigue.
25
Schedule reports are normally when either PBS or CS creates a schedule where the pilot
accumulates too much fatigue to continue. Examples may be five stand-ups in a row, PBS
awarding six days of flying in a row, or PBS forcing pairings that have circadian disruption.
When reporting Schedule problems please detail how CS or PBS has created an unrealistic
or fatiguing schedule.
When writing a fatigue report it is crucial that you take the time to explain all the
extenuating circumstances that led to your fatigue call. We have seen a few reports where
there was either no narrative or not enough information to create a case that supported
paying the fatigue call. Our hopes are to convey to you how to write a quality fatigue report.
Once your Fatigue Report is submitted SAPA and management will review the narrative
you added to determine whether the Company will pay you for your fatigue event. The
Company will compensate you if the details leading up to the event were in essence a
liability on the Companys part, e.g. ATC delays, Mx delays, PBS creating an
overburdening schedule, etc. If the Company does not contribute to your fatigue event, e.g.
sick kids at home, long commute, broken down car, sickness, etc, they will not compensate
you. Review the three root causes above. Operational and Schedule are almost always paid
but Pilot is seldom paid. Use this information to aid you in your report and remember that
all fatigue calls that are not paid can be compensated with User Time if you elect for it.
Bidding and FAR 117:
As you know 117 can be far more fatiguing than what you could have flown in the Part 121
days. Keep this in mind when you are bidding and be sure to craft a bid that you can
handle. Do not use either the Waive Default Minimum Work Block (allows 30hr
overnights to count as rest in domicile) or Waive Max Block Time (removes the 28hr
block of block in 6 days limitation). If you bid for a schedule that will induce fatigue it will
be identifiable and the Company has not been sympathetic to such bidding practices.
26
SP 3006.8 Fatigue Calls is the SP governing what happens when a pilot calls in fatigued. As a
reminder for those who do call in fatigued, this SP provides options for pilots to reclaim
their trip once they are rested, as well as sitting reserve to insure pay is not lost. The Fatigue
Pay Committee has been successful in getting the majority of fatigue calls paid, but those
pilots who do not attempt to return to work in some fashion have been losing the pay that
the company feels would have been reasonable for that pilot to return reclaim. The
Company expects pilots to return to work as soon as they are fit for duty.
27
Works Cited
FOM Chapter 3 Flight Crew Requirements
http://www.skywestonline.com/menudocs/+fo.manuals/flight operations manual sp 3100/05_chapter3.pdf
Documents Associated with FAR 117 (pdf versions)

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/Part117/
Clarification of Flight, Duty, and Rest Requirements (March 5, 2013)

https://federalregister.gov/a/2013-05083
ALL LEGAL RULINGS CAN BE FOUND ON SWOL:
Wykoff and Mullen ALPA Legal Interpretation March 20, 2014

Wykoff and Mullen link
Mark Anderson, Teamsters Local Union 357, Legal Interpretation July 11, 2014
Anderson/Teamsters link
Manuel Garciglia, Legal Interpretation, July 8, 2014

Garciglia Link
28
FAA AC-117-3 5. Definitions, c

Final Flight Duty Rule C. Fitness for Duty
4
Flight Duty Clarification K. Reserve, ii. Short-Call Reserve 1. Determining What FDP Limit
Applies for Each FDP + Reserve Limit
5
Flight Duty Second Correction, February 6, 2013, Technical Corrections
6
FAA AC-117-3 14
7
117.27
8
Flight Duty Clarification B. Definitions, iii Flight Duty Period, 2 Meaning of Further
Aircraft Movement
9
Flight Duty Clarification B. Definitions, 2. Limitations on Duty, iii Flight Duty Period
(FDP)
10
Flight Duty Clarification G. Flight Duty Period ii Adjusting the Number of Flight
Segments
11
Flight Duty Clarification G. Flight Duty Period i Adjusting FDP Start Time, and FOM
Chapter, 3, E.2.f FDP modification.
12
Flight Duty Clarification M. Rest Period iii One-Phone Call Rule
13
Segments
14
Segments
15
Segments
16
Flight Duty Clarification J. Flight Duty Period Extensions
17
Final Rule Jan 4, 2012
18
AC 117-3
19
Flight Duty Clarification F. Flight Time Limitations, i
20
Manuel Garciglia, Legal Interpretation, July 8, 2014
21
Flight Duty Clarification C. Fitness for Duty, i Means of Certification
22
Flight Duty Clarification J. Flight Duty Period Extensions, v Using Multiple Extensions
23
Flight Duty Clarification J. Flight Duty Period Extensions, v. Using Multiple Extensions
24
Flight Duty Clarification J. Flight Duty Period Extensions, ii Diversions and FDP
Extensions
25
Flight Duty Clarification J. Flight Duty Period Extensions, iv PIC Concurrence in the FDP
Extension
26
Flight Duty Clarification C. Fitness for Duty, ii Certifying as to a Specific Flight
Segments
27
Mark Anderson, Teamsters Local Union 357, Legal Interpretation July 11, 2014
28
Flight Duty Clarification M, Rest Period
29
Flight Duty Clarification - M. Rest Period, i. Sleep Opportunity 1. Definition of Sleep
Opportunity
30
Flight Duty Clarification M, Rest Period, 2. Interruptions to the Sleep Opportunity That
Are Not Caused by Carrier v. Prospective Identification of a Rest Period
2
29
31
Flight Duty Clarification H. Split Duty, iii. Time Zone on Which Split Duty Rest is
Based
32
Wykoff and Mullen ALPA Legal Interpretation March 20, 2014 Section 11
33
Flight Duty Clarification H. Split Duty, iii. Time Zone on Which Split Duty Rest is
Based
34
Flight Duty Clarification - B. Definitions i. Deadhead Transportation 1. Length of Deadhead
35
Flight Duty Clarification - B. Definitions, ii Duty, 2. Limitations on Duty
30

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FAR 117 and Pilot Fatigue Guide

Fatigue Reports .............................................................................................................. 24

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

FAR 117 and Pilot Fatigue Guide REV 4,

FAA and Fatigue

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Transient is acute fatigue brought on by extreme sleep restriction or extended hours

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

FAA: Fatigue is characterized by

increasingly frequent lapses in performance,

Fitness for Duty

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Split Duty Trips (Standups)

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Cancelations and Cancelation Standby Status (CSS)

FAR 117 for Reserves

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q: What is the window of circadian low (WOCL)?

Q: Are there limits to scheduling a pilot during the WOCL?

Q: What is considered duty and will I be in an FDP every time Im on duty?

Q: Can you explain the difference of duty and an FDP?

Q: Am I on duty while on a Reserve Availability Period (RAP)?

Flight Duty Period: Unaugmented Operations

Q: Are the limitations of FAR 117 applicable to training?

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Adjusting the Number of Flight Segments 10

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q: Im on an overnight (or at home). The company is trying to notify me of a change to my

Q: Im on an overnight (or at home). The company is trying to notify me of a change to my

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q: If we taxi out and never takeoff, is this a segment?

Flight Duty Period Extensions 16 17 18

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q: How many extensions can we take if none go beyond 30 mins?

Q: So Dispatch can add as many extensions as they want?

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q: How do extensions affect landing at an alternate?

Q: What if we land at the alternate and need a Table B extension to continue?

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q: If we decline the extension will it be in essence calling in fatigued?

Q: If I decline the extension will I still be paid?

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q: Does my 30hrs free from duty need to be in my domicile?

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q: Can I be extended while on a Split Duty assignment?

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q: Is the rest opportunity in local time or domicile time?

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q: Do DHs not count toward your FDP?

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Q. Is there a limit to how long they can deadhead me?

Q: Can I call in fatigued for a DH?

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Bidding and FAR 117:

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

FAR 117 and Pilot Fatigue Guide REV 4, Sept 2014

Documents Associated with FAR 117 (pdf versions)

Clarification of Flight, Duty, and Rest Requirements (March 5, 2013)

ALL LEGAL RULINGS CAN BE FOUND ON SWOL:

Wykoff and Mullen ALPA Legal Interpretation March 20, 2014