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PHD. MBA. MHS. Type rated on A350, A330, B777, B747-400, B747-200, B757, B767, B737, B727. International Airline Pilot / Author / Speaker. Dedicated to giving the gift of wings to anyone following their dreams. Supporting Aviation Safety through training, writing, and inspiration. Fighting for Aviation Safety and Airline Employee Advocacy. Safety Culture and SMS change agent.

Tuesday, August 19, 2014

FAR 117 Reality

"I'm so @#!*ing tired since FAR117!" 

I am the most avid commuter there is for someone based at home. I travel the airways (in the flightdeck) to see grandchildren, for FAA testing, school, Oshkosh and many other other aviation events. I have talked to many commuter pilots and the conversation is always the same...FAR117 has had an opposite effect.

One of the pilots I met along the way recently wrote sharing his story.

"I have been working as an first officer for almost 8 years. I was able to credit 90 hours or more every month for 5 years without any need for energy supplements. Then after FAR 117 was implemented, I have had to work more days, and found myself feeling more tired due to the changes in our work schedule. My seniority has only gotten better during this year, but my schedule has gotten worse.  

The new work rules have forced us to work longer days for less pay, and that in turn forces me to spend even more long days at work than I had in the past. None of this is due to some greedy corporation trying to squeeze me for more labor.  It's all because a bunch of politicians jumped in an made laws concerning a subject that they couldn't possibly understand.  I now find myself struggling to spend time with my family, and I keep a bottle of energy mix in my flight bag to help me through the long days and odd hours at work" 

An International pilot told me he was flying a short flight, 6 hours and 39 minutes from the East Coast to Europe. This flight actually required a single crew, but they were dispatched with three pilots. He wanted to take first break, as he did not sleep well in the hotel. It was 8 pm and he could have fallen to sleep for a good nap, and been in the seat with ample time to be refreshed for landing. However, due to FAR 117, he could not be in the seat for more than 2 hours prior to landing. 

Sometimes decisions are made in error. When they are, we need to fix them. Does anyone know how to change an FAR?

How has FAR117 been treating you?

Enjoy the Journey...If you can stay awake for it!
XO Karlene

Author of Flight For Control and Flight For Safety,
If you haven't read's time!


  1. Hmm, I am not for sure how I would fix a FAR, or this one in particular, but have had experience with people that perceive themselves to know what is best for everyone involved and implementing rules that do much more damage than good.

    My question is, do union reps/presidents have a say in these (new) rules or have more pull to get these FARs removed and or changed?

    Welcome back, I Hope your week went well last week... we'll definitely catch up!!

    1. Excellent question! I think they "over" reacted and created something unreasonable without thinking it through. A good start would be going back to what we did prior to this, and assuring we have proper rest facilities on every plane.
      Thanks for your comment. And...that was the best statement... "how to" fix it.

  2. Karlene,
    Every pilot I know including myself has expressed being MORE fatigued under FAR 117. While there's always a learning curve with new laws and procedures, this has mucked up everyone's schedules so bad that I don't see an end except for an extreme makeover.

    I thought this was a telling line: "The new work rules have forced us to work longer days for less pay...all because a bunch of politicians jumped in and made laws concerning a subject that they couldn't possibly understand."

    Bottom line: Clueless politicians making political decisions about things they know nothing about (but perhaps sounds good to the public)=LESS SAFE SKIES!

    1. I learned there is a way to change regulation. Part 13. I'm going to investigate and we're going to make this happen. Apparently there was at least one pilot on the committee... perhaps more. It's a shame they did not have the foresight to see the impact. Thanks so much for your comment.

  3. PS--another annoying aspect of 117 is the requirement for flight crews to sign a statement that they are "fit to fly." This is an obvious cave-in to the air transport industry to take the blame off them and hang it around pilots. Yes, of course we are responsible, but it's basically a contract saying if anything's the LITTLE GUY'S FAULT!

    1. Yes... I have to laugh. (Or cry) Half way through my flight if I did not sleep in the seat, I say, "I want that paper back. I changed my mind." We'll work on this for sure!

  4. I think about this every single day.

    Should politics take over aviation? Or aviation should have its own political power?

    Let's not forget aviation is an industry. Naturally, industries are under political power. Think about this:

    Air Transport is so intercontinental, so international and so global... It involves so much about diplomacy, humanitarian ethics, world trade...

    Politics impounds regulations and restrictions to aviation. This naturally affects the industry's capital rotation and growth. Not to forget working environment conditions to its employees.

    Turns out this discussion becomes part of a subject called "industry consolidation". And this is what IATA is striving for. It is a goal set to 2050.

    We are constantly discovering the air transport industry is "infected" by excess of "local" (meaning each country) political intervention, and we don't want this.

    What we want is to our industry become independent from overpowering political intervention methods, generate its own freedoms in a consensus with general and united political agreements, in a manner that politics does not overprotects aviation.

    And I'm not forgetting about safety - just to let you know.

    If this really happens, perhaps aviation will receive some classification other than "industry".

    This is probably the main point of the grand issue.

    I could go on... But it's too much writing for a comment section.

    Very complex. This is what I'm passionate about.


    1. Alex, I love the visual of "infected." I believe they only know what they know. And until they lived the life...they cannot possibly know, especially when the process is not thought out. This is the reason I am getting my PhD, so I can learn how to think critically, take into account all ramifications and ask... "what if." Then I will be headed to Washington to help keep our industry on task and bring some insider knowledge and a bit of thought behind reform.

      Thank you so much for the comment!!

    2. So we have similar intentions.

      You're heading towards your PhD. I'm heading towards my Research & Development platform, so I can head towards my PhD.

      We'll change it. We can only change it if we defy them.

      And it's like you've been telling all of us, this industry is constant learning. There won't be a point where someone or some entity will master it.

      But we can head to this direction, that's for sure.


    3. ALX, that is the exact point... always striving towards as we will never be. One interesting thing about the PhD...this is all about adding to the body of knowledge. Just a drop at a time. Hopefully I can leave that drop and you will carry it forwards with thousands of other drops to success. I know you will!

  5. Your best option at implementing change within FAR 117 is to work with ALPA and A4A. Both organizations have staff and lobbyists skilled at dealing with The Hill and FAA. Start a grass roots campaign, start with maybe 1,000 commercial airline pilots, or more, then take that to ALPA and A4A and have them do what they are paid to do ... bring awareness and lobby.

    1. Thank you Steven, do you know if ALPA and A4A are doing anything with this? I think there is a process to create change. Support is a good thing if we can bring them to the table on this.

  6. 117 is a total screw up. It's full of ironies.
    Two pilots can fly a 7:59 flight by themselves - no rest. But if three pilots happen to be on the same flight then, not only is in-flight rest required, but the pilot doing landing MUST be provided with a break opportunity in the last half of the duty period - which means he/she has to have the last of the three breaks. So two pilots - pilot flies 8 hours for landing,three pilots (same flight) he's not allowed to make it 2 hours. Or on a long flight, the pilot landing can be in the seat for three or more hours before landing, but on that short flight he can't - hu?
    Now also let's think about what it takes to compute that "two hours in the second half of the duty period." Sounds easy enough until you try to figure it out without a spreadsheet!
    Figure out the half time point between the time you report for duty and the time you'll block in. Then calculate the time that each break will start remembering to factor in taxi-out and taxi-in time, the non-break time before the first break and after the last break,yielding the breakable portion of the flight. Divide the breakable time by the number of pilots, then compare the times for each of those breaks with the half time value figured in part 1, to determine how much of each break falls on the back side of that mid point. Make sure it's at least 2 hours
    Note that this is required and how tired you really are is not a factor, your body clock—not a factor. Climbing in the seat at top of descent to be the PF for landing—not a factor. When the crew rest area will be quite enough to actually sleep—not a factor. Don't worry,the committee will decide when you'll be tired.

    117 was conceived as an answer to the Colgan Airlines crash where the FO had commuted across the country and had slept in the crew room. The result of 117 is that it ends up making pilot commute MORE!
    A 14 day trip is OK, but not a 7 day trip back to back with another trip of ANY length.
    This absurdity could only be conceived by people who have never actually crewed a long international flight. It should be repealed.

    1. Bill, I'm in Amsterdam and just awoke...still groggy... from my nap, and I am laughing so hard. You answered the spread sheet dilemma and why I could never figure out the mid half of the first half of the break...because NY or Amsterdam... taxi could be 10 minutes or 45, which throws the entire number gyration off of whose on first and what's on second.

      During my human factors class this quarter we will discuss this issue. And... I am in the process of figuring out how to get rid of it. When I do...we will.

      Thanks for the great comment!


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