FC5222

CHIRP passed on our concerns about the use of extended FDP in this way to the CAA and they engaged with the company. However, due to commercial considerations, the CAA do not pass on to CHIRP explicit details of follow-on associated discussions or data about specific concerns such as this other than to confirm that oversight activity has been conducted.

More generally, extended FDP allows the maximum basic Flight Duty Period for acclimatised crew members to be increased without the use of in-flight rest – this equates to an additional hour being applied to the basic FDP. Basic FDP may be extended not more than twice in any 7 consecutive days and must include either a pre- and post-flight rest extension of 2 hours, or a post-flight rest increase of 4 hours.  Extended FDP must be planned in advance.  If commander’s discretion is then applied to an extended FDP, then the maximum FDP from the basic FDP table is used to calculate the limits of discretion as shown in ORO.FTL.205 Flight Duty Period (FDP) (d) & (e)shown below.

ORO.FTL.205 Flight Duty Period (FDP)

(d)  Maximum daily FDP for acclimatised crew members with the use of extensions without in-flight rest.

(1)  The maximum daily FDP may be extended by up to 1 hour not more than twice in any 7 consecutive days. In that case:

(i)  the minimum pre-flight and post-flight rest periods shall be increased by 2 hours; or

(ii)  the post-flight rest period shall be increased by 4 hours.

(2)  When extensions are used for consecutive FDPs, the additional pre- and post-flight rest between the two extended FDPs required under subparagraph 1 shall be provided consecutively.

(3)  The use of the extension shall be planned in advance, and shall be limited to a maximum of:

(i)  5 sectors when the WOCL is not encroached; or

(ii)  4 sectors, when the WOCL is encroached by 2 hours or less; or

(iii)  2 sectors, when the WOCL is encroached by more than 2 hours.

(4)  Extension of the maximum basic daily FDP without in-flight rest shall not be combined with extensions due to in-flight rest or split duty in the same duty period.

(5)  Flight time specification schemes shall specify the limits for extensions of the maximum basic daily FDP in accordance with the certification specifications applicable to the type of operation, taking into account:

(i)  the number of sectors flown; and

(ii)  WOCL encroachment.

(e)  Maximum daily FDP with the use of extensions due to in-flight rest Flight time specification schemes shall specify the conditions for extensions of the maximum basic daily FDP with in-flight rest in accordance with the certification specifications applicable to the type of operation, taking into account:

(i)  the number of sectors flown;

(ii)  the minimum in-flight rest allocated to each crew member;

(iii)  the type of in-flight rest facilities; and

(iv)  the augmentation of the basic flight crew.

But there are penalties to a company for using extended FDP rather than commander’s discretion due to the additional rest periods required. The reporter’s comments that this particular company were using extended FDPs to avoid having to report discretion (which is a mandatory reporting requirement to the CAA for periods exceeding 1 hour) was therefore of interest. Asked what the CAA does with discretion reports, the CAA commented that if the actual operation of a route exceeds the maximum FTL for 33% of the times that a route is flown in a scheduled season then they require the operator to make changes to the route structure (ORO.FTL.110 (j) refers).