Legal Interpretations
Johnson-ALPA 2005
Summary
The Question
Is 14 CFR 121.471(g) an exception to the compensatory rest requirements of 14 CFR 121.471(c) when weather delays occur?
Background
The Air Line Pilots Association asked how the compensatory rest provision of 14 CFR 121.471(c) applies when a pilot experiences weather delays.
The FAA’s Interpretation
No. 14 CFR 121.471(g) is an exception to flight time limitations, not to rest requirements. A pilot who knows before departing on the last segment that weather delays will prevent release to begin compensatory rest within 24 hours after the reduced rest period began may not depart. A certificate holder may still reduce rest under 14 CFR 121.471(c)(1), (c)(2), and (c)(3) if compensatory rest is given during the next rest period.
- Requester
- Johnson
- Organization
- ALPA
- Issued
- July 15, 2005
- Subject
- Flight & Duty Time
Regulations Cited
Page 1
U.S. Department
of Transportation
Federal Aviation
Administration
Mr. James W. Johnson
Managing Attorney
Air Line Pilots Association, Intl
535 Herndon Parkway,
P.O. Box 1169 Herndon, Virginia 20172-1169
Dear Mr. Johnson,
This letter is in reply to your July 15, 2005 letter concerning the application of the compensatory rest provision of 14 CFR 121.471(c) when a pilot experiences weather delays. In essence, you ask if 14 CFR 121.471(g) is an exception to the compensatory rest provisions of section 121.471(c). As stated in prior letters of interpretation, section 121.471(g) is an exception to pilot flight time limitations; it is not an exception to rest requirements.1 Therefore, a pilot, who knows prior to departure of a last segment of a schedule, that he will not arrive and be released so he can begin compensatory rest no later than 24 hours after a reduced rest period begins, because of weather delays, may not depart on the last segment. However, as you are aware, section 121.471(c) is structured so that a certificate holder may reduce rest requirements in paragraphs 121.471(b)(1), (b)(2), and (b)(3). Therefore, although a certificate holder may not use section 121.471(g) to reduce rest requirements, a certificate holder may use paragraphs 121.471(c)(1), (c)(2), and (c)(3), to reduce rest as long as compensatory rest is given during the next rest period.
We trust this interpretation answered your questions. This letter was prepared by Douglas Mullen, Attorney, reviewed by Joseph Conte, Manager, Operations Law Branch of the Office of the Chief Counsel and coordinated with Flight Standards Service.
Sincerely,
/s/
Rebecca B. MacPherson
Assistant Chief Counsel, Regulations Division 1 See October 29, 2002 Letter to James W. Johnson, from Donald P. Byrne, Assistant Chief Counsel, Regulations Division [2003-6] (copy enclosed); Air Transp. Ass’n of America v. FAA, 291 F.3d 49, 52 n.3 (D.C. Cir. 2002); January 11, 2005 Letter to Jan Marcus, from Rebecca MacPherson, Assistant Chief Counsel, Regulations Division [2005-1] (copy enclosed).
800 Independence Ave., S.W.
Washington, D.C. 20591
Regulations Referenced
Snapshot retrieved August 6, 2026.