Legal Interpretations
Snieder 2017
Summary
The Question
On augmented flights with several segments in one flight duty period, does the two-hour in-flight rest requirement of 14 CFR 117.17(c)(1) apply only to the final landing?
Background
A requester described United Airlines augmented pairings from Guam with two or three segments in a single flight duty period, some with landings in its first half, and asked how 14 CFR 117.17(c)(1) rest applies.
The FAA’s Interpretation
Yes. The preamble to 14 CFR part 117 makes clear that 14 CFR 117.17(c)(1) applies only to the pilot making the landing on the final segment, so two consecutive hours of in-flight rest in the second half of the flight duty period must be available to the pilot who actually flies the final landing. Separately, 14 CFR 117.17(c)(2) requires 90 consecutive minutes for the crewmember performing secondary monitoring duties during the final landing.
- Requester
- Snieder
- Issued
- January 5, 2017
- Subjects
- Flight & Duty Time · Definitions
Regulations Cited
Unreadable text from the scan (such as a barcode or stamp) is left out of the text below; the original letter shows it exactly.
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U.S. Deportment
ot Transportation
Federal Aviation
Administration
JAN.- 5 2017
Dear Mr. Snieder:
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington, D.C. 20591
This letter is in response to your August 25, 2016 request for a clarification of 14 C.F.R. § 117.17(c)(l) as it applies to the two-hour consecutive in-flight rest requirements for the flightcrew member flying the airplane during landing of augmented crew operations consisting of multiple flight segments. Specifically, you asked whether that regulation applies only to the final segment of a flight duty period ("FDP") comprised of two or three flight segments.
Section 117.17(c)(1) prohibits a certificate holder from assigning and a flightcrew member from accepting an augmented crew assignment unless, during the FDP, "[t]wo consecutive hours in the second half of the flight duty period are available for in-flight rest for the pilot flying the aircran during landing." In context, the preamble to the final rule for part 117 makes clear that § 117.17(c)(1) is intended to apply only to the pilot making the landing on the final flight segment of an augmented flight. See 77 FR 363- 367. Thus, in each of the three scenarios you posed, involving augmented flights with more than one scheduled landing within a single FDP, the two consecutive hours of in-flight rest in the second half of the FDP must be made available to the pilot flying the aircran during the final landing.
You also asked whether the two-hour rest requirement in§ 117.17(c)(l) applies only to the pilot at the controls on the last landing of the FDP. Section 117.17(c)(l) applies only to the pilot "at the controls"-that is, the flightcrew member who actually flies the aircraft during the final landing. In contrast,§ 117.17(c)(2) requires that ninety (90) consecutive minutes of in-flight rest be made available for the flightcrew member who will be performing the secondary monitoring duties on the flight deck during the final landing. See 77 FR 367.
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We appreciate your patience and trust that the above responds to your concerns. If you need further assistance, please contact my staff at (202) 267-3073. This letter has been prepared by Richard Doan, Operations Law Branch, Office of the Chief Counsel and coordinated with the Air Transportation Division of Flight Standards Service.
Sincerely,
Lorelei Peter
Assistant Chief Counsel for Regulations, AGC-200
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Lore lei Peter, Acting Assistant Chief Counsel
Regulations, AGC-200
Fe,deral Aviation Administration
800 Independence Avenue, S. W.
Washington, DC 20591
Re: Request for Inrerpretation ofFAR ll7.17(c)(l)
Dear Ms. Peter:
This is to request clarification of FAR 117.17(c)(l) as it applies to the below described examples:
In the "Nelson" Interpretation dated Sept 3, 2015 you. state:
"The answer is yes. for those/lightcrew members who are flying the plane during landing. T/uJJ flightcrew member would have lo take the second break. although it would not have to be the foll 6 hours and 30 minutes-only the two consecutive hours are reLJutred by the rule for the individualjlying the plane during landing. Iftheflightcrew member is monitoring the aircraft during landing, ninety minutes are Y.etJUfred during the course ofthe flight and the break could be taken at any point. " I believe the "Nelson" letter only addresses a single lcfifscgmcnt augmented operation. My question is: How must rest occur on a multi-leg single Flight Duty Period augmented flight? The following three examples of pairings are cummtly being flown under FAR 117:i 7 by United Airlines in the Guam base and consist of either two or three flights/segments during a single FOP in augmented operations. Pairing/ID 05012 below contains two scheduled landings in the FOP with the first landing occurring in the first half of the FDP. Pairing/ID 05024 has two of the three landings in the first half of the FDP. Pairing/ID 05025 has one landing in the fust half of the FDP and the second and third scheduled landings occwring in the second halfof the FOP. All of these flights/segments are operated in augmented operation with three crew members utilizing a Class 3 rest facility under Table C limits.
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Lorelei Peter, Acting Assistant ChiefCounsel
November 2, 2015
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EQP FLT# DPT ARV DPTR ARVL GRND ML FTM ACM DTM lND DIC ---·------------------...-----------... -------;---------------- EFF 11/06/15 THRU 11/27/l 5 m:~~![)'fa - BASIC (PAC)
RPT: 0630
732 187 GUM CfS 0730 1125 LOO B 4.55 4.55
732 188 CTS GUM 1225 1805 L 4.40 9.3512.05 .00
RPT: 1745
73Z 193 GUMROR 1845 1955 .55
73Z 193 ROR MNL 2050 2235 .55
73Z I.84 MNL GUM 2330 0520
RLS:0550
2.10 2.10
2.45 4.55
3.50 .8.45 12.05
EFF 10/30/15 THRU 10/30/15 @~.0.25-BASIC (PAC)
RPT: 1800
73U 183 GUM MNL 1900 2050 .55 3 .50 3 .50
73U 192 MNL ROR 2145 0140 .45 2.55 6.45
73U 192 ROR GUM 0225 0530 2.05 8.50 12.00
RLS: 0600
DAYS- 2 CRD- 8.50* FTM- 8.50* TAFB- 12.00 INT- 8.50 NTE- .00 M$- 27.00 TIC- .00 .11 * FAR.117.17 states that: "1Wo consecutive hours in the second halfofthejlightduty period are available for in-flight rest for the pilotflying the aircraft during landing. " However, it does not define whether "landing" is the final landing ofthe· FDP, any specific landings within the FDP or all lanilings that occurs wi~ the augmented FDP. This raises the questions below for the operations currently being conducted at United Airlines in Guam. I.. On an FAR 117. l 7 augmented flight, if there are more than one scheduled landing contained within a single FDP:
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Lorelei Peter, Acting Asi.'istant Chief Counsel
November 2, 2015
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a. Would the landing pilots on all of the landings be required to have their rest ·in the second half of the FDP as indicated in the Nelson interpretation dated September 3, 2015? lfthe answer is yes, how is that possible since the .first landing occurs in the first half of the FOP? If the answer is no, when does the FAA expect the landing pilots on the first landing to obtain rest, if at all?
Would the landing pilots on segments 2 of 3 be required to have their rest in the second half of the FDP? If the answer is yes, how would the landing pilots obtain rest prior to landing 2 of 3 in these examples since there may not be two hours of time available in the second half of the FDP prior to the scheduled landing?
Does the 2~hour rest rule in the second half of the FDP only apply to the pilot at the controls on the last landing of the FDP?
Your prompt response is appreciated. If you need any additional infonnation, please contact me. s(J;·~1y,/ -.
I . ( c
Aiil:liony Snieder
Regulations Referenced
Snapshot retrieved August 6, 2026.