Anonymous

Ref117.3 Definitions, The NPRM details a definition of Unforeseen operational circumstance. Unforeseen operational circumstance means an unplanned event beyond the control of a certificate holder of insufficient duration to allow for adjustments to schedules, including unforecast weather, equipment malfunction, or air traffic delay. Ref 117.13 Flight time limitation.No certificate holder may schedule and no flightcrew member may accept an assignment or continue an assigned flight duty period if the total flight time: (a) Will exceed the limits specified in Table A of this part if the operation is conducted with the minimum required flightcrew. The NPRM does not appear reference actual flight times when actual distant alternates are required due to known and foreseen weather conditions. Example: The flight time limitation are 9 hours per table A and a scheduled flight is scheduled from ABC to XYZ for 8:45 - within flight time limitations of the table Then during preflight it is calculated that the actually flight would be a 8:50 flight and then due to a forecast and foreseen conditions a planned required alternate is required which is an additional possible 1 hour flight duration for a total of 9:45. This would place the possibility of the actual flight to overfly the flight time limit of table A. 1. Must the operator and flight crews take the additional possible flight time to an alternate into account when calculating the maximum permitted flight time when during preflight planning, the conditions would be actually be forecasted and foreseen? 2. Since the actual conditions would be known and foreseen prior to the flight, would the FAA consider the conditions to be within control of the certificate holder and require changes such as but not limited too assigning additional augmented crews to take into account actual conditions? 3. Does a pilot in command retain authority to request crew augmentation if the actual flight may exceed limits of table A.