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SOME QUESTIONS AND ANSWERS FOR COMMERCIAL OPERATORS 
(CONCERNING CARs 700.14 - 720.23)

 
Q.  Does FLTDUTY accommodate the newest amendments to the CARs in SOR 2018-269?

A.  No.  FLTDUTY was modified in December 2020 to remove airline 705 operations from calculations for compliance.  The new regulations, limits and options were implemented for 705 airline operations only.  703 air taxi and 704 commuter operations will have 2 more years - until December 12, 2022 - to continue with the old rules.  FLTDUTY will calculate compliance for these operations plus 702 and 604 private operations which will remain unchanged.  Archive records prior to Dec 12/20 for 705 operations will continue to calculate and display as before.  Flight time in 705 operations can still be recorded and will be used for total flight time calculations.

 

Q.  I was issued Commercial and Business Aviation Advisory Circular No. 0241 on 2005.03.18 advising that some duty time software does not properly address required rest issues from CARs 700.19.  Does FLTDUTY XLS correctly apply the Regulations and Standards in this area?

A.  Yes.  In response to the CBAAC 0241, this software was revised to take into account the commonly enforced requirements outlined in the guidance material to inspectors.  This content can be viewed at http://www.tc.gc.ca/eng/civilaviation/standards/commerce-manuals-guidance700-menu-1872.htm under Guidance Materials R740.19.  Within this document are additional conditions and restrictions for enforcing the CARs and Standards in this and other sections.  The FLTDUTY software will apply the conditions for using the two options for required rest in a 704/705 or On Call operation as outlined there.  Some detail can be seen in CBAAC No. 0170R 2004.05.12 where the options and the method for alternating between options are described.  Additional restrictions are described in the guidance material.

FLTDUTY is programmed to allow either Option a or Option b with either a 17 day cycle following a 3 date (or 80 hour) rest or a 7 day cycle following a 36 hour rest.  Either option can be scheduled.  A 3 date or 80 hour rest must precede any duty period longer than 5.5 days without at least a 36 hour break and a 3 date or 80 hour rest must precede reverting back to a 7 day/36 hour cycle whenever there was a stretch of duty longer than 5.5 days without at least a 36 hour break.  The Next Mandatory Day Off as indicated by the program will always be the latest that can be scheduled under the circumstances.  Any earlier rest may affect the Next Mandatory Day Off warning as well as the cycle of rest in effect.  

 

Q.  What is the maximum flight time a pilot can log over a 30 day period?

A.  According to CARs 700.15 (1) (c) the answer is 120 hours in any 30 day period.  There is an exception quoted here for the case if the pilot that has been designated as being on call.   (Defined as available for flight duty from an unspecified location within 1 hour or less).  In this case the 30 day limit is reduced to 100 hours.

Under the Standards, however, in CARs 720.15 (1) (c) under certain conditions this limit is raised to 150 hours.  These conditions are:  The operator must have Operations Specification 092 included in his Transport Canada Operating Certificate.  You can use the higher limits if the flight is air taxi or aerial work (Subpart 2 or 3) or DHC-6 not scheduled passenger service or helicopter operations except for scheduled passenger carrying and heli-logging; for a maximum of 6 non-overlapping 30 day periods within each 365 day period.  This means that if you use these upper limits, from the first time you used them in the previous 365 days, in 30 day blocks that do not overlap (but are not necessarily consecutive without a gap) from that date, you must have used them in less than 6 of the 30 day blocks in order to be able to use these high limits now.

Heli-logging operations are limited to 120 hours for single-pilot operations and 150 hours for two pilot operations (720.15 (2)).

None of these flight time totals are the actual flight time in the previous 30 days.  After a 5 consecutive day break, the accumulating total for 30 days, with respect to the CARs, can be re-set to zero (720.15 (1)(g)) under certain circumstances in certain types of operations.  In which case a pilot could fly to his limit, take 5 days off, and be able to fly to the limit again.

Under an exemption now in place (since May 1/02) non-scheduled 704/705 operations can extend their 30 day flight time limits to 135 hours during the summer months.

 

Q.  What is the minimum overnight rest a pilot needs?

A.   According to the CARs definitions, the basic minimum rest is 8 consecutive hours in suitable accommodation (single occupancy bedroom) plus any additional rest required by the CARs following any flight duty period (700.16 (3)).  Factors that require additional rest include - extensions to flight duty time as a result of a split duty assignment (700.16 (6)); extension of flight duty time as a result of flight crew positioning (700.20); long range flights (700.22 (1)); if the operator has Operations Specification 093 included in his Transport Canada Operating Certificate, then increased daily flight duty time to 15 hours (after more than 8 hours of flight time) (720.16 (1)(a)); extended flights with additional flight crew (720.16 (2)(b), (3)(c)); unforeseen circumstances extending flight duty time (720.17 (1)(a)); and early recall from reserve status (720.21 (2)(b)).  These extensions can add from 1 hour up to the length of the previous flight duty period to the required rest.

The minimum rest period of 8 consecutive hours does not apply to aerial application operations if Operations Specification 093 is in place.  The required rest for these pilots is 9 hours within each 24 consecutive hour period to be taken at least 5 consecutive hours between 2000h and 0600h local time and the remainder to be taken in suitable accommodation (720.16 (5)(b)(c)). 

 

Q.  What is the maximum flight time a pilot can log in a day?

A.  There is no general limit for flight time in a 24 consecutive hour period in the CARs.  Flight time would normally be limited by flight duty time and, except for long range flights with additional flight crew (who all log the entire flight, even when asleep) (720.16 (4)) and extended flight duty times due to unforeseen circumstances, would be close to 14 or 15 hours depending on whether Ops Spec 093 was in place.  The exception to this is single pilot IFR operations limited to 8 hours flight time (700.15 (1)(f))

 

Q.  What is the longest stretch a pilot can go without a day off?

A.  A pilot working in an air taxi or aerial work operation can be assigned up to 42 consecutive days without a day off with Ops Spec 094 in place (720.19 (1)(a)).   In contrast, any pilot who is designated as On Call must have at least 36 consecutive hours free from duty within each 7 days or failing that is required to have 3 consecutive dates off every 17 days (700.19 (1)(c)) or 80 consecutive hours.  To put this in perspective, a float pilot could be assigned to work on May 1st, fly 5 hours a day, not get a day off until June 12th and not be considered fatigued.  But a charter pilot sitting at home with his pager on would be technically fatigued by Saturday at noon if he went on duty Monday (or be entitled to a long weekend every 2 weeks).

The maximum stretch of 42 days without a break is only available to aerial work and air taxi operations after a 5 consecutive day break and must be followed by a 5 consecutive day break.  With these limitations, this option is only available for a very restricted period.  The normal maximum stretch without a break would be 27 consecutive days in order to comply with the 3 days off in each 30 day period (700.19 (1)(b)).  This stretch would need to be followed by 3 consecutive days off.

All commuter operations must observe the same time free from duty requirements as a pilot On Call.  That is, at least 36 consecutive hours off within each 7 day period, or failing that, 3 consecutive dates off in each 17 day period (700.19 (1)(a)) or 80 consecutive hours.  (Under new exemptions and proposed amendments to the CARs, remotely deployed 704 operations may use a 4 consecutive date rest to work a 19 day cycle; or if non-scheduled 704 during the summer, establish a 12 day cycle with a 48 hour rest.)  Generally, the longest stretch that a commuter pilot can go without a day (3 days) off is 14 consecutive days.
 

Q.  What is the difference between On Call and On Standby?

A.  The only difference in the definitions is that a specific location is associated with the On Standby condition.  On Call is for a pilot designated to be available for flight duty on notice of 1 hour or less.  An example of this would be any pilot wearing a pager who is expected to respond and be ready to fly within an hour of being paged.  On Standby is for pilots who report for duty but are not necessarily going on a flight.  An example of this would be any pilot who reports to the operations base and is expected to perform other duties while waiting to be dispatched on a flight.

The difference operationally is that any pilot On Call has his time free from duty limits set at the most restrictive - that is those for commuter operations - no matter what the actual type of operation.  On Call is not considered flight duty time but is also not considered time free from duty for purposes of determining flight duty time limits and time free from duty requirements.  On Standby is considered flight duty time and flight duty time limits apply as well as time free from duty requirements even if there was no flight time associated with the flight duty time.

A clarification proposed to be included in future CARs allows any period where the On Call response is greater than 1 hour will be considered time free from duty and any 24 hour period of greater than 1 hour call in will be considered a day off.

 

Q.  Does time off for weather and maintenance count as time free from duty?

A.  Yes.  Time spent not on actual flights can be time free from duty if it is specifically assigned as such.  Once a pilot is released from duty, including being available for duty (as in On Call or On Standby), he is on time free from duty.  If a weather assessment or maintenance condition during the day determines that the pilot will have no further duties (flight duties or other duties), and he is released (not restricted to any specified location), his time free from duty starts with his notification of his release.  If he is on more than 1 hour recall, the time is considered free from duty. 

In order that the rest required from the previous flight duty period be satisfied, the time free from duty must be at least 8 hours plus any additional requirements for special circumstances, if any.  If the time free from duty turns out to be less than 8 hours, the required rest for the previous flight duty time has not been met.  In this case the total duty time will extend from the initial report for duty time to the final released from duty time, including the time free from duty (that was less than 8 hours) and the rest can be attributed to a split duty assignment, if it qualifies, and total flight duty time can be appropriately extended although the subsequent required rest will also be extended.

Aerial application operations using the split duty assignment option after less than 8 hours overnight rest must allow for the remainder of the required rest in suitable accommodation (single occupancy bedroom) not just released from flight duty.  Other operations using the extended flight duty time split duty assignment with a rest during the flight duty period must allow for at least 4 hours of rest in suitable accommodation (700.16 (5)(b)).

 

Q.  Does layover time between charter flights away from base count as flight duty time?

A.  Yes.  As long as a pilot is expected to be at a certain place (the airport) or is available for a flight on 1 hour call or less, it is considered flight duty time on standby.  If an extended layover is expected that will put the flight duty time over the limit, a split duty assignment can be made if the pilot is allowed at least 4 consecutive hours rest in suitable accommodation (single occupancy bedroom) (700.16 (5)).

 

Q.  What happens if the rest during a split duty assignment extends to 8 hours or more?

A.  Following any flight duty period the requirement is for at least 8 hours rest.  (700.16(3))  Exceptions to this are covered by extending the flight duty period by using the split duty assignment so that a rest period that is less than 8 hours is actually considered part of the flight duty time and longer totals are allowed.  If the required rest following a flight duty period is given (at least 8 hours) then there is no need for the split duty requirements to come into play.


 

Q.  If I have a split duty day under Subpart 2 aerial application operations, when do I need to get the 5 days off in 30 days rather than 3 days off in 30 days?

A.  You must be able to show 5 days off in the previous 30 days to use the split duty option.  From the first instance of split duty assignment and until the last split assignment, you must show 5 days off in every 30 days.

 

Q.  If I have more than 100 hours flight time in the previous 30 days and need to go On Call, what are my options?

A.  On Call is not available after 100 hours of flight time in 30 consecutive days (700.15(1)(c)).  There is no such limit on standby time.  If you have more than 100 hours flight time in 30 consecutive days, you must accept standby and accumulate flight duty time.  This may not necessarily mean sitting around the airport.  Your specified location may be a 100 mile circle around the base, but you will be limited to the flight duty time maximums appropriate at the time (usually 14 or 15 consecutive hours).
  

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