Originally Posted by
mach85
Garret,
From your understanding, in2019 the limit will be 900 hours for all airlines or from 31st December 2019, you must comply with subpart p meaning effectively your 900 hr limit begins from 2020?
Cheers,
The way I understand things is this:
1) the regulation must be implemented no later than 31-Dec-2019, (It may be implemented earlier).
2) the old limitation under R4 of the regulations had a 1000:00 limit in a Calendar Year, (So up through 23:59 on 30-Dec-2019 the total flight time since 00:00 01-Jan-2019 may not exceed 1000:00)
3) the new limitation of 900:00 is effective 31-Dec-2019, (So up through 23:59 on 31-Dec-2019 the total flight time since 00:00 01-Jan-2019 may not exceed 900:00)
4) those crew members who have accrued more than 900:00 in 2019 would not be permitted to resume flying until 01-Jan-2020 (the start of the next calendar year).
The specific limitation in CCAR 121.487 (B) is a
Scheduled Limitation.
Personally, I think CAAC should have gone with a 1000:00 limit in a 365 day limit, doing so would:
1) follow international standards under FAA/EASA and CASA 2) require a fairer distribution of flight time across rosters, under the calendar year rule, can exceed 900:00 or even 1000:00 between 01July2019 to 30June2020, this sort of defeats the purpose of combating fatigue via prescriptive regulations.
Sorry to have gotten back so late./Garret