New GCAA Flight Time Limitations - It Could Not Be Any Worse
 

Heres an Extract from the GCAA Website

NPA 25-2014 CAR OPS1 - COMMERCIAL & PRIVATE AIR TRANSPORTATION (AEROPLANES)

https://www.gcaa.gov.ae/en/epublicat...s.aspx?dd=2759

The NPA closed 30th Nov 2014 with only two comments neither related to this huge policy change by the GCAA, which has been slipped through.

The two major UAE Carriers just got a massive New Years gift because in the coming months a return trip to New York will be LESS Hours than a London Heathrow.

In other words you can operate 4 USA ULR's, and still have time for 3 * Europe trips, Its quite staggering this has gone un noticed.

The Duty time limit means they can now roster you in effect as many working hours as an office worker with no regard whatsoever for time zone changes and the need to have any form of a life.

The interesting point is para in the NPA that says "Note: Unless otherwise specified, the UK Civil Aviation Authority document Civil Aviation Publication, CAP 371 and its applicable parts, with associated amending notices, shall be the basis of assessment of operator schemes"

How the below complies in any part with CAP 371 staggers the imagination.

The plot has truly been lost in the UAE ,


The NPA reads as follows :-

CAR-OPS 1.1125 Absolute Limits on Flying Hours

(a) No person shall act as an operating crew member of the flight crew of an aircraft if at the beginning of the flight the aggregate of all his previous flight times;

(1) during the period of 28 (twenty eight) consecutive days expiring at the end of the day on which the flight begins exceeds 100 (one hundred) block hours: or
(2) during the period of 12 (twelve months) expiring at the end of the previous month exceeds 900 (nine hundred) block hours:

(b) The maximum cumulative duty hours for Flight crew of an aeroplane shall not exceed;

(1) 55 hours in one week, but may be increased to 60 hours, when rostered duty covering a series of duty periods, once commenced, is subject to unforeseen delays.
(2) 95 hours in any 2 consecutive weeks, and;
(3) 190 hours in any 4 consecutive weeks.
(4) 2000 Hours in 12 consecutive months

Note 1: in relation with the 12 consecutive months cumulative limits, on the first day of January, April, August and November, a 25% of the GCAA accepted or approved mandatory regulatory footprint for On-line training or CBT courses, making 100% in total. Courses than can be conducted on remote and/or in flexibility schedule, are also included in this requirement.

Note 2: Post holders and managerial staff, as included in the OM A, that simultaneously maintain an operating flight crew member status, are limited on actual 12 consecutive months to 450 block hours , but their managerial activities are not considered administrative work “for duty” limits.

Note 3. A crew member is not considered Operating Crew Member, during the time spent at his/her rest period in an acceptable in-flight rest facility, or its equivalent under unforeseen circumstances, which will be reported to the GCAA. The duration of the flight rest time is not to be included in the flight time cumulative limits, but will be included in the Flight Duty Period Duty Time for cumulative limits consideration.

Issue: 04 Page 288 of 513 Issue Date: October 2014 Rev. 00 Revision Date: October 2014

It's quite simple.

Press 2 and make sure it goes as FATIGUE if that's what it is. The data will eventually overturn the rule.

I have heard through a reliable source that we will have the following changes in the near future.......

5% pay rise during the normal pay review (is that April or may)

A few weeks later we will then have it taken back in the following manner:
Rostered up to 105 hrs per month
No credit for bunk time toward annual limit
Max of three days off at a time.
O
Maybe I should change my mind about Ryanair and go work for them (if they would have me)

The cancer has truly arrived and if these rumors are even half correct thenwe are all screwed!

Since the turn of the century I've watched a series of regressive steps in T&Cs with the exception of a couple of years around 2005-2007 where significant payrises were awarded which were subsequently erased with the increase to the overtime thresholds. You rolled with it all. But this if true it is truly depressing. I'm truly glad I have applications in with other airlines now. I no longer care about a pay cut, I just want to leave, under controlled conditions.

Speaking of overtime,


As long as all those hours are credit hours, that won't cut your salary. It's more flying hours in a colander month will mean more salary due to overtime plus the flying pay. Except that the latest rumour I heard is the overtime threshold will be raised to 97/98/99/100 per month. If true, THAT'S where they'll take back some of the pay rise. They've used this sneaky trick before and it's nothing new or clever.

The hourly rate they are forced to pay their pilots must always go down in real terms. That's part of their rule of greed.

I am not so sure about the section:

(4) 2000 Hours in 12 consecutive months

Refers to duty hours - Sim, CRM, SEP, Standby(with the usual night period where half counts), FDP plus 30 minutes etc. Can you honestly say you have a program/log book that records all this? The operator should have and so should we.

It will now depend on what the definition of Block Hours is or will it be amended in the OM-A. Normally OFF CHOCKS to ON CHOCKS or rostered BLOCK hours.

Maybe I read it differently = end of factoring.

Which is a good thing is it not?

(1) during the period of 28 (twenty eight) consecutive days expiring at the end of the day on which the flight begins exceeds 100 (one hundred) block hours: or
(2) during the period of 12 (twelve months) expiring at the end of the previous month exceeds 900 (nine hundred) block hours:

Substitute the "block hours" for "flying hours" in OM-A and absence of extra "Notes" which define augmenting crew hours unless that portion is still approved in the OM-A in future.

Maybe I'm deluded.

I guess Note 3 on the bottom of the NPA is the killer. Stick time only counts, which is what I have been hearing.

The GCAA define long flights as the following

Long Range : 7 - 14hr flight time
Extra Long Range : 14:01 - 16hr flight time (two set of flight crew)
Ultra Long Range : 16hr + flight time


Even though according to the following;

CAR - OPS 1.1105 General principles

Factors to be considered when planning duty periods shall include:


(a)The allocation of work patterns, which avoid such undesirable practices as;


(1) alternating day/night duties,
(2) the positioning of crews so that a serious disruption of established sleep/work patterns
occur
(3) the scheduling of rest periods between 18 and 30 hours especially after long flights
crossing multiple time zones.

So the ORD layover amongst others, while legal, goes against the general principles of the GCAA CARs. No problem for EK as they have no principles.

EK says we can fly up to 14:59 minutes with 3 crew but cars says any flight between 14:01 - 16hrs requires 2 sets of crew.

These are very subtle changes but they will be maximised to EK's advantage and whomever else may be an operator in the UAE. These changes are going to be slowly introduced with a little $$$ thrown at us to make it all wonderful. At least you will be too tired to remember why you are tired.

I'm happy to say the bags are being packed and I'll be joining the line at the door soon.

Note 3. A crew member is not considered Operating Crew Member, during the time spent at his/her rest period in an acceptable in-flight rest facility, or its equivalent under unforeseen circumstances, which will be reported to the GCAA. The duration of the flight rest time is not to be included in the flight time cumulative limits, but will be included in the Flight Duty Period Duty Time for cumulative limits consideration.

I stand to be corrected, but believe the intent of this note to mean - yes only the stick time is calculated for the following:

(b) The maximum cumulative duty hours for Flight crew of an aeroplane shall not exceed;

(1) 55 hours in one week, but may be increased to 60 hours, when rostered duty covering a series of duty periods, once commenced, is subject to unforeseen delays.
(2) 95 hours in any 2 consecutive weeks, and;
(3) 190 hours in any 4 consecutive weeks.
(4) 2000 Hours in 12 consecutive months

BUT must still abide by the following:

CAR-OPS 1.1125 Absolute Limits on Flying Hours

(a) No person shall act as an operating crew member of the flight crew of an aircraft if at the beginning of the flight the aggregate of all his previous flight times;

(1) during the period of 28 (twenty eight) consecutive days expiring at the end of the day on which the flight begins exceeds 100 (one hundred) block hours: or
(2) during the period of 12 (twelve months) expiring at the end of the previous month exceeds 900 (nine hundred) block hours:


Which must still abide by the following:

CAR-OPS 1.1126 Duty cycle, days off and leave entitlement
Crew member;
(a) shall not be on duty more than 7 consecutive days between days off, but may be positioned , and operate only, under unforeseen circumstances, when any other prescriptive flight time or duty cumulative limits are not exceeded, to the usual operating base on the eighth day, provided they are then allocated at least 2 consecutive days off, and
(b) shall have 2 consecutive days off in any consecutive 14 days following the previous 2 consecutive days off, and
(c) shall have a minimum of 7 days off in any consecutive 4 weeks, and
(d) shall have an average of at least 8 days off in each consecutive 4 week period, averaged over three (3) such periods.
(e) Shall be entitled to a minimum calendar annual leave according the applicable labour regulation
(f) Wherever possible, by operational demands, should be provided with days off in the home environment.

There is a distinction between flight time(block hours) and Cumulative limits ( all duty time, stick time, Reserve, RTGS, SEP, CRM)

Still is a lot of flying/work!

Maybe, just maybe that's the reason the leave can't be allocated ......not enough resources.

We might try to follow EASA but are "NOT" EASA compliant as CAA Authorities like to hiold onto their FTLs

I think the fact that they do not consider you an "operating crew member" during the time spent at his/her rest period in an acceptable in-flight rest facility is what the sticking point is.

An Operating Crew Member is defined as:
a crew member carrying out his/her duties in an aircraft during a flight

On duty, in the company's eyes does not necessarily mean operating like positioning. I think they will take a liberty with that interpretation and like positioning, no credit.

Speaking of positioning...

Marcellus,

I read it the other way. I think you've got it backwards. Time in the bunk does NOT count for absolute limit of flying hours (ie. 900 in 12 months and 100 in 28 days), but it does count for the limit on duty hours (ie. 55 hours in 1 week, 95 hours in 2 weeks..etc).

The rules all looked pretty normal until I got to that Note 3. That's just appalling.

It's complete madness.

Not defending the GCAA or EK or whatever just trying to make sense of it all.

Not my definition - plucked from the CAR itself.

Flight time - The total time from the moment an aeroplane first moves for the purpose of taking off until the moment it finally comes to rest at the end of the flight.
Note.—“Flight time” as here defined is synonymous with the term “block to block” time or “chock to chock” time in general usage which is measured from the time an aeroplane first moves for the purpose of taking off until it finally stops at the end of the flight.

You will notice there are 2 distinct sections:

(a) No person shall act as an operating crew member of the flight crew of an aircraft if at the beginning of the flight the aggregate of all his previous flight times;

(1) during the period of 28 (twenty eight) consecutive days expiring at the end of the day on which the flight begins exceeds 100 (one hundred) block hours: or
(2) during the period of 12 (twelve months) expiring at the end of the previous month exceeds 900 (nine hundred) block hours:

(b) The maximum cumulative duty hours for Flight crew of an aeroplane shall not exceed;

(1) 55 hours in one week, but may be increased to 60 hours, when rostered duty covering a series of duty periods, once commenced, is subject to unforeseen delays.
(2) 95 hours in any 2 consecutive weeks, and;
(3) 190 hours in any 4 consecutive weeks.
(4) 2000 Hours in 12 consecutive months

(a) BLOCK HOURS MAX 100/900 (anytime in the airplane - as per definition above - flight time, block)
(b) means you can operate, jumpseat, deadhead, RTGS, SEP, CRM, SIM all you want but don't exceed the 55/95/190/2000 of cumulative duty hours (report to release, pre-flight to on chocks +30 minutes) limit.

Note 3: ....if you sleep you're not operating but you're still OFF BLOCKS to ON BLOCKS and all the time is used to calculate (b)

lowstandard - I see the point with positioning/deadhead - the CAR is clear what duty is and works towards cumulative limits but as to credit, it's not the CAR's business. SO the company could possibly roster you 100 hours block and 100 hours deadhead/SIM/RTGS/CRM/SEP in a month subject to all the proviso of duty hours being met.

Duty:
Any task that crew member is required by the Operator to perform, including, for example, flight duty, administrative work, training, positioning and standby when it is likely to induce fatigue.
Administrative work has to be understood as any task that a crew member is required to carry out associated with the business of an AOC holder, which is accepted or approved by GCAA under the regulatory framework.

That's how I read it. I'm not a lawyer I could be wrong.

What you guys say - don't get your knickers in a twist....just yet.

I'm with you 100% Marcellus, I think its good that everyone gets this figured out so we are all clear.

I think that Note 3 means you are not considered operating crew while in the rest facility (augmenting or operating ).

Therefore "The duration of the flight rest time is not to be included in the flight time cumulative limits, but will be included in the Flight Duty Period Duty Time for cumulative limits consideration."

So time in the bunk is included for flight DUTY PERIOD time, say ULR 22hr.

Bunk time will not count towards flight time cumulative time, similar to factoring but now using actual time in the seat for both sectors.

So on a 20hr duty period, you may only get 7hrs of time towards your absolute limits (900 hrs etc) for the time you were in the seat (stick) but your Flight Duty Period takes into account both bunk and stick time (for discretion etc).

Our flight time reports on the portal show full stick time for operating sector and whatever hours you sat in the seat on the augment sector. The way I understand it it will now show whatever hours you sit in the seat as your flight time towards your absolute limits.

Its how I understand it and more than willing to be corrected and should make for a good question during the ball washing exercise with management during ground school.

Marcellus, I follow you but what Rogerwilco is saying agrees with what I have been hearing from good sources.

To summarise....
 

Surely for the slightly simple and slow witted of us here, lead by myself, what we are saying the proposed changes add up to is as below:

BEFORE: operating crew counted 100% of block hours towards 28 day and annual totals, whereas augmenting crew only counted stick time.

AFTER: operating and augmenting crew now count only stick time towards 28 day and annual block hours totals.

Anyone see it differently?

Marcellus

Im afraid it is what it says :-

Note 3 applies to what we would describe as "Block Hours" i.e. if your not in the operating seat you are not technically operating the aircraft and the time DOES NOT count towards the FLIGHT TIME LIMITS of 100 in a month or 900 in a year.

Your full time from Check IN (Dependent on your operator) to Check Out (30 minutes post block on same for both UAE Long Haul Operators) counts towards the 190 Duty Hours per 30 days, and 2000 Per Year.

So regardless of Operator's

To keep the maths simple lets just split the time in seat evenly between "Operating" and "Augmenting" Crew (in reality time in seat will be a little over 1 hour more per sector for the Operating crew)

Say you operate 3 ULR's pr month (currently the max) at 32 "Block Hours" per trip, thats 96 Hours total as we traditionally calculate it, so your done for the month!

Lets apply the GCAA change,

You have actually only spent 48 hours in a seat (the time in the crew rest facility does not count)

You have 52 Hours you may then still fly.

You can still operate as many augmented Long Range trips <14 hours as operator wishes to roster, so lets assume you do 3 SLR trips at 12 block each way (24 hours per trip)

3*24 = 72 Hours "Block Hours"

Time in seat is 12 Hours per trip, Flying time counted towards Flying limit is 36.

To Conclude from the Flying Time Limit you have done 3 * 32 "Block Hour" Trips and 3 * 24 "Block Hour" Trips but the operator under the new rule will conclude you have only flown:-

84 Hours Total and you have 16 "Flying Hours" to spare, you really flew 168 "Block Hours"

From a "Duty Time" perspective, all hours count, there is no deduction for time not spent in an Operating Seat.

So at The Airline that "Keeps Discovering", you check in 60 minutes prior to departure and check out 30 minutes after block on. You have flown 12 sectors thats

Pre and Post Departure Duty Time = 18 Hours
Duty Time in Aircraft = 168 Hours

Total Duty Time is 186 Hours versus the GCAA Limit of 190

ALL IS LEGAL ACCORDING TO THE GCAA


I have had this verified by the GCAA that this is the intent; if you fly Long Haul your productivity is about to be increase by almost 70%

DO NOT WRITE TO YOUR COMPANY, WRITE TO THE GCAA, WRITE TO IFALPA about the GCAA, your operators response is that they only comply with the law of the land.

THIS IS MADNESS AND ITS NO RUMOUR AND ITS DANGEROUS

Agree 100% Plank. What happens now is you do a ULR for 16 hours each way, total 32 hours in the aircraft, but stick hours are only 16. So they can effectively get another Lonndon out of you.

It's crazy. But for me, I don't care anymore. But for my fellow pilots, I worry deeply.

If the operating Captain signs the tech log accepting the flight, he/she should be then responsible for the entire period until chocks on and the release is signed. I'm thinking then that they should log the entire time of liability.

What a corrupt GCAA.
You can do 190 duty hours a month.
I bet nobody in the GCAA works 190 hours a month.Let alone 2000 duty hours a year.

Simply put

FCUK THIS!!

So it would be possible to do 6 LAX trips a month as the three ULR restriction is only an EK requirement!

The wet and dirty dreams of all EK Managers are now fulfilled...


I am deeply embarrassed that a long time ago I had some sort of pride for working in this company.
So happy that I´m not a part of this anymore...

New GCAA Flight Time Limitations - It Could Not Be Any Worse
 

2000 duty hours is based on the UK working time directive which currently sits out side the ftl in the UK but is being put into EASA ftl schemes in the UK. It's roughly a forty plus hour week if one gets four weeks leave a year. The stick time change not very subtle is a game changer so the correlation with cap371 doesn't add up. There is no way the UK Caa would agree such a change with EASA looming and if it was a safety case would be needed. Someone gas sold gcaa a kipper. The only stopper is the duty limits but I can't see them getting in the way too much

The CAP 371 alignment change is a bait and switch. The GCAA is trying to show they are compliant with UK CAA standards and in line with their thinking while they slid this gem under the table.

Who in the UK or Europe is going to complain when the ME3 have their names plastered on everything or in certain cases buy into European airlines?

Hopefully the Aussie, US and Canadian regulatory authorities will take note as this will effect flying in their airspace.

Does this go on at any other place in the world??

Biggest mistake of my career was coming to this place.

Interesting times! The UK CAA are switching across to EASA for 2016 and the way they are doing it is found in the following 2 links.


EASA Flight Time Limitations (FTL) | Airlines | Operations and Safety

More information | Airlines | Operations and Safety

The recommended implementation plan is included at:



http://www.caa.co.uk/docs/2948/20141128%20EASAFTLRegulationsCombinedDocumentGuidance%20edn% 202.pdf


This document states:

"A person on board an aircraft is either a crew member or a passenger. If a crew member is not a passenger on board an aircraft he/she should be considered as ‘carrying out duties’. The crew member remains an operating crew member during in-flight rest. In-flight rest counts in full as FDP, and for the purpose of."

That seems pretty clear!

EASA says:

“flight time” means, for aeroplanes and touring motor gliders, the time between an aircraft first moving from its parking place for the purpose of taking off until it comes to rest on the designated parking position and all engines or propellers are shut down;

That does too!

EASA limits on Flight Times says:

ORO.FTL.210 Flight times and duty periods

(a) The total duty periods to which a crew member may be assigned shall not exceed:
(1) 60 duty hours in any 7 consecutive days;
(2) 110 duty hours in any 14 consecutive days; and
(3) 190 duty hours in any 28 consecutive days, spread as evenly as practicable throughout that period.

(b) The total flight time of the sectors on which an individual crew member is assigned as an operating crew member shall not exceed:

(1) 100 hours of flight time in any 28 consecutive days;
(2) 900 hours of flight time in any calendar year; and
(3) 1 000 hours of flight time in any 12 consecutive calendar months.

(c) Post-flight duty shall count as duty period. The operator shall specify in its operations manual the minimum time period for post-flight duties.

So it seems someone at the GCAA is prepared to go out on a limb against the regulations that underpin CARS. Bearing in mind the fatigue conclusions coming out of the Colgan debacle and others, a brave man indeed!

I would argue that bravery is unlikely, they just don't understand what they have been lobbied for and duly implemented, not to mention what they can and will be BLAMED for.

You may well be right. It contradicts other parts of the manual as it states:

One pilot amongst the flight crew, qualified as a pilot-in-command in accordance with the requirements governing Flight Crew Licences, is designated as the commander who may delegate the conduct of the flight to another suitably qualified pilot;

Commander - The pilot designated by the operator being in command and charged with the safe conduct of a flight.

You can have 2 PICs but only one Commander, so whoever signs for the aircraft has to remain commander unless we are planning in-flight maintenance checks. By the whim of Thor, what have I said!

EK can not be CAR compliant when they pick and choose what regulations to abide by.

The new rules if ever implemented will be changed before the end of the year ..

This is a short tem solution to the pilot shortage (under the blanket on GCaA)

Whoever suggested the idea is going to be showered in coins .. Come bonus

Short term solutions have a habbibit of becoming permanent :\

What they don't realise is that this "short term" answer to the recruitment/retention problem is part of the recruitment/retention problem!

Memories
 

I remember saying to my wife, one year after my upgrade at EK,

'This is the happiest I have been in my career so far'

It saddens me that I can not say that now. I am feeling that I actually despise the company and

it's so called management. I don't know how they can get it so wrong so

quickly. I am tired of being treated like a child/slave/fool by muppets!

I genuinely fear for my health and the inevitable hull loss.

I will not be here much longer. If you don't like it, leave!!!

Thanks for the advice. The best mantra to come from EK management.:ugh:

There is a sickening lack of respect from the idiots we have the misfortune to be managed by. I fully echo the above sentiment. It's hard to see how this can be turned around.

Am I thinking too simple here or is the text below, a way out of this?

Emirates operates under the authority and restrictions of the UAE Civil
Aviation Regulations (CARs). When operating outside the UAE Emirates
aeroplanes are subject to the rule of law of the State in which they are
operating. Generally, other states make provision for such operations by
publishing differences from ICAO standards and expecting foreign
Operators to comply with the published differences and ICAO standards.
Where the restrictions of other States on foreign operators, are more
stringent than those of the UAE CARs, the more restrictive rules shall
apply

L

Possibly Longsleep, but the boys at the funny farm will still give you a warning letter

ruserious,

Do you really care about getting a warning letter from a bunch of troglodytes of which NOBODY has any respect for? Here, a warning letter should be looked upon as a motivational tool to look for someone better to work for, it actually probably a good thing.

The damage was done a few years ago, its just become serious now. Sadly they have repeated the mistakes of GF and those in high levels will go down in history as killing what could have been the best company in the world to work for. As has been said before, its their train set.

You can't take them seriously any more. Once you realize that then its much easier to deal with the lunacy. Carry your resignation letter with you, leave the date blank and fill it in when the situation arises. Selling out your self respect and dignity goes with you to the grave...the job can be replaced in a few weeks.

Keep your eye on the ball :
EK is planning on 105 hours per month with no credit for bunk time, this will apply to all pilots
There will be no productivity pay under this system, so don't think you will be paid for the 15 hours over the 90 hrs

If and when that little increase is slipped in, I shall have my feet up in Costa coffee until STD-60. Hopefully it will be burst to overflowing with all the other big talkers on here doing the same.

Harry

The evidence is out there:

https://www.eurocockpit.be/pages/fatigue-in-accidents

https://www.eurocockpit.be/sites/def...SP_09_0528.pdf

Some interesting light reading!

We are all professionals. We know when we are fatigued. Therefore we are responsible, not only for our own health, but just a much for the health of our customers and for the health of our company, as accidents are detrimental to all.

We are therefore obliged to call in "sick fatigued" and fill in fatigue reports whenever we deem (or suspect, as in the OMA) fatigue to possibly be a safety issue.

I am the first to be guilty of moaning on these pages, but i have repeatedly filed fatigue reports when necessary and also called in "sick fatigued".

I truly hope we will all act as responsible professionals and i am therefore expecting a sharp increase in such reports if such deterioration of rules are manifest

Otherwise don't bother complaining here.