USA FTDT Documentation Verification Report

Updated: 2026-06-26 · Audited: 2026-06-26 · Prepared: 2026-03-03 · Reviewer: ALPA Bot (verify-usa-docs)

Regulatory source: part-117-25-rest-period.html (current as of Feb 27, 2026)

Documents verified: definitions.html · calculator-us.html · duty-period-us.html

1. Accuracy Check: Definitions vs. §117.3

Correct Definitions

TermStatusNotes
Flight Duty Period (FDP)✅ AccurateText matches §117.3 verbatim (minor formatting difference: extra space in "airport/ standby reserve" — cosmetic only)
Theater✅ AccurateMatches §117.3: "no more than 60 degrees longitude"
Acclimated✅ AccurateMatches §117.3: "72 hours in theater OR 36 consecutive hours free from duty"
Short-call Reserve✅ Substantially accurateCorrectly describes RAP assignment without prior rest period; slightly simplified vs. §117.3
Long-call Reserve✅ AccurateStates "at least 10 hours' notice" — matches §117.3 requirement to notify before §117.25 rest period

Inaccurate or Incomplete Definitions

1. "Extension" — Incomplete / Potentially Misleading

Doc: "Extended" means a pre or post takeoff extension of a FDP.

Issue: §117.3 does not define "Extended" or "Extension" as a standalone term. Part 117 covers FDP extensions under §117.19 (Extensions due to unforeseen operational circumstances). The current definition is a simplified paraphrase not drawn from §117.3 and could be misleading ("pre-takeoff extension" is not Part 117 language). Needs a regulatory citation or should be flagged as an app-specific term.

2. "Rest Availability Period (RAP)" — Not a §117.3 Term

Doc: "Rest Availability Period (RAP)" is a duty period during which a certificate holder requires a reserve flightcrew member on short call reserve to be available to receive an assignment for a FDP.

Issues: (1) §117.3 does not define "RAP" — the regulation uses "reserve availability period" as part of the Short-call reserve definition. "RAP" is an app-specific abbreviation and should be clearly labeled. (2) Calling RAP "a duty period" is technically incorrect — it is a reserve availability period, not an FDP.

3. "Rest Opportunity (RO)" — Not a §117.3 Term

Issue: §117.3 does not define "Rest Opportunity." It is used in §117.15 (Split duty). This is app-specific shorthand and should be labeled as such.

4. "FDP Types" Section — Contains a Naming Error (Critical)

Doc: "Un-Augmented" used to label a three or four person flight crew.

Issue: A three or four person flight crew is an Augmented operation (Part 117 Table C). The doc uses "Un-Augmented" for 2-person crew AND for 3/4-person crew — both labeled "Un-Augmented." This is a critical documentation error that could cause Table lookup selection errors in implementation.

Missing Definitions (in §117.3, absent from documentation)

Missing TermWhy It Matters
Deadhead transportationDirectly affects FDP calculations (§117.25(g), Table B — deadhead NOT a flight segment)
DutyFoundational for rest calculations — deadhead IS duty, not rest
FatigueBackground context for the regulation's purpose
Home baseRequired for §117.25(d) 56-hr rest calculation
Physiological night's restRequired for §117.25(d) three-physiological-nights requirement (10h encompassing 0100–0700)
Rest periodFoundational for all rest calculations
Reserve flightcrew memberFoundational for reserve operations
Unforeseen operational circumstanceRelevant to FDP extensions under §117.19
Window of circadian low (WOCL)Referenced in §117.17 and important for extension restrictions (0200–0559)
Rest facility classes 1, 2, 3Required for Table C augmented FDP lookup

2. Part 117 Sections Not Documented

SectionSubjectStatus
§117.5Fitness for duty — self-assessment, unfit notification❌ Absent
§117.7Fatigue risk management system (FRMS)❌ Absent
§117.9Fatigue education and awareness training❌ Absent
§117.11Flight time limits (FTL)⚠️ Partial (Table A in Calculator_US but no standalone doc)
§117.13Cumulative flight time limits⚠️ Partial (numerically covered in Calculator_US)
§117.15Split duty rules⚠️ Partial (mentioned as note; no requirements doc)
§117.17Augmented operations rules⚠️ Partial (Table C referenced; no dedicated coverage)
§117.19Extensions of FDP (unforeseen operational circumstances)❌ Entirely absent — no extension rules, caps, or procedures
§117.21Reserve requirements (airport standby, long-call, short-call)⚠️ Partial (Definitions.md only; no requirements doc)
§117.23Cumulative limitations⚠️ Partial (numerically covered in Calculator_US)
§117.25Rest period requirements❌ Entirely absent — 0 of 7 subsections documented
§117.27Certificate holder responsibilities❌ Absent
§117.29Applicability (121 carriers)❌ Absent

Notably missing — §117.19 FDP Extensions: Calculator_US.md and DutyPeriod_US.md include "Extended" as an FDP type, but document no extension conditions, no cap (max +2h for unaugmented beyond Table B), no WOCL restrictions, and no notification/recording requirements.

3. Rest Period Coverage: §117.25

§117.25 has seven subsections (a)–(g). Coverage before this audit:

SubsectionRequirementPre-Audit Coverage
§117.25(a)No assignment during required rest period❌ Not documented
§117.25(b)30 consecutive hours free from duty within past 168 hours❌ Not documented
§117.25(c)36-hr rest in new theater = acclimated + meets (b)❌ Not documented
§117.25(d)56-hr rest at home base after trans-theater travel (>60° long, >168h away) + 3 physiological nights❌ Not documented
§117.25(e)10-hr pre-FDP rest (minimum 8 hrs sleep opportunity)❌ Not documented
§117.25(f)FCM must notify if 8-hr sleep opportunity cannot be achieved❌ Not documented
§117.25(g)Deadhead exceeding Table B FDP → rest ≥ deadhead duration, min 10 hrs❌ Not documented

Summary: §117.25 was entirely absent from the documentation. All seven subsections were missing.

4. Tables Check

Table A — Correctly references image but no text fallback

Calculator_US.md uses ![table-a](../images/table-a.png) but does not reproduce the values in text. Not a values error but cannot be verified without the image.

Table B — Not Present

Status: "Table B reference image is not currently available in this repository."

This is a critical gap. Table B is the primary FDP lookup table for unaugmented lineholders. See part-117-25-rest-period.html for the complete table.

Table C — Not Present + Factual Error

Doc states: "For a three-pilot crew, it is 13 hours; for a four-pilot crew, it is 17 hours."

Reality: Table C FDP limits depend on both crew count AND rest facility class and vary by time of start. The values "13h" and "17h" are the minimum corner cases only (Class 3 / 3 pilots at 0000–0559 = 13h; Class 1 / 4 pilots at 0700–1259 = 19h). Presenting them as flat limits is a material misrepresentation that could cause incorrect calculations. Correct range: 13–19 hrs across all configurations.

Acclimation Reduction Rule

Calculator_US.md states the Maximum FDP is reduced by 30 minutes if the crew member is not acclimated. This cannot be verified from §117.25 alone — may be in §117.21 or FAA guidance. Needs a specific regulatory citation.

5. Discrepancies Summary

#FileDiscrepancySeverity
D-01Definitions"Un-Augmented" incorrectly used for 3/4-person crew (should be "Augmented")🔴 Critical
D-02Calculator_USAugmented FTL stated as flat "13h / 17h" — omits rest facility class entirely🔴 Critical
D-03Calculator_USTable B absent ("not currently available")🔴 Critical
D-04Calculator_USTable C absent ("not currently available")🔴 Critical
D-05Definitions"Extension" definition not grounded in §117.3 (not an FAA-defined term)🟡 Moderate
D-06DefinitionsRAP described as "a duty period" — incorrect framing🟡 Moderate
D-07All docs§117.25 rest requirements entirely absent (0 of 7 subsections)🔴 Critical
D-08All docs§117.19 FDP extension rules entirely absent despite "Extended FDP" being a tracked field🔴 Critical
D-09Definitions10 key §117.3 terms absent (deadhead, duty, home base, WOCL, rest facility classes, etc.)🟡 Moderate
D-10Calculator_US30-min non-acclimated FDP reduction lacks regulatory citation🟡 Moderate
D-11DutyPeriod_USUses "PDF" (likely typo for FDP) in three places🟢 Minor
D-12DefinitionsRAP and RO defined as if they are §117.3 terms — they are app-specific🟢 Minor
D-13Calculator_USSplit duty RO rules stated (22:00–05:00, 3-hr minimum) without regulatory citation🟡 Moderate

6. Recommendations

Priority 1 — Critical Fixes

  1. Fix the Augmented/Un-Augmented naming error in Definitions — rename 3/4-person crew to "Augmented" and "Augmented Reserve"
  2. Replace incorrect flat augmented FTL statement in Calculator_US — add complete Table C with start-time + rest-class dependency
  3. Add Table B to Calculator_US — full 10×7 text table
  4. Add Table C to Calculator_US — full 5×6 text table
  5. Create rest period documentation covering all §117.25 subsections (a)–(g)
  6. Add §117.19 extension documentation to DutyPeriod_US — conditions, 2-hr cap, WOCL restriction, notification

Priority 2 — Completeness

  1. Add missing §117.3 definitions: Deadhead transportation, Duty, Home base, Physiological night's rest, Rest period, WOCL, Rest facility classes 1/2/3
  2. Mark RAP, RO, and "Extension" clearly as ALPA app conventions, not §117.3 terms
  3. Add regulatory citations to Calculator_US for the 30-min acclimation reduction and Split Duty RO rules
  4. Fix DutyPeriod_US typos — "PDF is Extended" → "FDP is Extended" (3 instances)

Priority 3 — Nice to Have

  1. Add §117.5 fitness-for-duty note (self-assessment responsibility)
  2. Add §117.29 applicability note (Part 121 certificate holders)
  3. Verify Table A image matches regulatory values; add text-based table as fallback

Appendix: Key Regulatory Text for Missing Sections

§117.25(b) — Weekly Rest

"Before beginning any reserve or flight duty period a flightcrew member must be given at least 30 consecutive hours free from all duty within the past 168 consecutive hour period."

§117.25(d) — Trans-Theater Home Base Rest

"A flightcrew member must be given a minimum of 56 consecutive hours rest upon return to home base if the flightcrew member: (1) Travels more than 60° longitude during a flight duty period or a series of flight duty periods, and (2) is away from home base for more than 168 consecutive hours. The 56 hours of rest must encompass three physiological nights' rest based on local time."

§117.25(e) — Pre-FDP Rest

"No certificate holder may schedule and no flightcrew member may accept an assignment for any reserve or flight duty period unless the flightcrew member is given a rest period of at least 10 consecutive hours immediately before beginning the reserve or flight duty period measured from the time the flightcrew member is released from duty. The 10 hour rest period must provide the flightcrew member with a minimum of 8 uninterrupted hours of sleep opportunity."

§117.25(g) — Deadhead Transport Overage

"If a flightcrew member engaged in deadhead transportation exceeds the applicable flight duty period in Table B of this part, the flightcrew member must be given a rest period equal to the length of the deadhead transportation but not less than the required rest in paragraph (e) of this section before beginning a flight duty period."

Report generated by ALPA Bot subagent (verify-usa-docs) — 2026-03-03

View fixes applied based on this report →