I refer to CPL Air Law sample questions set 4, the answer states that the answer is A: 'FDP must end no later than 1900. However, given that Appendix 5 states that the cumulative flight time accrued by an FCM during any consecutive 168 hour period must not exceed 50 hours', thus shouldn't the answer be B instead? My reasoning is that 41 hours has already been accrued, leaving 9 hours left in the 1 week period, so 0700+ 9 hours=1600h?

Question 13 of Sample set 1 states that there has been 90 hours in the last 27 days, and the FDP will commence at 0800LMT, in that case wouldn't the max time be 9 hours (instead of 7)?

Another question I would like to seek clarification is from Q5 of Appendix 5 Research questions. Using the reasoning of the previous question Q4 (although I note it is a sleeping accommodation question), subsection 2.3 of Appendix 5 states that 'any portion of an FDP remaining after a split-duty rest period must be no longer than the sum of 6 hours'. As at the end of the resting accommodation in Q5, 3 hours of FDP has already been used, (so 12-3=7), 7 hours of FDP is left. But given subsection 2.3, this must be reduced to 6 hours- thus 1630 (time at end of resting accommodation) plus 6 hours= 2230? However, there is no answer for this? Could anyone point out what is incorrect with my reasoning?

This is a reply from our Air Law expert Bob Hamilton

Question 1

Your company operates under CAO 48.1 instrument 2019 Appendix 5. In the last 6 days you have flown 41 hours. You are not restricted by any 28 or 365 day flight time limitations. Today is day 7 and you are to start an FDP at 0700 LMT. Your FDP must end no later than:

(a) 1900
(b) 1600
(c) 2100
(d) you cannot be assigned this FDP

Answer

Answer (a) is correct. Refer to the definitions section of the Instrument and you see that flight time is defined differently from flight duty period (FDP). The question specifically asks that you find the end time of an FDP, and not how much flight time may be undertaken during that FDP. Reference to Table 1.1 of Appendix 5, shows that a flight duty period starting at 0700 may be a maximum of 12 hours. It may be that you encounter a flight time limitation during that flight duty period but you may still work the entire 12 hour FDP, in which case 0700 + 12 = 1900.

Question 2

Your company operates under is a CAO 48.1 instrument 2019 appendix 1. You are scheduled to commence a FDP at 0800 LMT. If you have flown 90 hours in the last 27 days and no other limitation applies, the maximum hours you may fly today are

(a) 8 hours
(b) 9 hours
(c) 10 hours
(d) 7 hours

Answer

Answer (b) is correct and so is the writer. You may accumulate 100 hours flight time in a 28 day period, so you have 10 hours left to fly. However, an FDP that starts at 0800 LMT is limited to 9 hours, so you can only fly 9 hours at most and can only accumulate a maximum of 99 hours for the entire 28 day period.


Question 3

Your company operates under CAO 48.1 instrument 2019 appendix 5. You have been rostered for an FDP commencing at 0730 LMT with a 6 hour split duty rest period with resting accommodation commencing at 1030 LMT. The operation is a single pilot operation and there have been no extensions. The latest time at which this FDP must be completed is

(a) 2130 LMT
(b) 2030 LMT
(c) 1930 LMT
(d) 1130 LMT

Answer

Answer (a) is correct. The references are Appendix 5 para 2.2 and 2.3. The question says ‘’no extensions”, so para 3 need not be considered.

Para 2.2 states that ‘’Where an FDP contains a split-duty rest period of at least 2 consecutive hours with access to suitable resting accommodation, the maximum FDP worked out under subclause 1.1 may be increased by half the duration of the split-duty rest period, provided the increase is not more than 2 hours”.

Para 2.3 states that “Any portion of an FDP remaining after a split-duty rest period must be no longer than the sum of 6 hours and any permitted extension under clause 3”.

Paras 2.2 and 2.3 each impose a limitation upon the baseline 12 hour FDP, but the limitation is imposed from different starting points. The question is, which is most limiting.

Pursuant to Table 1.1 of Appendix 5, an FDP that starts at 0730 can be a maximum length of 12 hours, so 0730 + 12 = 1930. Applying the split duty rest period restriction at Para 2.2, increases the length of the FDP by 2 hours to 2130 (2 hour maximum extension permitted from end of normal FDP). Applying the split duty rest period restriction at Para 2.3 increases the length of the FDP by 6 hours from end of split duty rest period to 2230 (6 hours maximum extension permitted from end of split duty rest period). Now pick the most restrictive para, which is 2.2, and the answer is (a) 2130.

In regard to question 13 sample set 1 is the answer not (b) in your book?

I am using the ebook version, that could be the reason why the answer appears different.