FAA Part 117 vs EASA FTL Scenario Comparisons
Carriers that operate across the Atlantic, wet-lease into European networks, or code-share on mixed fleets have to answer the same question twice: is this pairing legal under FAA rules, and is it legal under EASA rules? The two regimes share a vocabulary — report time, flight duty period, rest, cumulative caps — but the numbers, the tables, and the way acclimatisation is resolved diverge enough that the same roster can pass one and fail the other. This section works through concrete, identical scheduling scenarios and shows exactly where the two rule sets agree, where they part, and which one binds. It builds on the schema-level treatment in the FAA Part 117 rule schema design and the EASA FTL compliance frameworks, turning their abstract rule sets into head-to-head verdicts a dual-jurisdiction compliance team can act on.
The Dual-Jurisdiction Problem
The scoped challenge is precise: given one crew member’s duty history, produce two independent verdicts without letting either rule set contaminate the other, and surface which limit binds so a scheduler can fix the actual constraint. The naive approach — a single evaluator with if jurisdiction == "FAA" branches sprinkled through it — fails the moment a pairing must satisfy both regimes simultaneously, because the branches interleave and no one can tell afterwards whether the FDP that was applied was the American or the European one.
Three differences make the comparison genuinely non-trivial rather than a matter of swapping constants. First, the daily FDP tables are keyed differently: FAA §117.13 Table B keys on acclimatised report time and flight segments, while EASA CS FTL.1.205 keys on report time and sectors with a different banding, so the same four-leg early departure can read a twelve-hour ceiling under one and a slightly different one under the other. Second, acclimatisation is stateless under the FAA and stateful under EASA: Part 117 uses the crew member’s acclimatised time zone directly, whereas EASA’s CS FTL.1.235 resolves an acclimatisation state from elapsed time and time-zone difference, so a long-haul rotation can leave a crew member “unknown” state under EASA while the FAA simply uses their theatre. Third, the cumulative windows differ in both length and metric: the FAA counts 60 and 190 FDP hours over 168 and 672 rolling hours, while EASA counts duty over 7, 14, and 28 days — windows that catch different rosters.
Where the Two Regimes Diverge
The comparison matrix below fixes the ground truth the scenario pages build on. Every row is a place where an identical roster can produce different verdicts, and the divergence is the reason a dual-jurisdiction carrier cannot simply certify against the stricter regime and assume the other is covered.
Regulatory Mapping
Each scenario page traces its verdict to specific provisions in both regimes, so the comparisons are auditable rather than illustrative. The authoritative texts are FAA Part 117 and EASA Regulation (EU) No 965/2012, Annex III, Subpart FTL. The provisions that drive the divergences are:
- §117.13 and CS FTL.1.205 — daily FDP. Both cap the flight duty period by a table, but Part 117 counts flight segments while EASA counts sectors and applies a different set of report-time bands, so the ceiling for an identical departure can differ by up to an hour.
- §117.23 and ORO.FTL.210 — cumulative limits. The FAA windows are rolling hours (168 and 672); the EASA windows are rolling days (7, 14, 28). A roster that clears the FAA 168-hour window can breach the EASA 7-day window because the two count different intervals.
- §117.25 and ORO.FTL.235 — rest. The FAA floor is a flat 10 hours; the EASA floor is the greater of the preceding duty or 12 hours at base / 10 hours down-route, so European rest after a long duty is often longer than the American minimum.
- §117.13 acclimatised-time definition and CS FTL.1.235 — acclimatisation. The FAA treats the crew member as acclimatised to a theatre; EASA computes a state that can be “acclimatised”, “unknown”, or acclimatised to a new reference time, which changes which FDP table column applies.
The scenario pages below take one concrete roster each and run it through both mappings, reporting the two ceilings, the two rest requirements, and the binding constraint.
Explore the Scenarios
The general divergences above become concrete, numeric verdicts in the comparison pages beneath this topic:
- Maximum FDP for an Early Morning Report — a four-sector day starting at 05:30 acclimatised time, resolved against Table B and CS FTL.1.205 side by side, showing which regime grants the longer duty day.
- Rest Requirements After a Long-Haul Rotation — a transmeridian rotation where the FAA flat 10-hour floor and the EASA relative-to-duty floor produce materially different minimum rests.
- Cumulative Duty Caps Compared — a dense two-week block evaluated against the FAA rolling-hour windows and the EASA rolling-day windows, showing how each catches rosters the other misses.
Related
- FAA Part 117 Rule Schema Design — the American rule set these scenarios evaluate against.
- EASA FTL Compliance Frameworks — the European rule set and its stateful acclimatisation logic.
- Regulatory Reference Tables — the queryable constants both regimes are compiled from.
- Duty Time Validation & Rule Engines — the engine that runs both rule sets over one duty history.
Back to Core Architecture & Regulatory Mapping.