Independent analysis · Hypothetical
If Part 117 applied to cargo: a whole bid period, measured.
14 CFR Part 117 sets flight, duty, and rest limits for airline pilots — but all-cargo operations are exempt. We took one complete cargo bid period (BID2606, September–October 2026: seven bid packs across four fleets and four domiciles, 5,326 pairings on 1,110 lines with times) and evaluated every line and every pairing against Part 117 as written. This hub compares the domiciles; each pack page carries line-by-line verdicts.
The packs
Seven bid packs, line by line.
ONT 757/767
MIA 757/767
SDF 757/767
SDF-Z 757/767 international
SDF A300
ANC 747-400/-8
SDF 747-400/-8
| Pack | Lines w/ times | Lines pass | Pairings | Pairings legal | Augmented | Dominant rule |
|---|---|---|---|---|---|---|
| ONT 757/767 | 52 | 3 | 240 | 124 (+7) | — | §117.27 |
| MIA 757/767 | 50 | 24 | 188 | 122 (+2) | — | §117.27 |
| SDF 757/767 | 269 | 68 (+2) | 1657 | 1321 (+21) | 3 | §117.27 |
| SDF-Z 757/767 international | 234 | 67 (+1) | 916 | 677 (+22) | 321 | §117.27 |
| SDF A300 | 135 | 15 (+4) | 725 | 541 (+52) | — | §117.27 |
| ANC 747-400/-8 | 243 | 176 | 1002 | 969 | 873 | §117.13 |
| SDF 747-400/-8 | 127 | 92 | 598 | 574 | 495 | §117.13 |
Honesty section
Assumptions and interpretations.
Part 117 leaves several terms undefined. Every interpretation used here is stated, and each was chosen for defensibility, not for effect.
- WOCL infringement means any portion of the duty period overlaps 0200–0559 in the time zone the crewmember is acclimated to (per FAA interpretive Q&A).
- The consecutive-night reset is a duty-free interval encompassing a physiological night (0100–0700 acclimated time), or a duty period that does not infringe the WOCL. A 10-hour daytime layover does not reset the count. If the FAA accepted any 10-hour rest as a reset, most §117.27 failures on these pages would disappear — that reading has no support in the FAA's published Q&A and is not used.
- Acclimation follows §117.3 and §117.25(c): a crewmember displaced more than 60° of longitude from their acclimated theater is unacclimated (duty limits reduced 30 minutes, measured on the last-acclimated clock) until 72 hours in the new theater or 36 hours free from duty there.
- Augmented rest facilities are assumed Class 1 (bunk) — the most generous reading of Table C. In-flight rest scheduling (§117.17(c)) is assumed satisfied; it is not in the bid data.
- Sleep-room availability is not in the bid data. The sleep-room category is a geometric test of ground sits only; actual legality would turn on the carrier scheduling suitable-accommodation rest.
- Carry-in is unknown. Time before the bid period opens is treated as free for the 30-in-168 test — the generous assumption.
- Airport standby is flight duty for its full length, per §117.21(b).
- Station data: one UPS-internal station code (DJT) is absent from public airport data; its clock comes from the feed's own local times and its longitude is approximate — it affects theater math only.
What the numbers say
The rule bites exactly where the night sort lives.
The pattern across seven packs is stark. The domestic night-sort packs — ONT, MIA, and the SDF 757 and A300 groups — fail overwhelmingly on §117.27, consecutive nighttime operations: the week-long hub-turn pairings that make overnight-sort lines efficient run four and five consecutive duty periods through the 0200–0559 window of circadian low, with daytime layovers that never contain a physiological night's rest. Almost nothing fails on raw flight time, and no pack touches the cumulative duty caps at the pairing level.
The international packs invert the picture. Anchorage and Louisville 747 flying — and the SDF-Z international 757/767 group — run augmented crews with in-flight rest, long layovers, and duty periods measured against Table C's higher limits, so most of their lines pass as built. What catches them instead: Table B overruns on their unaugmented positioning legs, the 30-hours-free-in-168 weekly rest on long rotations, the 100-flight-hours-in-672 cumulative cap on heavy 747 lines, and — unique to long-haul — the 56-hour three-night home rest after crossing more than 60° of longitude. One geometric quirk: Anchorage to Louisville spans 64° of longitude, so every ANC hub run to SDF is technically a theater change under the rule as written.
ONT remains the deep-dive: its page carries a full domicile rebuild under Part 117 showing what compliance would cost — about a third more pairings and 788 additional credit hours for the same flying.
Method
Every line, every pairing, every duty.
Each pack's machine-readable bid feed was decoded and cross-checked against the published line and trip reports; crew complement (2-, 3-, or 4-pilot) comes from the published per-leg Need values. Every pairing occurrence was placed on the calendar in UTC and tested duty-by-duty: Table A flight-time and Table B duty limits for 2-pilot crews (§117.11, §117.13); Table C limits, the 3-segment cap, and the 13/17-hour flight-time limits for augmented crews (§117.17, §117.11(a)); 10-hour pre-duty rest (§117.25(e)); 30 hours free in every trailing 168 (§117.25(b)); the 56-hour three-night home rest after long international travel (§117.25(d)); consecutive nighttime operations (§117.27); airport standby counted as duty (§117.21(b)); and the sliding cumulative caps (§117.23). Rule text is the current eCFR edition.
Scope. Line types that carry no times — LCO, VTO, VOR, and the reserve families (RA/RB/RC/RD, SA/SB/SC/SD) — are excluded from all figures: they contain no evaluable assignments, and reserve lines would be governed by §117.21's reserve rules, which cannot be tested from bid data.
About this work
Built by people who fly these lines.
This analysis was produced with the schedule-evaluation tooling behind Far Horizon Group's crew products, which measure real airline schedules for pay, legality, and fatigue. Questions, corrections, and methodology challenges are welcome.