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Part 117 vs EASA FTL — Same Problem, Different Machines

The US rule is one fixed table set for everyone; the European rule is a scheme your operator designs, audited against a prescriptive core. The philosophies produce different numbers on the same trip.

Structural difference first

Part 117 (77 FR 330) is a closed prescriptive rule: Tables A/B/C in the regulation itself, hard 10/8 rest, hard cumulative caps. Exceeding any provision requires an FAA-approved FRMS (§117.7(a)). EASA Subpart Q (ORO.FTL, introduced by Commission Regulation (EU) No 83/2014) sets a prescriptive baseline but requires each operator to submit a flight time specification scheme — the actual FDP tables, rest and reserve arrangements live in the operator's approved manual, built from ORO.FTL.200–235 and its AMC/GM.

Key numbers side by side

	FAA Part 117	EASA ORO.FTL (baseline)
Max FDP, basic	Table B by report band × segments (9–14 h unaugmented)	13 h for 1–2 sectors (ORO.FTL.205(b)); −30 min per sector beyond 2, max −2 h; report-time and WOCL reductions bring the floor to about 9 h
Planned extension	+2 h for unforeseen circumstances, PIC + company concurrence, once per 30-h break (§117.19(a))	Up to +1 h, at most twice in any 7 consecutive days (ORO.FTL.205(d))
Augmented max FDP	Table C: 13–19 h by rest facility class and pilots (§117.17)	Up to 16 h with 3 pilots / 17 h with 4 pilots, refined by rest facility in the operator scheme (ORO.FTL.205(d))
Discretion mid-flight	After takeoff: as far as needed to land safely (§117.19(b)); 10-day report if >30 min over	Commander's discretion +2 h (+3 h augmented) for unforeseen circumstances (ORO.FTL.205(f))
Rest	10 h incl. 8 h uninterrupted sleep opportunity, from release (§117.25(e)); no reduced rest	At home base: ≥ preceding duty or 12 h; away: ≥ preceding duty or 10 h (ORO.FTL.235(a)–(b)); reduced/compensated rest possible in the scheme
Weekly reset	30 h free of duty in any 168 h (§117.25(b))	Recurrent extended recovery rest: 36 h including 2 local nights, ≤168 h apart, plus 2 local days twice a month (ORO.FTL.235(d))
Cumulative duty/FDP	60 h FDP/168 h; 190 h FDP/672 h (§117.23(c))	60 h duty/7 days; 110 h duty/14 days; 190 h duty/28 days (ORO.FTL.210(a))
Cumulative flight time	100 h/672 h; 1,000 h/365 days (§117.23(b))	100 h/28 days; 900 h/calendar year; 1,000 h/12 months (ORO.FTL.210(b))
WOCL	0200–0559 definition; ≤3 consecutive infringing FDPs (5 with ≥2 h accommodation rest) (§117.27)	WOCL defined 0200–0559 local; night FDP reductions built into ORO.FTL.205(b) tables
Reserve	RAP ≤ 14 h; combined FDP+RAP walls of Table B+4/16 h and Table C+4 h (§117.21(c))	Standby and reserve defined in ORO.FTL.210/230 with airport-standby credit rules in the scheme; no single statutory 14 h RAP

Three practical takeaways

EASA's 190 h/28 days is duty hours; the FAA's 190 h/672 h is FDP hours. Duty ⊇ FDP, so the same calendar month is measured over a wider net in Europe. The 60 h/7-day duty cap likewise covers more than the FAA's 60 h FDP/168 h.
US rest is shorter on paper but stricter inside: 10 h total with 8 uninterrupted sleep hours vs EASA's duty-length-based minimum (a 6-hour duty legally demands only 12 h rest at home base — but EASA never allows the "8 h sleep" core to be traded the way US reduced-rest proposals would).
Discretion power sits with different actors: FAA gives the PIC + company a +2 h pre-takeoff extension for unforeseen circumstances; EASA gives the commander +2 h (3 h augmented) largely after the operation has started, with the company owning the schedule.

Flying a US-registered aircraft in Europe (or an EASA-registered aircraft into the US)? The applicable FTL scheme follows the operator's certification, not the aircraft's route — check whose rules your trip is planned under before comparing "max FDP" numbers.

Run the FAA side in the calculator

Part 117 verified against eCFR (current); EASA values per ORO.FTL.205/210/235, Commission Regulation (EU) No 83/2014 as consolidated. Schemes may differ — always check the operator's approved FTL scheme. Educational only.