ALPA/ATA proposal may not comply with FAR 25.1309...

Date:         10 Jul 99 02:33:34 
From: (William Mac Gree)
Organization: SkyPoint Communications, Inc.
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I have learned that the proposition of the FAA concerning the extension
of ETOPS supposed a limit In flight Shut down (IFSD)  of 0.019 per 1000
hours, which is slightly bellow the actual performances of the latest
generation of ETOPS aircrafts. What I'd like to know is if this measure
complies with FAR 25.1309 considering the longer mean diversion time over
the North Pacific routes ?