3:45 on the JFK Tarmac and Delta's AWOL
#61
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I have no earthly idea whether we were refueling. I know we were not standing in line -- we stood in line for the first couple of hours, then moved to a vacant "holding" area on the tarmac. All I know is that we were parked a long way from the terminal, with an open door and no gate-thingy or stairs. Disembarking, even if it had been allowed, would have been about a 20' drop. I can't imagine that's what DOT had in mind by the "opportunity to deplane" rule.
#62
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I don't know either how DOT interprets the word "begins": it could mean starting the process of getting permission to return to the gate (which would be independent of whether the door is open) or it could require actual movement of an aircraft or jetway in which case this could not happen while the door is open. If it's the former case, an aircraft could be parked at the gate and require a GA to open the door, but if a GA doesn't appear for an additional ten hours, should the carrier get a free pass?