ALPA has been trying to modernize the flight- and duty-time regulations for nearly 25 years, working with Congress, the Federal Aviation Administration, the International Federation of Air Line Pilots’ Associations, and the International Civil Aviation Organization to develop a model FTDT rule. These efforts culminated in June when FAA Administrator Randy Babbitt appointed members of labor, industry, and government to the FAA Aviation Rulemaking Committee. He charged the ARC with completing a comprehensive review of the current flight-time and duty-time regulations.
During the past two months, seven ALPA pilots from cargo, international, domestic, and regional airlines played a critical role in the ARC, which completed its work on September 1 with a group agreement to
not release any information concerning recommendations to the FAA so that the agency could begin crafting a Notice for Proposed Rulemaking (NPRM). ALPA honored the information blackout, but other ARC participants chose to ignore it.
“While it remains our desire to not address any of the
information that has been recently leaked in interviews to the press,” said Capt. Don Wykoff (Delta), who co-chaired the ARC, “we do feel that it is now appropriate for our members to review some of ALPA’s positions on these issues as well.”
ALPA’s 6-point recommendation plan focused on securing the following for our members: (1) one rule for all airline pilots, not “carving out” the cargo and supplemental operators; (2) a minimum 10-hour rest period; (3) a reserve rest rule for all pilots; (4) having multiple segments and circadian rhythm disruptions addressed; (5) establishing limitations on duty periods, flight duty time, and block time based on the fact that excessive working hours affect flight safety; and (6) requiring the operator to prepare and publish reliable schedules.
“We must have a single rule for all types of flying: domestic, international, and supplemental,” said Capt. John Prater, ALPA president. “There is no basis in science, nor is there a true operational need, to have separate rules.”
ALPA’s recommendations, based on operational experience and scientific study, incorporate ICAO and IFALPA guidelines and represent a comprehensive framework, in concept and in detail, of a flight- and duty-time and rest requirement rule. The concepts within your union’s recommendation demonstrate a scientific way of addressing both short-term and cumulative (long-term) fatigue safeguards for all operations.
Other concepts that ALPA addressed included a non-punitive provision for pilots to be removed from flight duties when they are fatigued, and a fatigue education program. ALPA is also proposing the following block and flight duty-time limits, as well as a 10-hour minimum rest.
Maximum Flight Time (Block) Limits:
Time of Report (Home Base) Maximum Flight Time (hours)0000–0459 70500–0659 80700–1259 91300–1959 82000–2359 7
Flight Duty Period: Non-augmented Operations
Time of Report (Home Base or Acclimated) Maximum Flight Duty Period (hours) for Lineholders Based on
Number of Flight Segments 1 2 3 4 5 6 7+0000–0359 9 9 9 9 9 9 90400–0459 10 10 9 9 9 9 90500–0559 11 11 11 11 10 9.5 90600–0659 12 12 12 12 11.5 11 10.50700–1259 13 13 13 13 12.5 12 111300–1659 12 12 12 12 11.5 11 10.51700–2159 11 11 10 10 9.5 9 92200–2259 10.5 10.5 9.5 9.5 9 9 92300–2359 9.5 9.5 9 9 9 9 9
While the ARC has submitted a report to the FAA administrator as the next step in the process toward issuing a Notice for Proposed Rule Making, several important steps remain in the process to create new flight-time and duty-time regulations, including putting the proposed rule out for public comment. The NPRM is expected to be published by the end of the year, according to statements made by Babbitt. ALPA will remain fully engaged in the process, and we will keep you updated on any further developments.
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