Da Magic:

While your effort is noble and your letter eloquent, consider what outcome may result--perhaps opposite of what you intended.

I think your intent is to (somehow) legally force airlines to increase pay, which would (hopefully) reduce the number of commuters/jumpseaters, as they could then afford to live in lovely domiciles such as Newark. Or, give those who commute more days off to accomodate their commute.

And your argument is that commuting results in crews showing-up at the last minute, or sleeping illegally in the crew lounge, which could lead to an accident.

In an economic doldrum like this, I think it unlikely that Congress would force private enterprise to raise wages for "professionals." Oh, they'll raise minimum wage, which sounds good on paper. But the real result is that if wages go up, the employer keeps his payroll expenses even by laying-off more workers. The ones that kept their jobs got a raise--the rest lost theirs. Similar in this industry.

But I could see them enacting FARs that would require pilots to report to the crew desk the actual time they arrived from jumpseating, and there would be rest minimums; they couldn't call you out until the time had elapsed. They might go so far as to require you to provide a verifiable address to prove where you stay(ed). Violations would be hefty fines or loss of license.

It might force you to commute two days before a trip or reserve cycle.

And, if you're like me, that would mean I would be home perhaps ONE to THREE days a month, as my schedule is likely to be mostly two and three-day breaks in reserve duty.

No one would stand for that, so the airlines would have to build a second set of scheduling rules for commuters. They would have longer breaks in their schedules, and as such, might not get as many work days or hours. ALPA would have to negotiate the new guarantees for commuters--which I could see as being as low as 15 working days a month and 45 hours.

Which means they would be poorly-paid, again.

I have a heinous commute. I don't have faith in the industry to sell my house and move...and houses aren't selling, anyway. Hell, I've been assigned 4 domiciles in the last 10 years. I commuted in good faith, and have always made it. I always got a good night's sleep when I got to my domicile, too. And I would not have hesitated to call in fatigued or sick if it just didn't work.

I will write my letter to ask for protections against reprisal for those who commute, due to the poor wages, and the fear of recrimination if they do call in tired. I will suggest that airlines acknowledge that in some domiciles, a full 50% of all pilots commute (example: SFO for UAL), and the company cannot make them use up a day-off to guarantee compliance with a new FAR. Rather, they will have accept the possible loss of a reserve/line-holder due to the nature of the business, when a pilot tries to commute in good-faith but can't get on the flights. This might require tracking of CASS (and modification thereof) to show when a commuter actually did commute, or attempted to, but didn't get on.

We need to be careful what we ask for. Without commuters, this industry will collapse. We just need to protect them so they get adequate rest.