Adlerdriver

FedEx has in the past and I believe efforts are still on-going. The corporation conducted some kind of sleep/fatigue study quite a few years back (it had a name - maybe associated with the firm conducting it - but I can't remember). They never shared the findings with the pilot group and the rumor was they didn't paint a very good picture - so, best to leave that behind the green door.

In the last few years, it seems like there have been more transparent efforts to gather information. ALPA and FedEx have been collecting data by soliciting crewmembers to wear monitoring devices for specific trips series. They also have them utilize computer programs before and after flying to measure motor skills. I don't think any sort of report or findings have been released to the pilot group as of yet or if that's even the plan.

TonyC

And why shouldn't they fight to keep the Cargo Carve-Out in place? They lobbied to have it put there in the first place.

14 CFR Part 117 applied to everyone until it got to the OMB, and that's when numerous parties argued it would be too expensive, or at least more expensive than the loss of a couple of cargo pilot lives.

You didn't hear about it from your MEC Chairman at the time because we were too busy trying to be nice to The Company so we could get a better CBA -- you remember the "Interim Discussions", right?

The thing is, the meetings with the White House's Office of Management and Budget are a matter of public record.

OMB Meeting Records

OMB Meeting Records - Selected agency: Federal Aviation Administration

Between July 22 and November 14, 2011, some twelve meetings were held on the topic of "Flight and Duty Time Limitations and Rest Requirements Rule" or "Crewmember Flight Duty and Rest Requirements Rule." Click on any one of them (except the 3rd, see below) and you can see who attended, and you can see and "Meeting material provided to the OMB."

On July 22, Bob Bergman and Michael Kiely of UPS argued (Pilot Flight and Duty Time NPRM -- Summary of UPS Concerns) "The FAA's proposed rule on pilot flight and duty time imposes great costs on UPS and other air cargo carriers and provides virtually no safety benefits, if any."

On July 25, Jim Bowman of FedEx appeared with other representatives to the Air Transport Association to argue (Briefing for Office of Information and Regulatory Affairs (nice slide presentation -- excellent reading)), among other things, to remove daily flight time limits and permit "split duty" rest on the ground for a minimum of 2 hours.

On that same day, representatives from ALPA National (the link to the meeting is "broken" on the OMB website, so use this link instead: https://www.whitehouse.gov/omb/2120_meeting_07252011b ) also presented their side. (Office of Management and Budget -- Flight Limitations Briefing) Captain Lee Moak, ALPA President, and Captain Don Wykoff, Co-Chair, FAA Flight and Duty Time and Rest Requirements Aviation Rulemaking Committee, argued the NPRM was based on current sleep science, a committee of sleep scientists provided by industry and labor and scientific knowledge provided by the FAA. They highlighted the fact that Supplemental Ops had suffered 103 accidents in the last 20 years, 27 of which occurred between midnight and 6 AM. Their bottom line: The rule should be implemented based on safety, not on certain carrier's desire to maintain a competitive advantage due to archaic rules with no basis on science or operational experience.

The following day, representatives from a number of airlines argued (Fatigue Risk Management Systems (FRMS) will not be a panacea for nonscheduled airlines) Fatigue Risk Management Systems would be no good and (CRAF Crew Rest Study:Proposed FAA Changes) the proposed rule changes would make it impossible to carry out the CRAF program missions. Ironically, they admit (on Slide 14 of 21) "The proposed rules allow for better fatigue mitigation ..." They also took a swipe at ALPA (E-Mail thread from A. Oakley Brooks, President, National Air Carrier Association and ALPA One Level of Safety print advertisement in Politico), accusing ALPA of going to lengths to "scare people into a 'one size fits all' flight and duty rule."

Jim Bowman was back on the 26th along with Steven Taylor. For those who don't recognize that name, he's the Vice President, Regulatory and Industry Affairs at FedEx Express. (Psst, MEC ... he wants you to support FedEx (and oppose ALPA) in their support of Open Skies.) Also present were Roger Quinn of UPS, a couple of guys from Atlas Air, a couple of representatives of Cargo Airline Association and their attorney from Kirkland & Ellis, LLP. Indeed, this was a presentation by the Cargo Airline Asscociation, "The [self-proclaimed] Voice of the Air Cargo Industry." They provided a prepublication copy (Uncorrected Proofs) of the National Research Council of the National Academies study entitled "The Effects of Commuting on Pilot Fatigue" and their (the CAA's) 4½ page "summary" (POINTS FROM NATIONAL RESEARCH COUNCIL STUDY ON THE EFFECTS OF COMMUTING ON PILOT FATIGUE) including, "Aviation is an extraordinarily safe mode of transportation" and "little evidence that fatigue has caused aviation accidents." They also provided a Motion to Reopen Record and the FAA's response (Dennis R. Pratte, Acting Director, Office of Rulemaking, to Mr. Stephen A. Alterman, President, Cargo Airline Association, dated July 1, 2011). Finally, they included a nice slide presentation, (Flightcrew Member Duty and Rest Requirements -- Presentation to the Office of Management and Budget by: CARGO AIRLINE ASSOCIATION - The Voice of the Air Cargo Industry) in which they argued that the proposed rules would "provide virtually no safety benefits, produce far greater costs than benefits, and are not based on accepted scientific principles." The CAA argued that all-cargo pilots fly far fewer hours, do not transport "passengers" (yes, they used quotation marks), involve relatively few take-offs and landings, and have significantly more opportunities for rest. They also argued that there were no fatigue-related accidents since 2003. The balance of their arguments were focused on how much it would cost the industry.

Three representatives of the Allied Pilots Association met with the OMB on August 1. No meeting material was provided.

On August 8, five representatives of the Coalition of Airline Pilots Associations (CAPA) met to applaud Congress and the FAA's efforts to revise the outdated Flight and Duty Time regulations, to express their support of "One Level of Safety" and and rules based on existing science, and to support final implementation of the NPRM to establish the United States as world leaders in aviation safety. (Coalition of Airline Pilots Associations - - Flight Time and Duty Time Regulations: Summary Statement) CAPA also expressed concern about some of the flawed assumptions and exaggerated costing analysis submitted to the FAA by some operators. They noted one airline had already programmed the proposed rules into their crew scheduling software and found a negligible impact on crew scheduling practices. They were quite emphatic is stating, "Fatigue does not discriminate between types of operations, aircraft type or what is being carried on the aircraft; and neither should safety regulations. CAPA is strongly opposed to any type of 'carve-out' that would exempt any operator from complying with the rules proposed in the NPRM. This is particularly true for operators that transport our troops, all-cargo operators and charter operators. The NPRM currently contains a provision (§117.31 Operations into unsafe areas), which could permit operations under unique circumstances that could not otherwise normally be conducted. Additionally, §117.1 establishes an FRMS process for so carriers can operate outside prescriptive regulations for unique circumstances."

On August 17, David Bronczek (he's the President and CEO of FedEx Express Corporation, by the way) appeared before the OMB with David Abney of UPS, representatives from Atlas Air, JetBlue, American Airlines, Evergreen Airways, and three representatives of the Air Transport Association, They presented a Proposal for Non-Randomized Study of the Effectiveness of FAA Proposed Regulations Regarding Cockpit Crew Fatigue from Donald B. Rubin, PhD, Department of Statistics, Harvard University. Although they also included the same ATA 17-slide presentation from their July 25 meeting, which drew conclusions and made recommendations, the good doctor proposes a 2-year study is needed before proposing changes. He compared the proposed rules with the implementation of the national 55 mph speed limit.

On September 13, seven representatives of the Families of the victims of Colgan Air Flight 3407 appeared before the OMB and FAA Representatives. If you don't click on any other link in this post, click on this one.



On October 12, representatives of American Eagle and American Airlines met with the OMB to argue that the NPRM (§117) and the proposed "1,500 hour rule" would increase the demand for pilot staffing industry-wide. Among other proposals, they wanted to be able to extend pilots 2 hours a day, and not include time spent on short call reserve as duty.


On October 27, another contingent of ALPA representatives appeared before the OMB, this time without the President. Only one FedEx ALPA member was present. (The same guy who told us in TA videos we already have "real time trip trading.") No meeting material was provided.

Finally, on November 14, Robert Travis, William C. Trent, and Lauren Esposito of the IPA and their counsel, Jim Hall, met with the OMB. No meeting material was provided.


In summary, our Director of Flight Operations (at that time) took the time to go to Washington, D.C., and lobby against us not once, but twice. Our Vice President, Regulatory and Industry Affairs, lobbied against us. Our President and CEO lobbied against us.

Our MEC Chairman was a no show.


So, they're lobbying against us again -- no surprise.

The question is, what are we going to do about it this time?






.

birdstrike

Who need fatigue research. UPS just sends boxes of money to D.C.