Petition to Oppose Part 117
#11
Line Holder
Thread Starter
Joined APC: Jun 2007
Position: MD-11 Captain
Posts: 31
Yep decided hanging out on these forums and some its trolls was not productive. That's why I did something instead of trolling about it. Read the website. Don't agree? Don't sign it. I'm out for another 12 years.
When your head is buried in the sand there's a high likelihood of activity you may not enjoy near your rear end.
Here's one excerpt from http://saynoto117.com:
The 1/14/2020 Fastread strikes a similar bullet from the same sheet of talking points: "One hazard of supporting broad science-based flight time duty time regulations is the reality that those rules may not support behavior that you, the Company, and/or ALPA deem safe."
Translation: The MEC knows and you know week-on/week-off night hub turns are safer than doing a maximum of three hub turns (the limit in Part 117) and having more frequent circadian rhythm shifts. They also know that those week-on/week-off night hub turn lines won't be allowed under Part 117.
The update goes on, : "Importantly, there is the possibility built into Part 117 that an Alternate Means of Compliance (AMOC) can be obtained to deviate from the rule. The AMOC allows data collection to prove that operating outside the limits of Part 117 are demonstrably as safe or safer within the context of an individual operation, thus nullifying the one size cannot fit all arguments."
Nope. The possibility of AMOC doesn't nullify those arguments one bit. Not unless you know going in what AMOC would be approved and how long it would take to get it approved. Unbelievably, in the next sentence, they admit they have no clue about AMOC going in: "Since we cannot know which AMOCs will be sought or accepted, absolute forecasting of the effects of 117 are impossible."
Again, this approach is a huge a gamble. AMOC's can take years to get approval and given the heightened scrutiny on the FAA after the 737 Super Max debacle, don't expect the FAA to be bending over backwards to grant waivers to the rules. Buying a "fixer upper" is not a good move if you don't know fixing up is even possible or how much it'll cost.
When your head is buried in the sand there's a high likelihood of activity you may not enjoy near your rear end.
Here's one excerpt from http://saynoto117.com:
The 1/14/2020 Fastread strikes a similar bullet from the same sheet of talking points: "One hazard of supporting broad science-based flight time duty time regulations is the reality that those rules may not support behavior that you, the Company, and/or ALPA deem safe."
Translation: The MEC knows and you know week-on/week-off night hub turns are safer than doing a maximum of three hub turns (the limit in Part 117) and having more frequent circadian rhythm shifts. They also know that those week-on/week-off night hub turn lines won't be allowed under Part 117.
The update goes on, : "Importantly, there is the possibility built into Part 117 that an Alternate Means of Compliance (AMOC) can be obtained to deviate from the rule. The AMOC allows data collection to prove that operating outside the limits of Part 117 are demonstrably as safe or safer within the context of an individual operation, thus nullifying the one size cannot fit all arguments."
Nope. The possibility of AMOC doesn't nullify those arguments one bit. Not unless you know going in what AMOC would be approved and how long it would take to get it approved. Unbelievably, in the next sentence, they admit they have no clue about AMOC going in: "Since we cannot know which AMOCs will be sought or accepted, absolute forecasting of the effects of 117 are impossible."
Again, this approach is a huge a gamble. AMOC's can take years to get approval and given the heightened scrutiny on the FAA after the 737 Super Max debacle, don't expect the FAA to be bending over backwards to grant waivers to the rules. Buying a "fixer upper" is not a good move if you don't know fixing up is even possible or how much it'll cost.
#13
Gets Weekends Off
Joined APC: Jul 2005
Position: CA
Posts: 534
Yep decided hanging out on these forums and some its trolls was not productive. That's why I did something instead of trolling about it. Read the website. Don't agree? Don't sign it. I'm out for another 12 years.
When your head is buried in the sand there's a high likelihood of activity you may not enjoy near your rear end.
Here's one excerpt from http://saynoto117.com:
The 1/14/2020 Fastread strikes a similar bullet from the same sheet of talking points: "One hazard of supporting broad science-based flight time duty time regulations is the reality that those rules may not support behavior that you, the Company, and/or ALPA deem safe."
Translation: The MEC knows and you know week-on/week-off night hub turns are safer than doing a maximum of three hub turns (the limit in Part 117) and having more frequent circadian rhythm shifts. They also know that those week-on/week-off night hub turn lines won't be allowed under Part 117.
The update goes on, : "Importantly, there is the possibility built into Part 117 that an Alternate Means of Compliance (AMOC) can be obtained to deviate from the rule. The AMOC allows data collection to prove that operating outside the limits of Part 117 are demonstrably as safe or safer within the context of an individual operation, thus nullifying the one size cannot fit all arguments."
Nope. The possibility of AMOC doesn't nullify those arguments one bit. Not unless you know going in what AMOC would be approved and how long it would take to get it approved. Unbelievably, in the next sentence, they admit they have no clue about AMOC going in: "Since we cannot know which AMOCs will be sought or accepted, absolute forecasting of the effects of 117 are impossible."
Again, this approach is a huge a gamble. AMOC's can take years to get approval and given the heightened scrutiny on the FAA after the 737 Super Max debacle, don't expect the FAA to be bending over backwards to grant waivers to the rules. Buying a "fixer upper" is not a good move if you don't know fixing up is even possible or how much it'll cost.
When your head is buried in the sand there's a high likelihood of activity you may not enjoy near your rear end.
Here's one excerpt from http://saynoto117.com:
The 1/14/2020 Fastread strikes a similar bullet from the same sheet of talking points: "One hazard of supporting broad science-based flight time duty time regulations is the reality that those rules may not support behavior that you, the Company, and/or ALPA deem safe."
Translation: The MEC knows and you know week-on/week-off night hub turns are safer than doing a maximum of three hub turns (the limit in Part 117) and having more frequent circadian rhythm shifts. They also know that those week-on/week-off night hub turn lines won't be allowed under Part 117.
The update goes on, : "Importantly, there is the possibility built into Part 117 that an Alternate Means of Compliance (AMOC) can be obtained to deviate from the rule. The AMOC allows data collection to prove that operating outside the limits of Part 117 are demonstrably as safe or safer within the context of an individual operation, thus nullifying the one size cannot fit all arguments."
Nope. The possibility of AMOC doesn't nullify those arguments one bit. Not unless you know going in what AMOC would be approved and how long it would take to get it approved. Unbelievably, in the next sentence, they admit they have no clue about AMOC going in: "Since we cannot know which AMOCs will be sought or accepted, absolute forecasting of the effects of 117 are impossible."
Again, this approach is a huge a gamble. AMOC's can take years to get approval and given the heightened scrutiny on the FAA after the 737 Super Max debacle, don't expect the FAA to be bending over backwards to grant waivers to the rules. Buying a "fixer upper" is not a good move if you don't know fixing up is even possible or how much it'll cost.
#14
Line Holder
Thread Starter
Joined APC: Jun 2007
Position: MD-11 Captain
Posts: 31
"would largely not apply to our operations"...A quick glance at our bidpack tells a different story. There are specific requirements to be able to do 5 nights. Many of our week-on/week-off night hub turns DO NOT qualify for the 5 days under 117. So three night hub turns max. Do you think the Company is then going to lay you over somewhere for 36 hours to give you a nice weeklong pairing or send you back to domicile for 36 hours without pay?
Site analyzes a sample line in the Feb 2020 Bidpack: http://www.saynoto117.com/potential-impacts.html
#15
If 117 does away with those 11:30 night hub turns 4-5 days in a row its a good thing.
I wonder how closely our schedules matched 117 before we gave away SIG SLA in 08?
117 will produce schedules I like and provide more rest when I am at work...hope it happens.
Last edited by MEMA300; 01-28-2020 at 08:07 AM.
#17
Gets Weekends Off
Joined APC: May 2018
Posts: 210
I just re-read them. I don’t see an obligation to agree with everything proposed by ALPA. Either enough ALPA members sign to show that we aren’t all unified in pursuing 117 for cargo....or enough won’t. Since ALPA hasn’t polled us or better yet had a vote on whether to pursue this legislation, this might be the only consolidated feedback they get. That being said, write your block reps and the MEC officers of your support or opposition to 117. Perhaps encourage them to get a 100% poll before they pursue this. Maybe the guys/gals doing this petition will share the results with ALPA before going outside in an effort to give them one more data point on the sentiment of the crew force they represent. Just like VB, this does not appear to be a unanimous issue or even a slam dunk issue. I hope it doesn’t divide us unnecessarily before contract 2021...which will actually be contract 2026!
#18
I just re-read them. I don’t see an obligation to agree with everything proposed by ALPA. Either enough ALPA members sign to show that we aren’t all unified in pursuing 117 for cargo....or enough won’t. Since ALPA hasn’t polled us or better yet had a vote on whether to pursue this legislation, this might be the only consolidated feedback they get. That being said, write your block reps and the MEC officers of your support or opposition to 117. Perhaps encourage them to get a 100% poll before they pursue this. Maybe the guys/gals doing this petition will share the results with ALPA before going outside in an effort to give them one more data point on the sentiment of the crew force they represent. Just like VB, this does not appear to be a unanimous issue or even a slam dunk issue. I hope it doesn’t divide us unnecessarily before contract 2021...which will actually be contract 2026!
#19
Gets Weekends Off
Joined APC: May 2018
Posts: 210
#20
Gets Weekends Off
Joined APC: Nov 2017
Posts: 2,099
We've beat 117 dead in another thread, so all I'll say is that there is no guarantee that our schedules will be any safer under 117. Unintended consequences as addressed in the web site above are a very big threat.
Adding 1000 pilots to what appears to be a correctly staffed FedEx sounds like the regulators introducing a pretty significant level of inefficiency into our system form. Inefficiency is a two way street. Of course the company isn't going to like it. But, does that mean we will? Homogeneous, city pure hub-turn pairings built into week-on/week-off schedules are efficient for pilots too. In my experience, efficient schedules (that comply with our already safe CBA) means less work days per month and less circadian swaps - that in and of itself could be argued is less fatiguing. But now, potential inefficiency is a good thing because while we'll still be inefficient, we'll be able to "out-inefficient" our competition like Atlas? Genius.
But, I'd like to understand how you think adding pilots due to 117 is going to make you more senior. Unless 117 is going to magically drum up additional business and as a result, additional flying, how is adding 1000 pilots to deal with regulatory requirements make you more senior?
Pilots below you are a furlough buffer. If there's enough flying to build 900 lines, 50 reserve lines and 50 secondary lines and no flying is added but 200 pilots are, show me how #900 gets more senior. He's still got 899 pilots ahead of him scooping up the same trips he wants. Still gets to pick his vacation behind the same 899 pilots.
You want an end to 16 hour extensions, get some extra sleep time on the turns and 10 hours behind the door no matter what, then negotiate it in our next contract - or just call in fatigued if it happens tomorrow. Effing up our schedules with inefficiencies just to get those "one-offs" that don't happen that often doesn't seem too smart.
Adding 1000 pilots to what appears to be a correctly staffed FedEx sounds like the regulators introducing a pretty significant level of inefficiency into our system form. Inefficiency is a two way street. Of course the company isn't going to like it. But, does that mean we will? Homogeneous, city pure hub-turn pairings built into week-on/week-off schedules are efficient for pilots too. In my experience, efficient schedules (that comply with our already safe CBA) means less work days per month and less circadian swaps - that in and of itself could be argued is less fatiguing. But now, potential inefficiency is a good thing because while we'll still be inefficient, we'll be able to "out-inefficient" our competition like Atlas? Genius.
But, I'd like to understand how you think adding pilots due to 117 is going to make you more senior. Unless 117 is going to magically drum up additional business and as a result, additional flying, how is adding 1000 pilots to deal with regulatory requirements make you more senior?
Pilots below you are a furlough buffer. If there's enough flying to build 900 lines, 50 reserve lines and 50 secondary lines and no flying is added but 200 pilots are, show me how #900 gets more senior. He's still got 899 pilots ahead of him scooping up the same trips he wants. Still gets to pick his vacation behind the same 899 pilots.
You want an end to 16 hour extensions, get some extra sleep time on the turns and 10 hours behind the door no matter what, then negotiate it in our next contract - or just call in fatigued if it happens tomorrow. Effing up our schedules with inefficiencies just to get those "one-offs" that don't happen that often doesn't seem too smart.
We shouldn’t have to negotiate for safety. Think about that concept: negotiate for our own safety?
And you keep ignoring human factors in fatigue. Calling in fatigue is not always as easy as you make it out to be. And it’s insidious, so once you are fatigued your judgement is impaired, and making it more difficult to sense your own fatigue level. The point of 117 is to keep management AND the pilot from making their schedule fatigue prone. And then making it easier for any pilot to call in fatigued if they still have to by empowering them with an actual regulation that states specifically and unequivocally that the pilot decides whether they are fit to be extended beyond 30 minutes.
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