ALPA duty time proposal to FAA
 

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:
Flight Duty Period: Non-augmented Operations
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.

Sadly it did not format right. Not sure how to fix it.

It was interesting to hear some of the comments on these issues yesterday at the meeting. I will say, that some of them better not get though.

This looks more like what the ATA would want not ALPA. This will result in fewer pilots at the majors IMO.

ALPA talks a good line, but when it comes down to brass tacks, they're a bunch of concessionist pussies.

Couldn't get the formatting to work either...

Are you still here? I thought you were going for a fast-food Engineer position?

Can you explain your statement? This requires shorter duty days and longer rest periods. The only change where you can do more is if you report in the morning between 0700 and 1259 you can fly up to 9 block hours. That has no real impact on jobs.
The one big change is that it will force many pilots to fly more days per month to get their hours in. This is always a downside of better work and rest rules.

When is this new set of regulations suppose to take effect? Is there a projected date or time frame?

Nothing is official until it is official. Rumor was Dec 31, 2010. We will wait and see.

I'm assuming this was taken from the ALPA Fastread email. I'm not sure if I'm missing something from it, but in that proposal they say min rest at 10 hours, but they don't really define when rest would begin. It better be 10 hours behind the door because this garbage of rest being defined as time away from the aircraft needs to end.

"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."

If it's this :

http://public.alpa.org/portals/alpa/...15_9-24-09.pdf

(and I'm pretty sure it is)

that ALPA is talking about, I'd say it's an improvement, but misses some key issues. I'd personally rather see them just cut-and-past the British rules rather than cherry-pick some of their provisions, but this is certainly better than nothing.

At the very least, these rules would protect pilots who are subject to the worst and most dangerous circadian-disrupting, fatigue inducing schedules in the industry . . . i.e., regional airline pilots.

I find it interesting that a DAL pilot is a co-chair but there is no Delta signature at the end of the document.

I agree, but probably not as much as you'd think. Unless I'm mistaken (very possible), while the per-day flight hours would be raise, the monthly and yearly limits of 100/1000 would still be in place.

There's definitely the lurking possibility of the "law of unintended consequences" that will lead to all kinds of surprises if something this sweeping is instituted.

Here is ALPA's:
ALPA, Intl. FastRead

You know EVERY single company out there is going to schedule to the max; OK so we can fly more; what about food/bathroom? were not machines; people need brakes. I think these rules are still going to screw us in the end......

With the exception of the increase in flight time allowed on a 7 am to 1 pm report every other aspect is more restrictive. With the much shorter duty times its actually going to be hard for airlines to build as much flying as current rotations. I would expect this is going to mean more days worked per month. That is a consequence you always get from better rest and reduced flying times. There is nothing in this rule that I see which could cause a loss of pilot jobs.

Help me out here.

In the ALPA suggestion there are 6 hours in the day that you can be scheduled for more block time than current rules, but for the vast majority of operators the allowed duty period is less. Under the ALPA recommendations, 9 hours of the day scheduled block time is less than current regulation, but allowable duty time is reduced even more than most contracts currently contain!

I see this as a big step forward. Of course the ATA wants something different, they are management. But science isn't on their side. I really like the "experience" they refer to in the last sentence of the letter...:rolleyes:

Breaks would also be good. :)

Scoop - Also often a victim of fast typing on a laptop.

Personally, I prefer BOTH. :p

There is some negative impact on most of the majors. Most of the Europe flights back to the US East Coast can now be flown 2 pilot. I don't remember the last time I was SCHEDULED over 13 hours anyway, so I suspect that our schedules won't change much, if at all. My prediction is this is going to be a net negative for our manpower at UAL.

I'm dismayed to see that there is no provision to lower the monthly/yearly flight time limits, and I don't see any change to Whitlow. I guess ALPA didn't learn anything from Little Rock. Hopefully by the time the final language is written, this will be addressed.

Hi!

Actually, the Regional guys do NOT have it the worst.

I just did a bunch of research, and wrote a report on the Fligh/Duty/Rest issues, and am sending it out to Congress and to some reporters.

The guys who have it the worst at Part 91 guys, who have NO Flight/Duty/Rest rules. So, when they fly commercially, they can be scheduled by their managers for WHATEVER the managers want. NO rules, NO union...they can be ROYALLY screwed!

Next up are the -121 Supplemental guys:
Any Regional guys on reserve for 240 hours CONSECUTIVELY, and then called for a 16 hour+ day? I didn't think so. That's one of the problems they have!

cliff
NBO

I think that the augmentation rules were left untouched, i.e. > 8 hours = 3 pilots. There is a lot more to this report, ALPA only published some representative tables to counter the air carriers that put out their version yesterday. As they said in the fast read, everyone was supposed to wait until the FAA published their NPRM. Since the carriers broke their promise, ALPA probably wanted to get out something to counter their position lest it become generally accepted as a consensus opinion. According to one of the ARC participants, the report is quite detailed and cannot be described in a short period of time. I recommend again that everyone wait for the full report before making any substantive conclusions.

Yeah, I hope so! It would be insanity to think 2 pilots would be better rested than 3 after an all-nighter across the Atlantic and going into a busy app. environment like LHR, CDG, FRA or AMS. Amazing how any regulatory scenario promoting safety through increased rest could possibly entertain the idea of reducing augmented crews on 8+hrs flights through 6 time zones!

True. But right now, most (notice I said most) of the better CBA's out there have language that is more restrictive than current regs. Hopefully (notice again, hopefully) those CBA's get rewritten to to be more restrictive than the proposed changes.

However, It would be nice to get a trip/duty rig so as not to kill time off. Yeah, I know, not likely.

Is it me or is this all this incredibly over-complicated? Why can't it be something simple like "10 hours of rest, max scheduled 8 hours in a 14 day?" Change the numbers for 3 man crews and what not but just make is simple. With this proposal we'll all be looking at charts to figure out if we're legal or not. Way too much thought process for something that should be a no-brainer.

Just like trying to calculate runway distance down to the foot, if you gotta get it that precise is it even worth it?

No thanks. Under your proposal, I could work three straight 14 hour days, even with those days starting at 9pm. I'll take what ALPA came up with; the company can easily program their computers as is already done at DAL.

The document you're looking at is the management proposal, not the ALPA or the ARC proposal. The co-chair of the ARC is Captain Don Wycoff, the ALPA Executive Administrator, and he didn't endorse that document that you're reading, which is why he didn't sign it. His name would be attached to the ALPA document, not the management document.

It's not THAT complicated, and if you're working for a decent carrier, all of this is just going to go into a scheduling computer program anyway.

Besides, this is all supposed to be "scientific", not "simple". I'd like to hope that these new rules have some grounding in objective fatigue research, not just a splatter on the wall and see what sticks.

I'm afraid the detailed specificity is because if you count on carriers (and to some degree, pilots) to do the right thing that common sense would dictate, 95% will, and then 5% won't.

Thank you, 5%.

Thanks. I just found it a bit odd. That makes sense.

Hmmm. What about the all the 8.5 hour turns to the Caribbean? Now they're 3 man crews because of the 8 hour rule. They will go to 2 man crews now and cut hundreds of lines and jobs at many of the majors. Not to mention many other city pairs.

I'll say it again. ALPA is a bunch of concessionist pussies. They've done more to damage what's left of this profession than the execs.

Your take on the east coast flights is incorrect. If you look at when most flights to and from Europe depart and arrive in the US it will actually increase augmentation required on the Europe flights. The only flights out of JFK that can get by now with 2 man crews are to the UK. They will now require a 3rd pilot as they will be restricted to 7 hours max on at least one of the 2 legs.

At the majors, the new proposed rules would be a net even number of jobs. Between the reduction in scheduled duty periods and block hours during most parts of the day, and the slight increase in block allowed for a small part of the day, staffing requirements won't be affected much at all.

For the regionals, though, staffing needs will likely increase at most carriers, because the duty periods are reduced much greater, since many of them allow 14-15 hour duty days now.

Obviously you didn't "clear" your comments with them before posting...:D

I don't have to clear anything with a bunch of jerkoffs like ALPA. And if you don't think a 9 hour day will cost jobs and cause pilots to fly fatigued, you're naive or nuts. ALPA is either bought off or just plain stupid. Given the recent past, it's apparent to me that ALPA has now become nothing but company poodles.

Pilots never cease to amaze me. ALPA offers a proposal that reduces the max duty day from 16 hours to as low as 9 and a max of 13, and we've got idiots complaining about it. Unbelievable.

I think what you're seeing is frustration of a small minority of pilots who had some sort of fantasy that new rest/duty time rules would result in thousands of pilots being hired by the majors and the regionals.

Not only was this unlikely to happen, the purpose of these rules changes is safety, not featherbedding. If anything, rule changes that forced massive hiring to support existing routes would probably cause a reduction in flying, not an increase in hiring. There's no money in the till.

You said it well. I have no idea what guys wanted. I also don't see their logic. Flying 9 hours a day has no effect on manning. Pilot jobs are based on the number of block hours needed in that airlines system. If you fly more in a specific number of days you get a better schedule. The company still needs the same number of pilots to fly the same number of block hours.

Why does the heading of the chart read "Maximum Flight Duty Period (hours) for Lineholders Based on Number of Flight Segments"? Are they proposing something different for reserves?

not it the idiotic 30/7 rule was removed an we were allowed to fly 10 hours day with a 90 hour/month 850/year limit with no extension for any reason on duty times.

Okay, then get your own union and negotiate a better rig. Quit whining about the work done by others, get off your fat rump and do it yourself.