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Old 02-25-2010, 09:06 AM
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Default Why new FT/DT rules are taking so long...

This might be old but I stumbled upon the January issue of Air Transport world magazine. They interviewed Randy Babbitt and asked him about the new FT/DT rules. Here is what he had to say.


Can you provide an update on the status of the new flight duty time regulation? The Aviation Rulemaking Committee made its recommendations in September. When might we see a Notice of Proposed Rulemaking?


We take those recommendations and we have to convert them to regulatory language. We also have to do a cost benefit analysis. Then we turn it over to the Office of the Secretary [of Transportation]. Eventually it goes before the [Office of Management and Budget] and then we put it out as an NPRM. I'm hopeful that we can get it out early in 2010. One of the issues that we've run into has been that it's a complicated cost benefit analysis because you essentially have to ask carriers to run these models in their software. You have to see what the cost side of it is, meaning if we implement these changes and do nothing else, would it in fact require more pilots?

ATW Interview: Randy Babbitt

This infuriates me to no end. The FAA's job is not to see if the airlines can afford a change. This is proof that SAFETY does not come first. Cost is number 1. Completely unacceptable.
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Old 02-25-2010, 09:51 AM
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This infuriates me to no end. The FAA's job is not to see if the airlines can afford a change. This is proof that SAFETY does not come first. Cost is number 1. Completely unacceptable.[/quote]


Mission statement of the FAA from their website:
Our continuing mission is to provide the safest, most efficient aerospace system in the world.


Actually the FAA is supposed to see if the airlines can afford a change. You and I disagree with that, but that is part of their mission. Unfortunately, Safe and efficient are generally polar opposites when it comes to this industry, but you know which side the FAA will come down on.
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Old 02-25-2010, 09:55 AM
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This is unreal.... I guess we know where the FAA's priorities lie. I was naive to think that having Babbitt head the FAA after being ALPA president and a 25 year airline guy would be a good thing. They must be feeding him some good lobster on the hill.
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Old 02-25-2010, 10:04 AM
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"Cost" MUST (repeat MUST"|) be a component of every rule. If safety were the total, over-riding concern, the planes wouldn't fly. Ever.

It would be "safer" to have a complete maintenance inspection after every flight. It would be "safer" to have the engines boroscoped after every flight. Conduct a D check weekly. Pilots should be in the simulator once a week, a check ride every month, and an astronaut flight physical before each leg. Drug testing at the start of each trip, with the crewmembers quarantined until the results are back. Put a check airman in the jump seat of every leg. I could go on. All of these measures would improve safety. They are also excessive to the point of "unreasonable." No airline could operate, and the transportation system would collapse.

They are (and should) looking at the cost of each proposal and compare it to the relative benefit (i.e. improvement in safety) that comes with each idea.

Careful what you ask for. They could say things like no more commuting-- Pilots must live within 30 minutes of the airport. No drinking, even off duty. A GPS device that records a pilot’s location and movements in the 12 hours prior to departure. I can come up with LOTS of ideas that would put safety “Number One,” but you get the idea…
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Old 02-25-2010, 10:14 AM
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Originally Posted by ClipperJet View Post
"Cost" MUST (repeat MUST"|) be a component of every rule. If safety were the total, over-riding concern, the planes wouldn't fly. Ever.

It would be "safer" to have a complete maintenance inspection after every flight. It would be "safer" to have the engines boroscoped after every flight. Conduct a D check weekly. Pilots should be in the simulator once a week, a check ride every month, and an astronaut flight physical before each leg. Drug testing at the start of each trip, with the crewmembers quarantined until the results are back. Put a check airman in the jump seat of every leg. I could go on. All of these measures would improve safety. They are also excessive to the point of "unreasonable." No airline could operate, and the transportation system would collapse.

They are (and should) looking at the cost of each proposal and compare it to the relative benefit (i.e. improvement in safety) that comes with each idea.

Careful what you ask for. They could say things like no more commuting-- Pilots must live within 30 minutes of the airport. No drinking, even off duty. A GPS device that records a pilot’s location and movements in the 12 hours prior to departure. I can come up with LOTS of ideas that would put safety “Number One,” but you get the idea…
This would trigger people leaving the industry en mass and would cripple the transport world. As close to house arrest as you can get without a conviction
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Old 02-25-2010, 10:15 AM
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Originally Posted by ClipperJet View Post
They are (and should) looking at the cost of each proposal and compare it to the relative benefit (i.e. improvement in safety) that comes with each idea.
I agree with that statement to a point. However, when you have rules in place from 60 years ago that are less stringent than those for truck drivers or ICAO for that matter, something is wrong. I don't think it is too much to ask for to put into place fair rules that are based on scientific study of circadian rhythms, number of TO/LA per day, etc. I highly doubt that the staffing levels would need to change that much, depending on how efficient each airline schedules.
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Old 02-25-2010, 10:34 AM
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Originally Posted by ThrustMonkey View Post
This would trigger people leaving the industry en mass and would cripple the transport world. As close to house arrest as you can get without a conviction
Exactly my point. But it would "make sure we were at home" (30 mins from the airport) and "resting" before flying.

I think folks have this "expectation" that the new rules will say the airlines have to work us less, pay for a hotel when we commute, more days off, etc., all while paying us the same or more.

The rules that come out are likely to be very unpopular among the pilots...
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Old 02-25-2010, 11:32 AM
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Originally Posted by ClipperJet View Post
Exactly my point. But it would "make sure we were at home" (30 mins from the airport) and "resting" before flying.

I think folks have this "expectation" that the new rules will say the airlines have to work us less, pay for a hotel when we commute, more days off, etc., all while paying us the same or more.

The rules that come out are likely to be very unpopular among the pilots...
Ahhhh not a problem. Just let Renee use a grinder, and remove the device from your wrist (You don't need a thumb to fly do ya?) LEave said device at the crashpad... (I can have ALL my meals delivered there) JS on another airline, and pick up said device on the way to the airport, and viola'... Other than the blood and severe pain thingy... I think it's a pretty sound plan.
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Old 02-25-2010, 12:20 PM
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Originally Posted by shfo View Post
This might be old but I stumbled upon the January issue of Air Transport world magazine. They interviewed Randy Babbitt and asked him about the new FT/DT rules. Here is what he had to say.


Can you provide an update on the status of the new flight duty time regulation? The Aviation Rulemaking Committee made its recommendations in September. When might we see a Notice of Proposed Rulemaking?


We take those recommendations and we have to convert them to regulatory language. We also have to do a cost benefit analysis. Then we turn it over to the Office of the Secretary [of Transportation]. Eventually it goes before the [Office of Management and Budget] and then we put it out as an NPRM. I'm hopeful that we can get it out early in 2010. One of the issues that we've run into has been that it's a complicated cost benefit analysis because you essentially have to ask carriers to run these models in their software. You have to see what the cost side of it is, meaning if we implement these changes and do nothing else, would it in fact require more pilots?

ATW Interview: Randy Babbitt

This infuriates me to no end. The FAA's job is not to see if the airlines can afford a change. This is proof that SAFETY does not come first. Cost is number 1. Completely unacceptable.
It's Federal Law as per Executive Order 12866. All proposed Federal Regulations must undergo a cost benefit analysis.

Economic Analysis of Federal Regulations Under Executive Order 12866
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Old 02-28-2010, 09:09 AM
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Default They have it all tied up with the Lawyer's:

Typical Beltway methods. Delay, Delay, Delay.
This what they told Congress 1-Feb-2010.

Fatigue: In July 2009, the FAA charted an ARC to develop recommendations for an FAA rule on
pilot flight and duty time. The ARC met its September 1, 2009, deadline and provided the FAA
with a broad framework for drafting a Notice of Proposed Rulemaking (NPRM) that the agency
planned to publish by December 31, 2009. The FAA now plans to publish an NPRM in April 2010.

http://transportation.house.gov/Medi...204/SSM_Av.pdf
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