wags3539

For those of you planning on commenting on these proposed rules, the FAA has listed a number of issues they would like to receive comments on. They were even nice enough to number them in the document to make it easier for me to find them. Sorry for the small font, but this is copied directly from the .pdf. The following is painful to read through, but I would urge anybody who has anything to say about this rule, to take the time to go through the document. It shouldn't be too difficult to come up with something for at least each of the points that would affect you.

(2) Please comment on permitting
flightcrew members and carriers to
operate beyond a scheduled FDP. Is the
proposed 2-hour extension appropriate?
Is the restriction on a single occurrence
beyond 30 minutes in a 168-hour period
appropriate? Should a flightcrew
member be restricted to a single
occurrence regardless of the length of
the extension? Please provide
supporting data.

(3) Please comment on the proposed
schedule reliability reporting
requirements. Should carriers be
required to report on crew pairings that
exceed the scheduled FDP, but not the
maximum FDP listed in the FDP table?

(4) Should carriers be required to
report on more parameters, such as
cumulative duty hours or daily flight
time? If so, why?

(5) What should be the interval
between reporting requirements?

(6) How long after discovering a
problematic crew pairing should the
carrier be afforded to correct the

scheduling problem?

(7) Is a 3-day adjustment to a new
theater of operations sufficient for an
individual to acclimate to the new
theater?

(8) Is a 36-hour break from duty
sufficient for an individual to acclimate
to a new theater?

(9) Should flightcrew members be
given a longer rest period when
returning to home base than would
otherwise be provided based on moving
to a new theater?

(10) Should the FAA have different
requirements for flightcrew members
who have been away from their home
base for more than 168 hours? If so,

why?

(11) Should the FAA require
additional rest opportunities for
multiple pairings between two time
zones that have approximately 24-hour
layovers at each destination? What if the
scheduled FDPs are well within the
maxima in the applicable FDP table or

augmentation table?

(12) If the FAA adopts variable FDP
limits, is there a continued need for
daily flight time limits?

(13) If the FAA retains daily flight
time limits, should they be higher or
lower than proposed? Please provide
data supporting the answer.

(14) Should modifications be made to
the proposed flight time limits to
recognize the relationship between
realistic flight time limits and the

number of flight segments in an FDP?

(15) Should augmentation be allowed
for FDPs that consist of more than three
flight segments? Does it matter if each
segment provides an opportunity for
some rest?

(16) Should flight time be limited to
16 hours maximum within an FDP,
regardless of the number of flightcrew
members aboard the aircraft, unless a
carrier has an approved FRMS?

(17) Should some level of credit be
given for in-flight rest in a coach seat?
If so, what level of credit should be
allowed? Please provide supporting
data.

(18) Is there any reason to prohibit
augmentation on domestic flights
assuming the flight meets the required
in-flight rest periods proposed today?

(19) Are the proposed required rest
periods appropriate?

(20) Should credit be allowed if a
flightcrew member is not type-rated and

qualified as a PIC or SIC?

(21) Please comment on whether a
single occupancy rest facility provides a
better opportunity for sleep or a better
quality of rest than a multiple
occupancy facility such as a multi-bed
crew sleeping facility or multi-bed
living quarters. Please provide

supporting data.

(22) Should there be any restriction
on consecutive nighttime operations? If
not, why?

(23) If the nighttime sleep opportunity
is less than that contemplated under the
split duty provisions of this notice,
should a carrier be allowed to assign
crew pairing sets in excess of three
consecutive nights? Why or why not?

(24) If the nighttime sleep opportunity
meets the split duty provisions of this
notice, should the carrier be allowed to
extend the flight duty period as well as
the number of consecutive nighttime
flight duty periods? Why or why not?

(25) Should a fourth night of
consecutive nighttime duty be permitted
if the flightcrew member is provided a
14-hour rest period between nights three

and four?

(26) Please comment on whether a 16
maximum hour FDP for long call reserve
is appropriate when the maximum FDP
for a lineholding flightcrew member is
13 hours.

wags3539

system.

(32) The FAA also asks for comments
on measuring limits on an hourly rather
than daily or monthly basis. Does this
approach make sense for some time

periods but not for others?

acl65pilot

I stuck the comments link. If you want this one stuck too, let me know.

Pozrategearup

Thanks! The comments link sticky should be good enough.

Nevets

Just to point out the concerns I have with the NPRM:

I like the idea of having the rest time begin when we are our rest facility. But 9 hours is still not enough. Nine hours at the hotel does not provide for an 8 hour sleep opportunity because it is not enough time for personal hygiene, physiological needs, mental/emotional needs (time to decompress and or call family/freinds), nutrition (dinner and breakfast), and exercise. This rest period has to be a minimum of 10 hours at the rest facility/hotel. Also, the way I read the proposed regulation it doesn't account for the travel time back to the airport. It says the rest period is measured from the time the pilot arrives at his rest facility. So if I arrive at my rest facility at 2100 for a 0600 show time, this would suffice even though a transportation time of 0500 may be required to arrive at show time. Lastly regarding the rest period, how does the FAA contemplate enforcing this? How will the company know what time the pilot arrived at his rest facility? Will the pilot have another burden of having to call crew scheduling? Just from my experience at XJT, this phone call can take up to 45 minutes. This would not be acceptable. Maybe a better approach would simply be to require a 12 hour rest period measured as it is now. Also, instead of 30 consecutive hours of rest in 7 days, it should be one calendar day or 30 hours of rest, whichever is greater, in order to give enough time to recover (maybe this may alleviate Steve's concern about having to work more days?).

As for being able to fly 10 hours for un-augmented crews, they should hold the line with the ALPA proposal that only allows 9 hours but also reduces it to 7 hours for red eye flights type flight/flights during WOCL.

There should be no extensions allowed to FDP. If there is going to be an extension, it should only be able to be solicited by the ENTIRE flight crew (if they all agree, NOT JUST THE PIC as the current proposed regulation is written) and it should only be one hour. Extension should only be allowed once per week regardless of length, none of this 30 minutes or less nickle and dime BS. To allow extension up to 15 hours doesn't help much than what we currently have. Also, these extensions only happen during high stress and high workload type situations such as weather or mechanical type delays. Its is counter intuitive to allow such long FDPs during these specific situations. I also feel that the FDP should be limited to 8 hours for red eye flights and only extendable if there are 6 legs or less, just like they do in other countries. The FDP tables should be adjusted by rounding down all numbers to the nearest hours to get rid of half hour increments in order to simplify it for the flight crew and company. All these flight time and FDP limitations are going to be hard enough for pilots to keep track of especially when they are all now rolling hours rather than calender days/months/years. They should also increase the un-acclimated penalty to be increased to 1 hour rather than the 30 minutes. Lastly, the Whitlow type limitation should be placed on this as well on flight time limits also. No more good to start good to finish of any kind!

The pilots, captain or first officer, should be the ONLY people to be able to determine their own fatigue. You can have the worlds renowned expert on pilot fatigue and yet they couldn't tell me how fatigued MY BODY feels. The proposed regulation under fitness for duty must be changed to prevent anyone else other than the pilot himself to determine his own fatigue! Also, there must be NO appearance or actual discipline, retaliation, or financial ramifications of any pilot calling in fatigue. It must be a no fault fatigue policy for this to be effective. Just as we do when we use ASAP when calling in fatigue. The chief pilot is taken out of the process and its given to the ERC to investigate whether fatigue was caused by the pilot. There are many reasons why it seems as though the pilot should have gotten adequate rest but didn't such as a medical condition or a disturbance at the hotel, and on and on.

The NPRM also said that the carrier can require a flightcrew members to spend the night prior to starting a series of FDPs within the local area if the carrier became aware the flightcrew members were commuting during the WOCL. (Pg 5585 This is unacceptable and should NOT be allowed under any circumstances!!! The accompanying Fit For Duty Advisory Circular proposes "If the crewmember starts their commute into their domicile after 0559, and their flight duty period starts at any time within a 7-hour window, the crewmember will not be required to have rest prior to their assigned flight duty period. However, if the crewmember’s assigned flight duty period starts more than 7 hours after 0600, the crewmember must receive required rest in accordance with § 117.25 before their flight duty period. In the case of a flightcrew member commuting during the night through their window of circadian low, that crewmember must also receive a required rest period in accordance with § 117.25 before starting their assigned flight duty period." THIS MUST BE REMOVED FROM ANY PUBLICATION!

The limitation of 60 hours of duty in the last 168 hours seems a bit high to me on fist glance. I don't know what it should be or if its too high but it sounds like an un-augmented crew can theoretically have 48 hours of flight time in 168 hours and be legal. That just sounds high to me. It also seems to me that there must be more of a flight time and FDP penalty given for operating during the WOCL. Credit for split duty should only be given for temperature and light controlled, lay flat bed, single occupancy facility. The FAA seems to think that single occupancy is not their problem yet I'm sure Babbitt or ANYONE in the FAA never get anything else other than single occupancy accommodations when they travel of their desk job. The fact is that some people snore or have flatulence (I could go on with other physiological phenomena but I wont) that would not allow others to get adequate sleep. On board class II rest facility should also be temperature and light controlled with 100% lay flat bed for maximum credit. And the Class II credit should be rounded to 50% for simplicity of calculation. Lastly, the carriers should be required to report on duty hours and flight times. We have been told that these regulations are comprehensive and should be viewed as a whole. So if we want to continuously validate these regulations, the carriers should be forced to report comprehensively on all the aspects of the regulation and not just schedule integrity, since that is just one aspect of fatigue mitigation. If we want to get serious about fatigue, we need to hold the carriers feet to the fire on this.

Lastly, the reserve rules seem to be a little complicated. There needs to be a way to either make these regulations simpler or write them in such a way that a regular line pilot can understand them in order to follow them without having to use advanced calculus.

atpcliff

Hi!

In response to the above post: When on an overnight, Duty starts the next day in the lobby of the hotel at checkout, so travel time back to the airport IS accounted for.

12 hours of rest, with the current rules, is not good enough, as sometimes it takes 2+ hours to get to the hotel from the airport.

cliff
MIA

STILL GROUNDED

As for the post 2 above... If you can't get some rest with 9 hours actually at the hotel you should be calling fatigued prior to starting any pairing with anything less then a 10 hours over night on your schedule. I'd love 9 hours at the facility. The current program with 8 hours starting 15 minutes after you park to 30 minutes before push ends up with leaving you 6 hours at the hotel on a Atlanta reduced rest over night for example.

9 in the facility is much better, that is like a scheduled 10 hour over night without rushing around. My concern is we go to far to the left on this thing and next thing you know we are all down to 12 days a month off because they can't get an efficient schedule with the long required over nights. The other thing is I am not making any money in a hotel, I don't want to be in a hotel and I certainly don't want to be in one for 12 hours at a time EVERY night of the 4 day. I've seen all I can see in walking distance from these dumps they put us in these days.

We have to get this right because fixing it after wards is going to be an act of congress.

I am all for ALPA sticking there nose in this but if they aren't going to represent the guy making $40 bucks an hour how can we assume they will care about the pay cut we'll take when our monthly min goes to 65 because that's about all they can schedule us for.

Nevets

Yeah, that was exactly my point. It does NOT account for travel back to the airport. As for 12 hours not being enough, I would be ok with requiring 10 hours at the hotel. The only question with that is how would it be enforced. I don't want to see another burden put on the pilots by the FAA in order to enforce it.

Supposedly, the NPRM was written with scientific data input. Science says that its best if our bodies receive 8 hours of sleep preferably during WOCL. So my point is that if the rule is going to take science into the equation, we must be given a minimum 10 hours of uninterrupted rest at the hotel.

Unfortunately for our pocket books, money should not enter the equation. Sadly, this will have to be dealt with by negotiation duty and trip rigs along with minimum monthly guarantees, and minimum days off into our contracts. The fact that you don't get paid for being in a hotel is just because you do not have trip/duty rigs. Some airlines do have those.

By the way, while you are at it, maybe you should recommend your NC to put some hotel language in your contract so that you are not stuck in dumps in the middle of nowhere.