Will NPRM comments matter
10-01-2010, 01:11 PM
#1
Gets Weekends Off
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Joined APC: Dec 2009
Position: Capt
Posts: 2,023
Will NPRM comments matter
Just spent quite a bit of time reading over the comments on the NPRM with regards to duty/flight time and I would estimate over 95% are opposed to the 10 hour increase and over 90% do not like the 9 hours of rest. Do comments matter or is a done deal.
10-01-2010, 04:56 PM
#6
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Joined APC: Jul 2009
Posts: 96
The comments do matter but are minor. Like iceman said it depends how much horsepower is behind it. The NPRM process recognizes that the different lobbying groups get in early and participate in the writing of the NPRM (normally a couple years). The comments are a way to let the general public comment. Do they listen-- yes. If an overwhelming number of comments say no to the 10 hour duty, they will look to see if one of the groups was "suggesting" it to their respective folks. If it appears to reflect general concensus, they'll take it into consideration. The age 65 NPRM showed the politics of the process. Virtually nobody in the US wanted the age 65 but the ICAO had switched and the FAA was in a bind to harmonize the FARs so....it didn't really matter what anybody wanted--it had to happen.
10-02-2010, 11:45 AM
#7
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Joined APC: Feb 2010
Position: Dispatcher / Meteorolgist
Posts: 49
Comments matter
I have been posting comments, mostly attempting to correct the FAA's omissions and oversights too tighten up the loopholes so they have truely one set of rules as as opposed to loose and vastly diverse interpretations that exist today, forget the politics you will lose.
I use the information the FAA has provided in the formulation process, you know the scientific studies, CAP 371 etc.
I understand pilots, concerned about flying in excess of 8 hrs with 2 pilots, or greater than 12 with 3, but I am not a pilot, just a mere programmer whom has to create the scheduling system to account for the changes.
If you really believe that it is unsafe dont just say it but use the evidence provided, or other valid evidence to prove your point, that is how you get the change you deserve.
Good luck, and comment well and often.
I use the information the FAA has provided in the formulation process, you know the scientific studies, CAP 371 etc.
I understand pilots, concerned about flying in excess of 8 hrs with 2 pilots, or greater than 12 with 3, but I am not a pilot, just a mere programmer whom has to create the scheduling system to account for the changes.
If you really believe that it is unsafe dont just say it but use the evidence provided, or other valid evidence to prove your point, that is how you get the change you deserve.
Good luck, and comment well and often.
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