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Old 01-26-2012, 07:02 PM   #1  
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Default What’s Behind The Crew Rest Rule’s Lower Pric

What’s Behind The Crew Rest Rule’s Lower Price Tag?
Aviation Week & Space Technology Jan 23 , 2012 , p. 17
Andrew Compart

Printed headline: The Cost Of Sleep

When the FAA finally issued a new crew rest rule for U.S. pilots in December—one that has been decades in the making and could become a model for the rest of the world—something was very *different from the proposed rule the agency published in September 2010: The cost.

The difference was dramatic. In the rule as originally proposed, the FAA estimated airlines’ 10-year cost at $1.3 billion—which, it should be noted, the U.S. airlines argued was wildly underestimated and instead would have amounted to nearly $20 billion. But in the analysis the FAA provided with its final rule, its 10-year cost estimate was a relatively modest $390 million.

Similarly, part of the reason for the higher cost estimate in the original proposal was that the FAA assumed the airlines would need to hire a lot more pilots to comply with the new fatigue-avoidance mandates. The agency never estimated how many, but American Airlines alone claimed it would need 2,300 more.

The FAA’s new estimate for how many more pilots U.S. airlines will have to hire? Zero.

This could account for why the U.S. airline industry has remained pretty quiet—at least so far—about the impact of the new rule. But what did the FAA change to lower the projected costs? Is it realistic?

One factor—which is of no help to passenger airlines—is the agency’s decision to exclude cargo carriers from the new mandates.

The FAA did not separately state a cost for cargo carriers when it performed the cost analysis of its proposed rule in 2010. But in its analysis of the final rule that excludes them—because the FAA says the cargo carrier costs would far outweigh the rule’s life-saving benefits for planes carrying no passengers—it estimates the cargo carrier cost would have come to $306 million.

But eliminating cargo carriers from the rule does not come close to explaining the entire difference. The estimated training costs dropped dramatically, from $262.3 million in the proposed rule to $16 million in the final rule. Obviously, that is not solely because cargo carrier costs no longer are included. The figure also reflects the FAA’s removal of the proposed rule that pilots must receive additional fatigue training that carriers are already required to provide under fatigue risk-management plans.

Together, by dropping cargo carriers and amending training rules, at least $568 million is now out of the estimate.

The actual amount removed by those changes is higher, because the separate cargo carrier cost estimate is based solely on the somewhat less-stringent final rule. Even so, the difference between the 10-year estimated cost in the proposed and final rule is $864 million, so other factors must also be in play.

One of them is the estimate for the new rule’s impact on the cost of flight operations. Under the proposed rule the estimate was $760.3 million; under the final rule, it is $236 million.

In its regulatory analysis of the final rule, the FAA says inclusion of the cargo carriers would have added $240 million. That means something else accounts for about $284 million of the flight operations cost reduction.

The FAA says a few changes in the final rule regarding crew scheduling “significantly reduce the cost to the industry.” One is that the final rule allows up to a 2-hr. extension beyond a pilot’s flight duty period limits for unexpected circumstances that arise after takeoff. Another is the removal of a proposed requirement that “circumstances beyond the control” of the airline have to be present in order to utilize the 2-hr. extension for certain unforeseen operational circumstances.

The final proposal also alters the maximum flight-duty period limits for unaugmented operations. That had ranged from 9-13 hr., based on the time a pilot starts on a day and the number of flight segments. The final rule is 9-14 hr., with increases for certain start times within that range.

For example, the maximum for pilots starting their day between 5:00-5:59 a.m. ranges from 10.5-12 hr. in the final rule depending on number of flight segments; in the proposed rule, it had been 9-11 hr.. For 6:00-6:59 a.m., the range is 10.5-13 hr. instead of 10.5-12 hr.

With that additional flexibility built in, the FAA simulated the final rule’s impact by inputting the new limits and industry scheduling data into a Cygnus crew-pairing optimization system. Cygnus has been used by more than 30 major airlines worldwide over the past 40 years and remains widely in use.

“The crew-pairing optimization did not show a need to hire new crewmembers to comply with this rule, because the flight crewmembers currently used in reserve allow certificate holders to conduct operations under this rule without hiring additional [pilots],” the FAA says.

If that assessment proves accurate, airline management will sleep better than they had expected under the new rules, too.

It seems that some math refinements and/or good ole lobbying caused the FAA to adjust their rest/duty/flight times from 2010 to 2011. No more hiring forecast for the new Reg’s.

Last edited by flyinpigg; 01-26-2012 at 07:06 PM. Reason: Formatting
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Old 01-27-2012, 05:55 AM   #2  
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Human lives is a small price to pay when it comes down to saving $$. Once more our government, and corporations, bow to the "KING"...The all mighty DOLLAR......
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Old 01-27-2012, 06:12 AM   #3  
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Originally Posted by LittleBoyBlew View Post
Human lives is a small price to pay when it comes down to saving $$. Once more our government, and corporations, bow to the "KING"...The all mighty DOLLAR......
I think that two hour extension is at PIC's discretion.

Just say "NO"!

But yes this rest rule change is a big game of whack a mole. MGMT will take the time to re-adjust the schedules to take advantage of the new loop holes. Voila
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Old 01-27-2012, 06:30 AM   #4  
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Originally Posted by cal73 View Post
I think that two hour extension is at PIC's discretion.

Just say "NO"!

But yes this rest rule change is a big game of whack a mole. MGMT will take the time to re-adjust the schedules to take advantage of the new loop holes. Voila
Even with the 2 hour discretion the new FTDT rules are more restrictive, especially with hard throttle up block times. While its impossible to not to see how the ATA (A4A, whatever) exerted its massive influence in mitigating the new rules, I can't see how it will result in zero new pilot positions across the entire industry.

The new rules contain a few very limited reliefs on current regs but that appears to be more than offset everywhere else. The only real "give back" over current rules is the 9 hour block 2 man ops, but with that being a hard time at throttle up with no relief under any circumstances, and with duty limits under the current 16 anyway, how can this be 100% manning neutral?
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