I don't think it is extendable. Your max duty will vary based on your scheduled flight time for the day, so it may be less then 13.

I am sure the FAA looked at most companies contracts and came up with an average of what we already have. Then put together this new law. Now they can go to congress and tell them what a bang up job they did, hand out pay raises and go back to doing what they do best. Nothing.

A company could probably require that you live in a certain geographic area as a condition of employment but airline's don't WANT to do that...it would drastically reduce their pool of applicants (depending on the domicile) and would require higher wages in long run.

The government however, has no legitimate basis for making such a requirement. Cops can be required to live in their jurisdiction, but that's because they want their stabilizing presence, it's not to babysit them. It wouldn't hold up in court.

They will actually not be able to do this either, I think it would run afoul of legal requirements for consistent treatment of all employees. They cannot just require the commuters to be "in domicile" ten hours early...what the hell is "domicile"?

Also being present in domicile does not guarantee rest, if I arrive early do I go to sleep? No, I go to the gym :rolleyes: What about the local guys who stayed up to party the night before (while I went to bed early because I had an early commute), or the guy with the screaming baby who's up all night? There's no way to apply that fairly.

They only way they could do this would be to require ALL flight crew to arrive at a company-provided rest area 8-10 hours early to ENSURE that rest occurs. That would actually be just fine with me...but I will damn well get PAID block for it :D

Then what about layovers? It would be arbitrary (and therefore probably illegal) to apply silly rules on day one but not regulate layovers. The hotels would have to track our comings-and-goings and provide a report to the company to ensure we are getting rest behind closed doors. The internet, cable TV, and most lights would of course be de-activated during rest hours.

Actually I was told by someone who should have some insight that the FAA dropped any attempt to regulate commuting early on in their review process. There was no way to do it fairly and legally and the airlines would have been opposed because it would drive up labor costs.

The Bloomberg article matches exactly with what I heard. I'm OK with ten flight hours as long as there is a leg limit (preferably two). If I'm allowed to be on duty anyway, may as well get paid.

So based on this alone, essentially they eliminated reduced rest, made changes that we all already have, and upped the block allowed in the day. Looks like things got worse. Hopefully the announcement has more details that are missing here. When considering the fact that the next change could be in 2050, I'm pretty disappointed so far.

I like what I see, but...

Have they changed max allowed in 7, 30 days, and for the year? If it gets reduced we take a pay cut!

give me two 4 day trips at 35 hours a piece. Good thing!

MOD INPUT: I merged the two threads on this subject, into the regional forum thread which was larger and started first.

Unfortunately this "public comment period" aka "airlines counter offer" period will end with something less restrictive than what the proposal is. The airlines will fight tooth and nail over the 9-13 hr max duty day.

Two of my better trips this month won't be allowed under this proposal. A very productive 3 day trip and a great CDO/Highspeed/nap.

A downside to this proposal is that only the really bad naps with a short RON will still be legal. The great naps that pay well will no longer comply. In addition, it will be very hard to build productive 3 day trips, especially for those airplanes that primarily do short legs. Get ready for more 4 day trips.

Like someone said earlier - be careful what you wish for. Those of you that seem to think you are going to get paid more (or the same) to fly less hours with the same number of days off, you might be dreaming...if you think this means working 8 hour days, like the rest of the world, then you can probably plan on two days off a week, like the rest of the world.

that is where contract negotiations come in right? We have these fantastic unions that will help! :) time will tell really on that, but i think its better than what we have, interesting for the fee for departure players too!

That is a risk in the short term, but ultimately they can't just take away all of our days off and put us on the road five days a week long-term. I would quit, unless the pay was really spectacular ($300K+) and then I'd only do it long enough to accumulate a big nest egg.

The "two days off a week like everyone else" argument does not hold water at all because "everyone else" gets to go home at night, or even at lunch, or in the afternoon if their kid gets sick.

Some people think pilots will just keep taking it in the shorts, but at some point we really will just walk away. This would be the equivalent of putting all of us on a really crappy reserve schedule with daily callouts...for life. Folks only put up with that for a finite period of time, and they only do it in order to get something better down the road.

I think the airlines know this too.

This forum is all discombobulated between the major, regional, cargo, etc. sections.

People are still discussing the fatigue rule possibilities and meanwhile the thread with a direct link to the actual proposal itself is locked and gone, nowhere to be easily found.

Here is the link to the proposal again:

http://www.faa.gov/regulations_polic...2010_22626.pdf

There are some charts at the bottom.

Ummm....no. Contracts have duty rigs, min days off, etc & it will stay that way. 8 days off a month. That's hilarious.

It's an exagerration to prove a point. Contracts are negotiated. If you think that you can squeeze the balloon on one end and get shorter work days, fewer hours flying, and still make the same annual salary without compromising QOL, then you are delusional.

I know it doesn't make sense. I posted a NEW thread in the regional and the major forum so that people could get the LATEST info instead of clicking on a thread in just the regional forum that says COMING SOON that everyone is going to stop reading. Sorry folks I tried to get the new info out there so everyone could see it.

For those flying internationally:

Minimum Rest Prior to Duty - International: 9 hours
Maximum Flight Duty Time - Unaugmented: 9-13 depending on start time and number of flight segments
Maximum Flight Duty Time - Augmented: 12-18 depending on start time, crew size, and aircraft rest facility
Maximum Flight Time - Unaugmented: 8-10 depending on FDP start time

There's nothing that says this could never happen.

Exactly. When has the FAA or any company done anything to make pilot's lives easier?

The only things I'd like to see are 9 hard hours once at the hotel and regulations for WHEN the flying is done. IE Day 1: 5:30am show, done at 4pm, Day 2: 4pm show fly till 8pm, Day 3: 6:00am show. While the first and second day here aren't an issue that third day feels like death. after a late show it's hard to force the body to sleep on a min rest overnight for an early show.

The rest can be negotiated for in contracts.

Nice of them to think of the reserves. Basically no change. You can have a 16 hour duty day. Good thing my contract protects me more than the FAA.

Huh? Are we talking about the same thing here? Now that the proposed rules are out, and closely mirror the ALPA proposal, let's take an example shall we?

IAD-BRU. Leaves around 5PM, so max duty un-augmented is 13 hours and 10 hours (ridiculous) of flight time. No problem.

BRU-IAD. Time change is 6 hours. Scheduled departure is 12 noon, or 6 AM body clock time. Showtime is 1.5 prior, so 4:30AM. Flight time is 8:15, so illegal for 2 pilots.

But what if UAL moves the departure back to 12:30, which still easily feeds the bank in IAD? Then the show time is 5AM, which allows for 9 hours of flight time and 11 hours of duty, both easily accomplished. Do you think UAL would move the departure time back 30 min if it meant saving a pilot?? Hell, the thing left at 12:37 today and will have no problem with connections. Most Europe destinations will now be doable with 2 pilots with minor schedule tweaking.

Thanks ALPA. How many more mainline jobs is this going to cost?

Is there a carve out for supplemental and/or cargo? Or do we finally treat everyone the same?

As someone who has had the opportunity of constantly and consistantly operating to the absolute minimums of the rest regulations, this is my opinion. It's the bottom feeders that are a big part of what make this necessary (at least the sections of the proposed regulations that would apply to my operations). Those airlines that view the minimum regulations as an operational goal, rather than minimums to be rarely used, and only during IROPs; those airlines who have absolutely no regard for safety, beyond what the regulations require. You might say,"Hey, your airline is just trying to make money." Yes, but how much further ahead will they be, when we pile one in? Trading safety for money; it's not a wise investment. I have flown 12 legs in a day. I have waited 1.5 hours for a hotel shuttle during reduced rest, to operate 8 legs the next day, with a dead-head thrown in there. I have flown all night (6 legs, 15 hours of duty) on a stand-up overnight that was originally scheduled for 4 legs (with added repos/ flagstops, etc.). I have made numerous informational reports to my company, regarding fatiguing pairings and schedules, and have never received any acknowledgement, or response. These are just a few of the situations that I seem to always find myself in. Why do I not call in fatigued? If I called in fatigued for every fatiguing situation I'm placed in, I don't think I would ever complete a trip. Sometimes, you just don't know you're fatigued until you're in the aircraft, at the controls, and start noticing how many things you are missing; how poor your situational awareness is becoming; how poor your scan is, etc. Plus, start making numerous fatigue calls, and you can certainly expect to be on the company blacklist...good luck on your next PC, buddy, and you can forget about ever having the opportunity to make LCA. Yes, I operate under a crappy CBA. However, the level of safety of my passengers shouldn't be so heavily dependent on the quality of my CBA. Passengers don't buy tickets based upon the scheduling rules in a CBA. They buy tickets fully expecting that all airlines operate under the same level of safety, whether it's a bottom feeder, or top of the industry. For those who have operated to the very minimums of the regulations on a constant basis, I'm sure you understand what I'm talking about.

Fully agreed, and understand your plight. I did the commuter thing as well, and it's atrocious. This new rule will go a long way to improving the QOL at the crappiest carriers, and that is the segment that needed the most improvement.

What I struggle to understand is why ALPA decided to make things worse on the other end at the potential cost of the higher end pilot jobs. I'm not sure how many pilots UAL will be able to shed if this passes, but it will be a decent amount. Sigh. It's been a long decade.

The ALPA proposal of INCREASING allowable flight time combined with age 65 are both good reasons to FIRE Prater and get some new leadership. Two of the biggest changes in our careers and Prater and his cronies blew it. I am pro union, just not the leadership of this union.

I'm glad someone could put an actual pairing up here to back me up. People talked about how these rules would increase staffing but as of right now I don't see how it won't decrease staffing. If all they have to do is push back the departure time 30 minutes, it a no brainer what their going to do. Its funny how the creating of these rules were based on pilots working to long and hard and now fewer pilots will be needed to do the same amount of flying.

If you take a look at the footnotes on page 43 it explains why there are two charts there. One is from the industry, one is from ALPA.

Take a look at page 44, ALPA is proposing a maximum of 8 in the situation you described.

It is going to come down to the comment section on what is the final rule.

Got it. I see where you are now. I do wish ALPA hadn't even proposed anything with the flight time over 8, but you are right. It's going to come down to the comment.

The rule as written puts IAD-CDG, FRA, AMS, LHR, BRU in play with 2 pilots and marginal tweaking, and IAD-GVA and ZRH in play with a little extra tweaking. That's just at UAL! Add CAL at EWR, AMR and DAL at JFK, and US at PHL and you have hundreds of pilot jobs at stake here. Hopefully ALPA will repond appropriately. We will see.

I know this affects everyone and I haven't read through the document but are these new rules better or still worse than ICAO rules?

That is incorrect. It will depend on what time of the day the flight departs. Most flights that will be allowed to fly over 8 hours will have to depart at 8 or 9am. That means transcons. Also, there would be a limit on duty hours, like 13 hours max per day, and only 2 legs. If you do a 10 hour roundtrip, with an hour on the ground in LAX, that doesn't give you much wiggle room for running out of duty day. For North Atlantic crossings and allnighters in general, the regs will be tighter.

''''''
From DOT Secretary LaHood

Welcome to the FastLane: The Official Blog of the U.S. Secretary of Transportation

September 10, 2010

Landmark rule to manage pilot fatigue
will help protect 700 million air passengers each year

Today, we're announcing a significant improvement in air travel safety: a proposal to fight fatigue among commercial pilots. This will help protect the more than 700 million passengers and pilots who travel our nation's airways each year.
As you may recall, managing fatigue was a top priority in our Airline Safety Call to Action following the tragic crash of Colgan Air flight 3407 in February 2009. We held a dozen safety forums all across the US. We've talked with safety experts, aviation specialists, and fatigue scientists. And I'm pleased that we have addressed this issue.


The proposed rule also incorporates input from an Aviation Rulemaking Committee with members from labor, industry, and the FAA. As Administrator Randy Babbitt said, "Fighting fatigue is the joint responsibility of the airline and the pilot, and after years of debate, the aviation community is moving forward to give pilots the tools they need to manage fatigue and fly safely."
Key new features of the proposed rule include:

• One consistent rule for domestic, international, and unscheduled flights
• A nine-hour opportunity for rest prior to duty (a one-hour increase over current rules)
• New approach to measuring a rest period that guarantees the opportunity for eight hours of sleep
• Different requirements based on time-of-day, number of scheduled segments, flight types, time zones, and likelihood that a pilot is able to sleep

Features to manage cumulative risk include:

• Weekly and monthly limits on duty time of any kind
• Thirty consecutive hours free from duty every week (a 25% increase over current rules)

The proposed rule also gives pilots the right to decline an assignment if they feel fatigued--without penalty.
The FAA has also prepared guidance for air carriers who are required by Congress to develop a Fatigue Risk Management Plan.
One important aspect of our proposed rulemaking is that it will be open for public comment. So please weigh in at www.regulations.gov.





----

So here is where we still won't be getting "8hrs of sleep". Under definitions:

Rest period means a continuous period determined prospectively during which the crew member is free from all restraint by the certificate holder, including freedom from present responsibility for work should the occasion arise.

So basicly still sounds like it is NOT behind the door rest.

From a regional puke, I also see what you are saying as well. If we could limit it to 8, I'd think we'd be in good shape with this NPRM.

I do think that ALPA will respond approriately to that provision in there. They will probably have guidance as well for the members to respond.

This is the ALPA blast mail summary:

a. The proposed rules will eliminate distinctions between domestic, flag, and supplemental operations.

b. Rules contained within this NPRM will apply to all flights conducted by 121 certificate holders, including ferry flights, repositioning flights, delivery flights, etc.

c. Public comments are due to the FAA 60 days from today.

d. A final rule must be enacted by August 1, 2011.

e. The proposed minimum rest period prior to duty is 9 hours at the hotel.

f. The proposed maximum duty day ranges from 9 to 13 hours, depending on the pilot’s start time and the number of flight segments.

g. The proposed maximum flight time ranges from 8 to 10 hours, depending on the pilot’s start time and the number of flight segments.

h. Fatigue mitigation is identified as a joint responsibility between the air carrier and the pilot.

i. Carrier must develop and implement an internal evaluation and audit program to monitor whether flightcrew members are reporting to work fatigued.

j. Pilots must receive 30 consecutive hours free from duty in each 7 day period.

k. Carriers must implement a Fatigue Risk Management System

l. Carriers must implement a fatigue education and training program for flight crewmembers.

Actually it is. Reading a little deeper, there's two sections that clarify:

This is one of the parts that concerns me the most.
Without contractual protections, I see the potential for arbitrary fatigue assessment at report time and the increased use of airport ready reserves to replace a pilot who is so deemed to be "unfit for duty".

Hi!

mmaviator: "I know this affects everyone and I haven't read through the document but are these new rules better or still worse than ICAO rules?"

ICAO does not have any rules. The CAA (local FAAs) that all operate under ICAO all have their own rules. For example, the European rules are 190 duty hours max in 30 days, while the Kenya CAA rules are 160 duty hours in 30 days. The Kenya CAA rules for duty/rest were quite different than the British CAA rules, but they were both a TON better than FAA rules overall (in Kenya, I had 11 hours min rest, NOT reducable for any reason.).

cliff

Hi!

shfo: "Nice of them to think of the reserves. Basically no change. You can have a 16 hour duty day. Good thing my contract protects me more than the FAA."

I have not seen the reserve rules, but 9 hours rest is required AT the hotel/rest facility. So, you couldn't do two 16 hour reserve days in a row...
And, the -121 airline I was at had 24/7 reserve indefinitely, until you were called on a trip (or went on days off). My record was approximately 240 hours of continuous reserve, and then called for a trip (25" callout time). This was allowed because -121 was divided into domestic, intntl and supplemental...no more!

cliff

Here is a link to the new regs. Looks pretty good!

FAA Proposes New flight- and Duty-time Rules : AINonline

I'll tell you guys what isn't good. They are going to allow 2 pilots on Europe flights that now require 3 pilots. They are going to allow 3 crew members on flights that now require 4 pilots. A lot of major airlines do trips to the Caribbean where one crew deadheads down to fly back and vice versa (4 pilots required). Some airlines just send an IRO down (3 pilots required). The new rules will let 2 pilots fly it. Same with transcontinental turns. It will be allowed. This will eliminate more high paying jobs thereby affecting the regionals. Just something to think about.