Please comment on fatigue NPRM

[carl p]

Done, 10 hrs too much. Duty max 12, 8 hrs flight!

 

[Rekks Inbound]

Done!

Peace.

Rekks

 

[densoo]

Thanks to all who commented!

Last one squeaked in at 1159pm on the 15th. There was a flurry of comments the last day or two, over 200. Ended with 717 comments. Don't know how this compares with other NPRMs, but most of them are from line pilots who said two things:

1) how can you get more rest with longer flight time allowances? and

2) there was not enough change to the current overnight rest rule to make a difference--it has to be longer.

http://www.regulations.gov/search/R...=All&Ntx=mode+matchall&Ntt=FAA-2009-1093-0001

 

[densoo]

Wall Street Journal. More delays.

A bid to exempt some flights from proposed pilot-fatigue regulations threatens to complicate long-delayed congressional action on tougher Federal Aviation Administration rules.

With the FAA poised to impose more-stringent rules later this year limiting flight time and workday lengths for all airline pilots, the Senate is about to consider an amendment exempting certain cargo and passenger operations from those tougher limits. It is one of the most contentious issues roiling the aviation industry, pitting different airlines and pilot groups against each other.

Oklahoma Republican Senator James Inhofe is expected to introduce an amendment Wednesday barring the FAA, as part of its current comprehensive rule-making effort, from imposing new restrictions on pilots flying for nonscheduled carriers. The exemption would cover charter flights carrying commercial cargo, as well as flights contracted by the Pentagon to transport troops or materials.

By retaining the current regulatory treatment of such flights, the amendment would allow some pilots flying cargo and passengers on charter trips to remain on duty for several hours longer than other airline crews. Pilots for nonscheduled carriers also could be required to stay behind the controls for longer stretches and report to work after shorter rest periods than those employed by the rest of the industry.
Under Sen. Inhofe's amendment, however, the FAA would have to initiate a separate, lengthy process to mandate changes to pilot rules affecting nonscheduled carriers.

The amendment is intended to benefit carriers such as Evergreen International Airlines Inc., the World Airways Inc. unit of Global Aviation Holdings Inc. and Atlas Air Worldwide Holdings Inc.

The National Air Carrier Association, which represents nonscheduled airlines, previously submitted comments to the FAA arguing that such carriers have "distinctly different operations" than scheduled airlines and a "one size fits all" regulatory approach isn't appropriate. The association told the FAA that complying with the proposed rule would require a roughly 40% increase in the number of pilots working for nonscheduled carriers.

Nonscheduled carriers carry nearly 95% of U.S. military passengers around the world.

In remarks prepared for delivery on the Senate floor on Wednesday, Sen. Inhofe said his amendment "would ensure that a segment of our economy" heavily relied on by the Pentagon "is treated fairly" by the FAA. According to Sen. Inhofe, the FAA should "recognize the peculiar operating environment" in which non-scheduled carriers operate and provide them additional flexibility in scheduling crews.

The Air Line Pilots Association, the largest U.S. pilots union, delivered a letter to all Senators Tuesday strongly opposing Sen. Inhofe's amendment. The union has maintained that the proposed comprehensive rules, covering the entire industry, are based on the latest scientific evidence about the dangers of fatigue in the cockpit.

"Pilot fatigue is universal and the factors that lead to fatigue in most individuals are common," Lee Moak, ALPA's president, said in the letter. "There is no rational or scientific basis to support different 'fatigue rules' depending on the type of operation," according to the letter, which added: "ALPA is adamantly opposed to any 'carve out' " for nonscheduled carriers.

The National Air Carrier Association also has said that the proposed rules, if they become final, would have a "disastrous" economic impact on its members. Oakley Brooks, the president of the association, on Wednesday said consideration of the issue "is in its early days" and it is premature to predict how much support it will generate on Capitol Hill.

Senate Democratic leaders have indicated they hope to get bipartisan support for a "clean" FAA bill, free of controversial amendments. The legislation authorizes about $8 billion for airport construction and also includes money to continue funding the government's share of modernizing the nation's air-traffic-control system. The House is expected to take up its version of the FAA reauthorization bill later this month.

The FAA's anticipated new fatigue rules, which Congress ordered to be finalized by the beginning of August, seek to replace a decades-old system with new, flexible rules spelling out daily and weekly pilot-scheduling limits based on various operational and physiological factors. The limits vary depending on the time of day, length of flights and number of takeoffs performed by crews between rest periods. The proposal also covers commuter and ultra-long-haul operations.

While the rest of the industry also has criticized the FAA's proposal as overly restrictive and expensive, those airlines and associations generally haven't asked for an explicit exemption. Rather, they have urged the agency to amend its proposal to resolve their concerns.

Write to Andy Pasztor at [email protected]

 

[densoo]

In looking through the NPRM comments, virtually all the heavy-hitters in the cargo community asked for an extension to the comment period. Some wrote that this new rule would completely undermine their business model. When you limit back side of clock flying you'd have to increase pilot group size by nearly half.

The rules do not allow flying into a hub, sitting four hours during the sort, and then flying out of the hub, all on back side of clock. The duty day limits are too stringent for this. You'd have to have one group of pilots fly into the hub and another set of pilots fly out of the hub.

Talk about a hiring spree.

 

[pilotyip]

Nothing to do with rest

The rules do not allow flying into a hub, sitting four hours during the sort, and then flying out of the hub, all on back side of clock. The duty day limits are too stringent for this. You'd have to have one group of pilots fly into the hub and another set of pilots fly out of the hub. Talk about a hiring spree.

Talk about more days away from home for the same amount of flying. There was no thought in this NPRM about backside of the clock flying, it was a hub and spoke thought process. 10 hours behind door has nothing to do with rest or fatique. Yes if it is in your normal sleep pattern it is great. But how about I call you at 0900 right after you get out of bed, I tell you to go into 12 hours of because I need you for 9 hour flight starting at 2100 KYIP-MMTO-KELP. Will you be rested for that flight, most likely not, so what did 12 hours have to do with rest?

 

[CheapFlyer]

You'd have to have one group of pilots fly into the hub and another set of pilots fly out of the hub.

Talk about a hiring spree.

Sounds good to me!

 

[jetwash]

US Senate passes 2-year, $35-billion aviation bill encouraging competition
February 19, 2011, 5:52pm
WASHINGTON (Dow Jones) – The US Senate approved a two-year, $35-billion aviation bill that avoids contentious labor-management issues while encouraging greater airline competition between the West Coast and the nation's capital.

The bill was approved by an 87-8 vote.

Seeking to end a long-standing legislative stalemate, the legislation calls for loosening restrictions on flights between western states and northern Virginia's Reagan National Airport. But in a disappointment to industry, the bill excludes significant federal investments to help airlines install onboard equipment necessary to use next-generation systems of satellite-based navigation and air-traffic control.

Still, Senate leaders hailed the compromise as a milestone because, since 2007, various disputes have blocked passage of a comprehensive bill reauthorizing Federal Aviation Administration programs.
House Republican leaders have called swift passage of an FAA bill one of their priorities, and their current version doesn't appear to include any provisions likely to hold up final passage. Both lawmakers and White House officials are portraying the legislation as a jobs-creation measure, though the House version, covering a longer period, calls for cutting and maintaining FAA spending back to 2008 levels, despite the ongoing traffic-control modernization efforts.

Going into Thursday's debate, the legislation already had been stripped of provisions dealing with various union-representation issues and FAA supervision of foreign aircraft-maintenance facilities. But close to the last minute, Sen. James Inhofe (R, Okla.) agreed to drop his controversial amendment proposing to exempt some all-cargo charter airlines from complying with the agency's impending pilot-fatigue rules.


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http://www.avweb.com/avwebflash/new...rtage_american_FAA_ntsb_fatigue_204144-1.html



February 18, 2011

Rest Rules Could Create Pilot Shortage?
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By Glenn Pew, Contributing Editor, Video Editor




American Airlines says proposed rules intended to reduce pilot fatigue would require it to hire an additional 2,325 pilots at a cost of $514 million annually, and seemed to suggest the industry-wide effect could be crippling. The rules would effectively decrease maximum time on duty for pilots. In November, American offered public comments on the rules, saying "if AA needs 2,300 more pilots to meet the proposed rules, other certificate holders will need many additional pilots, too." Stakeholders also claim that the regulation's cost will be substantially higher than the FAA's estimate of $1.25 billion over 10 years. The Air Transport Association says the rule would cost more than 15 times that figure. As for the total number of pilots needed to meet the requirements of the bill, American said, "The industry figure will be so large as to raise the question of from where they all will come." American wasn't the only carrier to express concern.

Southwest commented on the proposal, saying "we feel than many of the rule changes will impact our operation as dramatically, if not more so, than the impact on any other carrier." The proposed rules call for nine hours rest between shifts and 30 consecutive hours away from work, each week. The proposal arose with support of people who lost family members in the crash of Continental Connection Flight 3407. There were no survivors of that flight, so the exact role of fatigue is unknown. However, the investigation found that neither member of the cockpit crew had slept in a bed the night before the crash, both had long commutes, and fatigue may have affected crew performance. In February 2010, NTSB Chairman Deborah Hersman called the crash "an opportunity to reexamine fatigue in aviation."

Fatigue in aviation has been on the NTSB's Most Wanted List of Transportation Safety Improvements since 1990. The FAA accepted comments on the proposed rules (PDF) through Nov. 15, 2010.

 

[densoo]

Talk about more days away from home for the same amount of flying.

Talk about soft time pay. Contract pay methods will have to be completely revamped.

 

[mamba20]

Didn't I post 6 months ago that you were wasting your time on this? IT DOSEN'T MATTER WHAT WE THINK OR WHAT WE WRITE TO OUR CROOKED PUBLIC OFFICIALS!! Those of you who still have faith in our system of government be it democrap or repuklican make me sick! Its all about money for our scum bag government.

 

[jetwash]

Another A$$hole who cares more about the bottom line then safety of flight.



http://www.investorplace.com/32701/can-airlines-be-too-safe/


Can Airlines Be Too Safe?

Accident rates plunge, but regulators keep pushing safety
Mar. 4, 2011, 11:26 am EST | By Susan J. Aluise, Aviation, Auto & Transportation Writer
The good news for the commercial airline sector: 2010 was the safest year in history for Western-built jet aircraft. The bad news: federal regulators believe the industry can further reduce accident risks if new rules to reduce pilot fatigue take effect as planned later this year.

Just don’t expect much cheering from the airline industry — trimming pilots’ work schedules could radically increase operating costs.

Last week, the International Air Transport Association said the 2010 accident rate of Western-built jet aircraft (measured in hull losses per million flights) was 0.61 — one accident for every 1.6 million flights. Not only were those numbers the lowest in aviation history, but the rate in North America was even lower — just 0.10.

But those statistics aren’t likely to cause the Federal Aviation Administration to rethink plans to boost safety further. The agency’s new rules governing pilot work time, which Congress told the agency to finalize by Aug. 1, aim to ensure that pilot fatigue doesn’t impair performance. To curb daily and cumulative fatigue, the regulations would reduce pilots’ flight and other duty time to a maximum of 13 hours, compared to the current 16 hours.

The issue of pilot fatigue moved to the forefront in the aftermath of the February 2009 crash of Continental Connection Flight 3407 (a code-share flight operated by Colgan Air) near Buffalo, N.Y. Investigators concluded that pilot fatigue contributed to that crash, which killed all 49 passengers and crew onboard and one person on the ground.

Obviously, safety is a critical issue for all stakeholders – airlines, aircraft manufacturers, lawmakers and the traveling public. But safety enhancements come at a price – and for an industry that already is struggling with shrinking margins due to more expensive fuel, costly new requirements are not exactly welcome.

How big of a hit could airlines take on the bottom line? It depends on whom you ask. The FAA says its rules would cost U.S. airlines $1.25 billion over the next decade. But the Air Transport Assocation, the trade group that represents U.S. airlines, says the agency has seriously low-balled its cost estimates – by a factor of 15.

“We are very concerned that the proposed rule reflects a lack of understanding by FAA of how airlines operate,” ATA President and CEO James C. May said when the rules were first proposed last November. “Our concerns are validated by the fact that FAA’s economic analysis is off the mark by at least a factor of 15 in its impact assessment, making it imperative that this proposal be significantly revised.”

Predictably, there have been howls of protest from airlines. AMR Corp.’s (NYSE:AMR) American Airlines said the new rules would force it to hire more than 2,300 additional pilots, boosting its operating costs by more than $500 million a year. Southwest Airlines (NYSE:LUV) believes reducing its pilots’ productivity would hamper its ability to compete. If those numbers are anywhere near right and the FAA makes no changes to the proposal, the earnings of all U.S. carriers – including United Continental (NYSE: UAL), Delta (NYSE: DAL) and U.S. Airways (NYSE: LLC) – could take yet another big hit.

As of this writing, Susan J. Aluise did not hold a position in any of the stocks named here.



How the hell is reducing accident risks "bad news"??

 

[HalinTexas]

Here's a not-so-good outcome to this NPRM.

Bankruptcy.

FAA says $1.5B, the ATA says $15B. Either way, it increases costs. The truth probably lies somewhere in between. So, lets just say $5B. It's conservative and it makes for easier math.

So, where are those costs going to be made up? Most, if not all, of you will just say "increase the ticket prices." OK, what if the public balks and refuses to pay the increase? Then what? I don't know where I can get a nice pretty graph of industry wide ticket prices over the last 4 years, but you can see with liquidations, and furloughs, and oil prices, it hasn't been pretty.

My bet is that companies will come to the unions, under threat of BK, to renegotiate contracts. Those with duty and trip rigs will probably get hit the hardest. Time away from base will most likely greatly increase, with no increases in per diem, equals long layovers in some place you don't care to be, and difficulty readjusting to circadian rhythms once home. W2's and QOL issues will not be much better, if at all, if this passes as written. A blanket approach doesn't solve anything.

One additional consequence not covered under regs. or CBAs is the effort by airlines to discourage commuting. Such as, early shows on day one followed by late returns on the last day. Lines with 10 days off per month and 40 hours of flying. This is entirely likely if the NPRM is passed as is. The elimination of CASS. After all, it was the commute and the lack of rest therein that contributed to the fatigue. It's a cheaper option than COL adjustments in large metro areas like EWR.

I'm just sayin'. Be ready.

Changes need to be made, such as no scheduled reduced rest, duty times reflective of flight time and number of legs flown, back side of the clock and multi-time zone operations over a trip.

 

[pilotyip]

Here's a not-so-good outcome to this NPRM.

Bankruptcy.

FAA says $1.5B, the ATA says $15B. Either way, it increases costs. The truth probably lies somewhere in between. So, lets just say $5B. It's conservative and it makes for easier math...................I'm just sayin'. Be ready.

Changes need to be made, such as no scheduled reduced rest, duty times reflective of flight time and number of legs flown, back side of the clock and multi-time zone operations over a trip.

The ole unintended consequences