FAA Rest Rules: Impact on COMMUTING (doc pgs 89-92, 25)

[Flopgut]

There is no commute out there that is more willfully contrary to preventing fatigue than what CAL does thier reserves. They do it daily and they've done it for decades... Did it for 8 years. And that includes a red-eye into a full work day. (which is something I would never do)

 

[Joblu]

Funny how these fools label a commuter 'responsible' or 'irresponsible based on what time of day they commute to work. Like they never get bumped off flights. Ridiculous!

 

[av8tor19]

Hopefully they won't require the commute to be the start of the duty day and force the carrier to monitor it.

I saw a draft copy of an advisory circular that talked about his and that basically prevented commuting on Fedex and UPS to a normal airline job. Has any one else seen it?

If its an Advisory Circular, can it become a rule?

 

[crxpilot]

I saw a draft copy of an advisory circular that talked about his and that basically prevented commuting on Fedex and UPS to a normal airline job. Has any one else seen it?

If its an Advisory Circular, can it become a rule?

How would they know you are commuting to work or home?

 

[Beetle007]

Computer Assisted Passenger Prescreening System

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The Computer Assisted Passenger Prescreening System (often abbreviated CAPPS) is a counter-terrorism system in place in the United States air travel industry. The United States Transportation Security Administration (TSA) maintains a watchlist, pursuant to 49 USC § 114 (h)(2)[1], of "individuals known to pose, or suspected of posing, a risk of air piracy or terrorism or a threat to airline or passenger safety." The list is used to pre-emptively identify terrorists attempting to buy plane tickets or board planes traveling in the United States, and to mitigate perceived threats.


CAPPS systems rely on what is known as a Passenger Name Record, often abbreviated PNR. When a person books a plane ticket, certain identifying information is collected by the airline: full name, address, etc. This information is used to check against some data store (e.g., a TSA No-Fly list, the FBI ten most wanted fugitive list, etc.) and assign a terrorism "risk score" to that person. High risk scores require the airline to subject the person to extended baggage and/or personal screening, and to contact law enforcement if necessary.

 

[Beetle007]

And under the Patriot Act they will tap your phones, your wife's phone, and inevitablly the phones of all your friends, relatives and associates.

They will catch you...you can run but you can't hide. You are a threat to national security and irresponsible commuters will be held indefindently in a prison at an unknown location. Waterboarding will be common.

 

[XJTAv8r]

Submit your comments to the FAA

For those of you who want to give the FAA your opinion/comments on this rest rule NPRM:

http://www.regulations.gov/search/Regs/home.html#submitComment?R=0900006480b4ea5b

 

[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.

 

[JFReservist]

Colgan Crash

How many thousands of pilots commute responsibly every day? Their lives may change and irrevocable damage to their QOL due to the crappy decisions of two of our unfortunate colleagues.

This is a training issue that should be addressed... I have choice words, but I'll leave it at that lest I become politically incorrect... More unintended consequences to an already horrific accident.