Voice Of Reason
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- Sep 21, 2004
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http://www.faa.gov/regulations_policies/rulemaking/recently_published/media/FAA_2010_22626.pdf
p89-92:
"M. Commuting
The impact of commuting to a duty station has been linked to increased fatigue,
most recently in the crash in Buffalo, New York. Commuting is common in the airline
industry, in part because of lifestyle choices available to pilots by virtue of their being
able to fly at no cost to their duty station, but also because of economic reasons
associated with protecting seniority on particular aircraft, frequent changes in the
flightcrew member’s home base, and low pay and regular furloughs by some carriers that
may require a pilot to live someplace with a relatively low cost of living. While
commuting to a duty station can be handled responsibly (particularly assuming one has
the means), it is also subject to abuse.
The only current impediment to irresponsible commuting in the FAA’s
regulations is the general requirement in part 91 that pilots report to work fit for duty.
CAP-371 provides that if journey time from home to normal home base is more than 1.5
hours, crew members should consider making arrangements for temporary
accommodation nearer to base. This provision is not mandatory.
The ARC unanimously recommended that pilots be reminded of their existing
obligations under part 91 to report to work fit for duty, but that the FAA impose no new
requirements. The FAA has tentatively rejected this approach.
Commuting is fundamentally a fitness for duty issue. If a flightcrew member
commutes irresponsibly, it is possible that he or she may become fatigued. A responsible
commuter plans his or her commute to minimize its impact on his or her ability to get
meaningful rest shortly before flying, thus fulfilling the proposed requirement that he or
she reports for an FDP rested and prepared to perform his or her assigned duty.
The FAA considered proposing a requirement similar to the one in CAP-371
mandating that pilots arrive at the pilot’s domicile airport in time to receive the pre-flight
rest period in that area prior to commencing flight. At first blush, this approach has
appeal, in that it would require a flightcrew member to have an opportunity for rest
immediately prior to commencing an FDP. However, because commuting constitutes an
activity conducted by a pilot on his or her own time, it is difficult to regulate. In addition, a strict commuting regulation, such as one that requires a pilot to report to a duty station
area well in advance of the scheduled flight, would not necessarily result in more
responsible commuting. A pilot could choose to commute during times that interfere
with his or her WOCL (for example, taking a red eye for an afternoon flight), leaving him
or her less rested for flight. This approach could also discourage responsible commuting.
For example, today a flightcrew member can catch a mid-morning flight to his or her
duty station and then commence his or her flying shortly after arrival a couple of hours
later. The flightcrew member would have received a full night of sleep, and would be in
a much better position to work than the individual who had taken an overnight or very
early morning flight. While the irresponsible commuter would be available to fly by
mid-afternoon, the mid-morning commuter would not be available to fly until late
evening, just as he or she is beginning to tire.
The FAA does believe that it is unreasonable to assume that an individual is
resting while commuting. Accordingly, time spent commuting, either locally or longdistance,
is not considered rest, and a certificate holder will need to consider the
commuting times required by individual flightcrew members to ensure they can reach
their home base while still receiving the required opportunity for rest. This approach is
consistent with that taken for transportation to and from a sleep facility other than home
discussed earlier in this document.
The FAA also believes it is inappropriate to simply rely on the existing
requirements in part 91 to report to work fit for duty. The FAA believes a primary reason
that pilots may engage in irresponsible commuting practices is a lack of education on
what activities are fatiguing and how to mitigate developing fatigue. The FAA has developed a draft fitness for duty AC that elaborates on the pilot’s responsibility to be
physically fit for flight prior to accepting any flight assignment, which includes the pilot
being properly rested. Additionally, the AC outlines the certificate holder’s
responsibility to ensure each flightcrew member is properly rested before assigning that
flightcrew member to any flight. That document has been placed in the docket for this
rulemaking. Additionally, the proposed training program discussed earlier contains an
element on the impact of commuting on fatigue. "
----------------------------------------------------------
(Last statement refers to additional text on p 25)
Any interpretations of what may develop from all this?
p89-92:
"M. Commuting
The impact of commuting to a duty station has been linked to increased fatigue,
most recently in the crash in Buffalo, New York. Commuting is common in the airline
industry, in part because of lifestyle choices available to pilots by virtue of their being
able to fly at no cost to their duty station, but also because of economic reasons
associated with protecting seniority on particular aircraft, frequent changes in the
flightcrew member’s home base, and low pay and regular furloughs by some carriers that
may require a pilot to live someplace with a relatively low cost of living. While
commuting to a duty station can be handled responsibly (particularly assuming one has
the means), it is also subject to abuse.
The only current impediment to irresponsible commuting in the FAA’s
regulations is the general requirement in part 91 that pilots report to work fit for duty.
CAP-371 provides that if journey time from home to normal home base is more than 1.5
hours, crew members should consider making arrangements for temporary
accommodation nearer to base. This provision is not mandatory.
The ARC unanimously recommended that pilots be reminded of their existing
obligations under part 91 to report to work fit for duty, but that the FAA impose no new
requirements. The FAA has tentatively rejected this approach.
Commuting is fundamentally a fitness for duty issue. If a flightcrew member
commutes irresponsibly, it is possible that he or she may become fatigued. A responsible
commuter plans his or her commute to minimize its impact on his or her ability to get
meaningful rest shortly before flying, thus fulfilling the proposed requirement that he or
she reports for an FDP rested and prepared to perform his or her assigned duty.
The FAA considered proposing a requirement similar to the one in CAP-371
mandating that pilots arrive at the pilot’s domicile airport in time to receive the pre-flight
rest period in that area prior to commencing flight. At first blush, this approach has
appeal, in that it would require a flightcrew member to have an opportunity for rest
immediately prior to commencing an FDP. However, because commuting constitutes an
activity conducted by a pilot on his or her own time, it is difficult to regulate. In addition, a strict commuting regulation, such as one that requires a pilot to report to a duty station
area well in advance of the scheduled flight, would not necessarily result in more
responsible commuting. A pilot could choose to commute during times that interfere
with his or her WOCL (for example, taking a red eye for an afternoon flight), leaving him
or her less rested for flight. This approach could also discourage responsible commuting.
For example, today a flightcrew member can catch a mid-morning flight to his or her
duty station and then commence his or her flying shortly after arrival a couple of hours
later. The flightcrew member would have received a full night of sleep, and would be in
a much better position to work than the individual who had taken an overnight or very
early morning flight. While the irresponsible commuter would be available to fly by
mid-afternoon, the mid-morning commuter would not be available to fly until late
evening, just as he or she is beginning to tire.
The FAA does believe that it is unreasonable to assume that an individual is
resting while commuting. Accordingly, time spent commuting, either locally or longdistance,
is not considered rest, and a certificate holder will need to consider the
commuting times required by individual flightcrew members to ensure they can reach
their home base while still receiving the required opportunity for rest. This approach is
consistent with that taken for transportation to and from a sleep facility other than home
discussed earlier in this document.
The FAA also believes it is inappropriate to simply rely on the existing
requirements in part 91 to report to work fit for duty. The FAA believes a primary reason
that pilots may engage in irresponsible commuting practices is a lack of education on
what activities are fatiguing and how to mitigate developing fatigue. The FAA has developed a draft fitness for duty AC that elaborates on the pilot’s responsibility to be
physically fit for flight prior to accepting any flight assignment, which includes the pilot
being properly rested. Additionally, the AC outlines the certificate holder’s
responsibility to ensure each flightcrew member is properly rested before assigning that
flightcrew member to any flight. That document has been placed in the docket for this
rulemaking. Additionally, the proposed training program discussed earlier contains an
element on the impact of commuting on fatigue. "
----------------------------------------------------------
(Last statement refers to additional text on p 25)
Any interpretations of what may develop from all this?
Last edited:
