Please comment on fatigue NPRM

[TheCheat]

Got one in... it was hasty, but at least will help the numbers I hope.

 

[Sandhawk]

.....

 

[sleeves]

Done!!

 

[jtf]

It is very easy to submit and you don't have to identify yourself. Please tell them what you think- what is good, what is bad, how it can be improved. They very well may not listen, but at least there is a chance they do. While I'm preaching- please vote in the coming elections. I'm doing the early voting thing today since I'm working on the normal day.

 

[densoo]

Two Weeks Left, ALPA comments

Progress of the Flight Time and Duty Time NPRM

November 2, 2010

Since the Notice of Proposed Rule Making (NPRM) was made public, your ALPA team of experts has been conducting a broad analysis of the details of the proposed rule and how it compares with the recommendations made by ALPA’s participants on the Flight Time/Duty Time Aviation Rulemaking Committee (ARC). In addition to this analysis, members of the ALPA team also briefed and received direction from your representatives during the recent Board of Directors meeting. Specifically, the direction received was to ensure that our comments were made in accordance with current ALPA Flight Time and Duty Time (FTDT) policy. This policy was revised and unanimously adopted during last fall’s Executive Board meeting.

ALPA continues to support the FAA’s efforts to modernize flight and duty time regulations. The overall framework creates a scientifically based, multi-faceted approach to minimizing and mitigating pilot fatigue. As with any effort of this magnitude, and with the broad range of ARC participants, there are details we support and a few details which we believe merit a review by the FAA to ensure that the proposed rules are supported by known science and our operational experience.

The good news is that the rule:

· applies scientific principles and recognizes human physiological limitations with increased minimum rest periods and more reasonable duty days, and recognizes the effects of circadian rhythms on fatigue,

· applies to all FAR Part 121 flying, eliminating “carve outs” for supplemental operations,

· incorporates FAR Part 91 “tag on” or ferry flights within FT/DT limits,

· requires recurrent fatigue education and training at all airlines and calls for airlines to implement a fatigue risk management system,

· requires airlines to accurately record and set scheduled flight and duty periods based on actual operations, with adjustments mandated if unreliable scheduling is used,

· makes the decision to extend the duty period a joint responsibility of the pilot-in-command and the airline, and limits the number of times the duty period may be extended,

· requires deadheading to be counted as duty time, and

· specifically recognizes short call reserve as duty.

Components requiring work:

· Ensuring that the length and quality of rest after a long-range flight across multiple time zones is sufficient before the next flight/duty period. The science behind a proper rest involves two components. The first is an opportunity for eight hours of sleep (for the average person—there is a degree of individual variability). The second is that the sleep opportunity needs to occur at the proper time of day. Only requiring a nine-hour opportunity at the hotel following a flight that crosses multiple time zones does not ensure that the sleep opportunity occurs at the proper time of day based on the crewmembers’ body clocks. In addition to ensuring that the length and quality of rest are adequate, it is also important to ensure that the flight duty period (FDP) table is used correctly considering where the pilot’s body clock is acclimated. We do not believe 36 hours free of duty at a foreign layover creates an acclimated pilot for the purposes of using the proposed FDP table.

· We are concerned about the limitation on consecutive night duties and believe that with appropriate safeguards the science and operational experience supports a fourth consecutive night duty.

· Ensuring that the concept of fitness for duty remains a joint responsibility that does not create a burdensome tracking and reporting system on commuting with an unintended consequence of adversely affecting pilot fatigue. While it is important for all stakeholders to be involved in the fitness-for-duty equation, we simply cannot operate in an environment that places a priority on the tracking and reporting of commuting over educating and encouraging responsible, jointly managed commuting policies.

· Ensuring that the application of augmented flight- and duty-period tables addresses the circadian disruption that the flightcrew member may experience in certain types of flying. The science behind the methodology used is applicable, but there is still concern as to how quickly a pilot could be considered acclimated to their destination, which could drive a level of augmentation that is not appropriate for the planned flight. Additionally, we are concerned with multiple-leg augmentation as the science behind the chart was based on a single-sector flight.

· The viability of increasing block time in a duty period up to 10 hours. Even though the flight time limit proposed by the FAA is a hard time, not scheduled, we still believe that 10 hours for an unaugmented crew is excessive.

Moving forward

The next steps in the process are completing and submitting ALPA’s comments to the FAA’s rulemaking docket, which are due by November 15, 2010. As mentioned above, our comments will be driven by current ALPA policy and backed up by known science and our operational experience.

A copy of ALPA’s comments will be made available to the membership immediately after being submitted to the federal docket.

Comments or questions? Write to [email protected].

 

[densoo]

You can still comment!

To submit your comment, go here:
http://www.regulations.gov/search/Re...00006480b4ea5b


To see the comments others have already made, go here:
http://www.regulations.gov/search/Re...2009-1093-0001

 

[XJTAv8r]

Easy way to message FAA & Congress on NPRM

Capt. Sully's video on the rest rule NPRM:
http://www.vimeo.com/16668928

Easy link to write to Congress and the FAA about this NPRM:
(took only about a minute to do!)
http://capwiz.com/capapilots/issues/alert/?alertid=19337501

 

[densoo]

Capt. Sully's video on the rest rule NPRM:
http://www.vimeo.com/16668928

Thanks, Sully! Now please do one on the security theater we go through.

 

[Flyer1015]

hahahHAHAHA Southwest guy, initials DP posted this:

"Ultimately, the responsibility needs to rest with the individual pilot where it belongs. Stop limiting my productivity in the name of safer rest rules to level the playing field with less productive carriers."

 

[densoo]

Last Chance! Closes Tomorrow.

To submit your comment, go here:
http://www.regulations.gov/search/Re...00006480b4ea5b

Over 400 comments so far.

To see the comments others have already made, go here:
http://www.regulations.gov/search/Re...2009-1093-0001