Sully & CAPA respond to Flight Time/Duty Time
09-16-2010, 01:24 PM
#1
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Joined APC: Apr 2009
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Sully & CAPA respond to Flight Time/Duty Time
FOR IMMEDIATE RELEASE
Contact: Captain Paul Onorato (202) 624-3540
CAPA URGES FAA TO CHANGE NPRM ON FLIGHT AND DUTY TIME
Washington, D.C. (September 16th, 2010)—The Coalition of Airline Pilots Associations (CAPA) which represents over 28,000 commercial passenger and cargo pilots is concerned that portions of the Noticed of Proposed Rulemaking (NPRM) on Flight and Duty Time published on September 14th, 2010 may have a negative impact on flight safety.
While CAPA applauds the Federal Aviation Administration (FAA) for looking at a broad range of causal factors with regard to fatigue mitigation, CAPA’s Safety professionals have exhaustively analyzed the NPRM and feel the solutions proposed by the FAA often address industry economic issues to the exclusion of safety concerns.
Although the proposal places limits on how long pilots can be on duty based on time of day, it falls short of the mark to protect pilots against fatigue in many areas.
1) The rule proposes a 25% increase in the amount of flying a pilot can be expected to accomplish in a day.
2) For augmented (3 person) crews there is no specified limit on hours flown in a duty day. Using only total duty as a limit, three pilots could fly as much as 15 hours, a 25% increase over today’s limit of 12 hours.
3) The rule calls for a 9 hour rest period which still does not allow enough rest time for a pilot to get 8 hours of sleep. This minimum rest would apply following extended international flights as well, a major reduction compared to today.
4) Even this 9 hour rest period can be shortened once a week to 8 hours, further inducing fatigue.
Pilot fatigue is an ever present threat to the safety of traveling public and has been identified on the National Transportation Safety Board’s “Most Wanted” list of regulatory changes for two decades. Logical regulatory reforms must take precedence with government regulators over the economic interests of the airline industry. Captain Paul Onorato, president of CAPA says, “You cannot make a pilot less fatigued by requiring them to fly more hours”.
The proposed rule has caught the attention of industry safety experts. In a recent letter to Administrator Babbitt, Captain Chesley “Sully” Sullenberger states, “The stated purpose of the rulemaking process was to enhance the safety of the traveling public by reducing pilot fatigue.This NPRM does neither”.
Letter from Captain Chesley "Sully" Sullenberger to the FAA & CAPA Press Release (Click here to download)
The Coalition of Airline Pilots Associations is a trade association which represents over 28,000 professional pilots at carriers including American Airlines, Southwest Airlines, UPS, US Airways, Southern Air, ABX Air, Atlas Air Cargo, Kalitta Air, Polar Air Cargo, Arrow Air, Horizon Air, Gulfstream Air, Cape Air, Miami Air, Omni Air and USA 3000.
While CAPA applauds the Federal Aviation Administration (FAA) for looking at a broad range of causal factors with regard to fatigue mitigation, CAPA’s Safety professionals have exhaustively analyzed the NPRM and feel the solutions proposed by the FAA often address industry economic issues to the exclusion of safety concerns.
Although the proposal places limits on how long pilots can be on duty based on time of day, it falls short of the mark to protect pilots against fatigue in many areas.
1) The rule proposes a 25% increase in the amount of flying a pilot can be expected to accomplish in a day.
2) For augmented (3 person) crews there is no specified limit on hours flown in a duty day. Using only total duty as a limit, three pilots could fly as much as 15 hours, a 25% increase over today’s limit of 12 hours.
3) The rule calls for a 9 hour rest period which still does not allow enough rest time for a pilot to get 8 hours of sleep. This minimum rest would apply following extended international flights as well, a major reduction compared to today.
4) Even this 9 hour rest period can be shortened once a week to 8 hours, further inducing fatigue.
Pilot fatigue is an ever present threat to the safety of traveling public and has been identified on the National Transportation Safety Board’s “Most Wanted” list of regulatory changes for two decades. Logical regulatory reforms must take precedence with government regulators over the economic interests of the airline industry. Captain Paul Onorato, president of CAPA says, “You cannot make a pilot less fatigued by requiring them to fly more hours”.
The proposed rule has caught the attention of industry safety experts. In a recent letter to Administrator Babbitt, Captain Chesley “Sully” Sullenberger states, “The stated purpose of the rulemaking process was to enhance the safety of the traveling public by reducing pilot fatigue.This NPRM does neither”.
Letter from Captain Chesley "Sully" Sullenberger to the FAA & CAPA Press Release (Click here to download)
The Coalition of Airline Pilots Associations is a trade association which represents over 28,000 professional pilots at carriers including American Airlines, Southwest Airlines, UPS, US Airways, Southern Air, ABX Air, Atlas Air Cargo, Kalitta Air, Polar Air Cargo, Arrow Air, Horizon Air, Gulfstream Air, Cape Air, Miami Air, Omni Air and USA 3000.
For more information, please visit: www.capapilots.org
FORWARD TO A FRIEND - ADD YOUR NAME TO CAPA'S ACTION E LIST
FORWARD TO A FRIEND - ADD YOUR NAME TO CAPA'S ACTION E LIST
09-16-2010, 02:43 PM
#3
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Joined APC: Nov 2009
Position: C560XL/XLS/XLS+
Posts: 1,278
FOR IMMEDIATE RELEASE
Contact: Captain Paul Onorato (202) 624-3540
CAPA URGES FAA TO CHANGE NPRM ON FLIGHT AND DUTY TIME
Washington, D.C. (September 16th, 2010)—The Coalition of Airline Pilots Associations (CAPA) which represents over 28,000 commercial passenger and cargo pilots is concerned that portions of the Noticed of Proposed Rulemaking (NPRM) on Flight and Duty Time published on September 14th, 2010 may have a negative impact on flight safety.
While CAPA applauds the Federal Aviation Administration (FAA) for looking at a broad range of causal factors with regard to fatigue mitigation, CAPA’s Safety professionals have exhaustively analyzed the NPRM and feel the solutions proposed by the FAA often address industry economic issues to the exclusion of safety concerns.
Although the proposal places limits on how long pilots can be on duty based on time of day, it falls short of the mark to protect pilots against fatigue in many areas.
1) The rule proposes a 25% increase in the amount of flying a pilot can be expected to accomplish in a day.
2) For augmented (3 person) crews there is no specified limit on hours flown in a duty day. Using only total duty as a limit, three pilots could fly as much as 15 hours, a 25% increase over today’s limit of 12 hours.
3) The rule calls for a 9 hour rest period which still does not allow enough rest time for a pilot to get 8 hours of sleep. This minimum rest would apply following extended international flights as well, a major reduction compared to today.
4) Even this 9 hour rest period can be shortened once a week to 8 hours, further inducing fatigue.
Pilot fatigue is an ever present threat to the safety of traveling public and has been identified on the National Transportation Safety Board’s “Most Wanted” list of regulatory changes for two decades. Logical regulatory reforms must take precedence with government regulators over the economic interests of the airline industry. Captain Paul Onorato, president of CAPA says, “You cannot make a pilot less fatigued by requiring them to fly more hours”.
The proposed rule has caught the attention of industry safety experts. In a recent letter to Administrator Babbitt, Captain Chesley “Sully” Sullenberger states, “The stated purpose of the rulemaking process was to enhance the safety of the traveling public by reducing pilot fatigue.This NPRM does neither”.
The Coalition of Airline Pilots Associations is a trade association which represents over 28,000 professional pilots at carriers including American Airlines, Southwest Airlines, UPS, US Airways, Southern Air, ABX Air, Atlas Air Cargo, Kalitta Air, Polar Air Cargo, Arrow Air, Horizon Air, Gulfstream Air, Cape Air, Miami Air, Omni Air and USA 3000.
For more information, please visit: www.capapilots.org
FORWARD TO A FRIEND - ADD YOUR NAME TO CAPA'S ACTION E LIST
FORWARD TO A FRIEND - ADD YOUR NAME TO CAPA'S ACTION E LIST
09-16-2010, 03:41 PM
#4
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Joined APC: Sep 2007
Position: Cap. 737
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Regulations.gov
Someone else had started another thread with the link to the public comments about the proposed FAA changes. We were all too silent while age 65 was brewing, but hopefully we are far more vocal on this issue.............
Someone else had started another thread with the link to the public comments about the proposed FAA changes. We were all too silent while age 65 was brewing, but hopefully we are far more vocal on this issue.............
09-17-2010, 01:33 PM
#6
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Joined APC: Jun 2007
Position: Legacy FO
Posts: 4,105
09-17-2010, 05:28 PM
#8
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Joined APC: Apr 2009
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The Good and Bad of the NPRM...from CAPA
The Good:
1. Reduced maximum time on duty and tailored duty limits to time of day and number of legs. The range is from a low of a nine hour Flight Duty Period (FDP) on the back side of the clock to a high of 13 hours on the front side (0700-1259 sign-in).
2. Reserve Rest for International. The rules are now the same for both Domestic and International, and Reserve Rest is prescribed for both.
3. Realistic Scheduling Provisions. Reliability provisions exist but they may be almost impossible to enforce because they are on a FDP basis, rather than a leg basis. FDP’s change all the time.
4. Rest Periods are measured based on time at the rest facility, removing transportation from the equation.
5. Weekly rest increased from 24 hours in 7 days to 30 hours off each 168 hours. This provides at least one physiological nights rest each week.
6. Maximum of three consecutive all-night duty periods unless split duty period rest is provided.
7. Deadhead is classified as part of a FDP if it precedes flying in the same FDP. Otherwise, it is considered duty only, but is not rest.
The Bad:
1. Maximum allowable flight time increased to as much as 10 hours, a 25 percent increase over today, without scientific basis or validation. NO reduction below eight hours on the back side of the clock (even though both labor and industry recommended seven hours in their proposals).
a. Workload / time-on-task is scientifically recognized as an important contributor to acute or transient fatigue.
b. NO scientific basis or validation for the increase.
c. One slight upside may be that the flight time limits are hard limits and cannot be exceeded, except after takeoff on the final leg of a FDP, we suspect.
2. No weekly flight time limit. Proposed limit of 60 hours of Flight Duty per week would allow as much as 48-50 hours of flight time versus previous limit of 30 or 32 in 7. In two weeks, this number could be close to 100 hours. As an example, six consecutive DFW-SEA turns at approximately 10 hours on duty per day, with 8 hours of flight time would be equivalent to 48 hours total flying in six days.
3. Augmentation:
a. The first augmentation would occur at 8-10 hours, depending on time of day. Today the limit is eight hours.
b. Three pilots could fly as much as 15 hours with a bunk or 14.5 hours with just a rest seat (lie flat or near flat). This is a 21 to 25 percent increase over today.
c. A bunk would no longer be required for flights longer than 12 hours.
d. Domestic augmentation would be permitted.
e. Four-pilot limit would remain at 16 hours unless an FRMS is utilized and FAA permission is obtained. Up to 16 hours would be permitted without a bunk, rest seat only (lie flat or near flat).
4. Minimum Rest
a. Nine hours, regardless of domestic or international.
i. This is perhaps a 20 percent increase over today, but still does not consistently provide an opportunity for eight hours of sleep, the minimum dictated by science. It does not allow adequate time to eat and tend to other physiological needs.
ii. For international, this is a dramatic reduction. An eight-hour flight today would require 16 hours rest (twice the flight time off). This is a 44 percent reduction over today.
b. There is no extension to the minimum layover when daytime rest is required. Science indicates that more time is needed to get sleep when forced to sleep in the daytime.
c. Both the British and EU regulations include a provision that a rest period cannot be shorter than the previous duty period, an important protection to avoid combining long duty periods with short rest periods. This would apply to international legs as well. NO SUCH PROVISION is included.
d. Specification for suitable accommodation does not specify single accommodation nor specify that the temperature should be controllable by the pilot.
5. Anyone can question a pilot’s fitness to fly based on suspected fatigue. The pilot must then be evaluated by a “trained” company representative prior to flight.
6. A non-punitive fatigue policy is not mandated.
7. The British (CAP-371) and EU regulations were referenced as mandated by the tasking message for the ARC and FAA. However, the safety provisions were undercut in numerous areas due to industry economic concerns and pressure. Examples include minimum rest period.
1. Reduced maximum time on duty and tailored duty limits to time of day and number of legs. The range is from a low of a nine hour Flight Duty Period (FDP) on the back side of the clock to a high of 13 hours on the front side (0700-1259 sign-in).
2. Reserve Rest for International. The rules are now the same for both Domestic and International, and Reserve Rest is prescribed for both.
3. Realistic Scheduling Provisions. Reliability provisions exist but they may be almost impossible to enforce because they are on a FDP basis, rather than a leg basis. FDP’s change all the time.
4. Rest Periods are measured based on time at the rest facility, removing transportation from the equation.
5. Weekly rest increased from 24 hours in 7 days to 30 hours off each 168 hours. This provides at least one physiological nights rest each week.
6. Maximum of three consecutive all-night duty periods unless split duty period rest is provided.
7. Deadhead is classified as part of a FDP if it precedes flying in the same FDP. Otherwise, it is considered duty only, but is not rest.
The Bad:
1. Maximum allowable flight time increased to as much as 10 hours, a 25 percent increase over today, without scientific basis or validation. NO reduction below eight hours on the back side of the clock (even though both labor and industry recommended seven hours in their proposals).
a. Workload / time-on-task is scientifically recognized as an important contributor to acute or transient fatigue.
b. NO scientific basis or validation for the increase.
c. One slight upside may be that the flight time limits are hard limits and cannot be exceeded, except after takeoff on the final leg of a FDP, we suspect.
2. No weekly flight time limit. Proposed limit of 60 hours of Flight Duty per week would allow as much as 48-50 hours of flight time versus previous limit of 30 or 32 in 7. In two weeks, this number could be close to 100 hours. As an example, six consecutive DFW-SEA turns at approximately 10 hours on duty per day, with 8 hours of flight time would be equivalent to 48 hours total flying in six days.
3. Augmentation:
a. The first augmentation would occur at 8-10 hours, depending on time of day. Today the limit is eight hours.
b. Three pilots could fly as much as 15 hours with a bunk or 14.5 hours with just a rest seat (lie flat or near flat). This is a 21 to 25 percent increase over today.
c. A bunk would no longer be required for flights longer than 12 hours.
d. Domestic augmentation would be permitted.
e. Four-pilot limit would remain at 16 hours unless an FRMS is utilized and FAA permission is obtained. Up to 16 hours would be permitted without a bunk, rest seat only (lie flat or near flat).
4. Minimum Rest
a. Nine hours, regardless of domestic or international.
i. This is perhaps a 20 percent increase over today, but still does not consistently provide an opportunity for eight hours of sleep, the minimum dictated by science. It does not allow adequate time to eat and tend to other physiological needs.
ii. For international, this is a dramatic reduction. An eight-hour flight today would require 16 hours rest (twice the flight time off). This is a 44 percent reduction over today.
b. There is no extension to the minimum layover when daytime rest is required. Science indicates that more time is needed to get sleep when forced to sleep in the daytime.
c. Both the British and EU regulations include a provision that a rest period cannot be shorter than the previous duty period, an important protection to avoid combining long duty periods with short rest periods. This would apply to international legs as well. NO SUCH PROVISION is included.
d. Specification for suitable accommodation does not specify single accommodation nor specify that the temperature should be controllable by the pilot.
5. Anyone can question a pilot’s fitness to fly based on suspected fatigue. The pilot must then be evaluated by a “trained” company representative prior to flight.
6. A non-punitive fatigue policy is not mandated.
7. The British (CAP-371) and EU regulations were referenced as mandated by the tasking message for the ARC and FAA. However, the safety provisions were undercut in numerous areas due to industry economic concerns and pressure. Examples include minimum rest period.
09-17-2010, 09:28 PM
#9
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Joined APC: Feb 2008
Posts: 403
The Good:
1. Reduced maximum time on duty and tailored duty limits to time of day and number of legs. The range is from a low of a nine hour Flight Duty Period (FDP) on the back side of the clock to a high of 13 hours on the front side (0700-1259 sign-in).
2. Reserve Rest for International. The rules are now the same for both Domestic and International, and Reserve Rest is prescribed for both.
3. Realistic Scheduling Provisions. Reliability provisions exist but they may be almost impossible to enforce because they are on a FDP basis, rather than a leg basis. FDP’s change all the time.
4. Rest Periods are measured based on time at the rest facility, removing transportation from the equation.
5. Weekly rest increased from 24 hours in 7 days to 30 hours off each 168 hours. This provides at least one physiological nights rest each week.
6. Maximum of three consecutive all-night duty periods unless split duty period rest is provided.
7. Deadhead is classified as part of a FDP if it precedes flying in the same FDP. Otherwise, it is considered duty only, but is not rest.
The Bad:
1. Maximum allowable flight time increased to as much as 10 hours, a 25 percent increase over today, without scientific basis or validation. NO reduction below eight hours on the back side of the clock (even though both labor and industry recommended seven hours in their proposals).
a. Workload / time-on-task is scientifically recognized as an important contributor to acute or transient fatigue.
b. NO scientific basis or validation for the increase.
c. One slight upside may be that the flight time limits are hard limits and cannot be exceeded, except after takeoff on the final leg of a FDP, we suspect.
2. No weekly flight time limit. Proposed limit of 60 hours of Flight Duty per week would allow as much as 48-50 hours of flight time versus previous limit of 30 or 32 in 7. In two weeks, this number could be close to 100 hours. As an example, six consecutive DFW-SEA turns at approximately 10 hours on duty per day, with 8 hours of flight time would be equivalent to 48 hours total flying in six days.
3. Augmentation:
a. The first augmentation would occur at 8-10 hours, depending on time of day. Today the limit is eight hours.
b. Three pilots could fly as much as 15 hours with a bunk or 14.5 hours with just a rest seat (lie flat or near flat). This is a 21 to 25 percent increase over today.
c. A bunk would no longer be required for flights longer than 12 hours.
d. Domestic augmentation would be permitted.
e. Four-pilot limit would remain at 16 hours unless an FRMS is utilized and FAA permission is obtained. Up to 16 hours would be permitted without a bunk, rest seat only (lie flat or near flat).
4. Minimum Rest
a. Nine hours, regardless of domestic or international.
i. This is perhaps a 20 percent increase over today, but still does not consistently provide an opportunity for eight hours of sleep, the minimum dictated by science. It does not allow adequate time to eat and tend to other physiological needs.
ii. For international, this is a dramatic reduction. An eight-hour flight today would require 16 hours rest (twice the flight time off). This is a 44 percent reduction over today.
b. There is no extension to the minimum layover when daytime rest is required. Science indicates that more time is needed to get sleep when forced to sleep in the daytime.
c. Both the British and EU regulations include a provision that a rest period cannot be shorter than the previous duty period, an important protection to avoid combining long duty periods with short rest periods. This would apply to international legs as well. NO SUCH PROVISION is included.
d. Specification for suitable accommodation does not specify single accommodation nor specify that the temperature should be controllable by the pilot.
5. Anyone can question a pilot’s fitness to fly based on suspected fatigue. The pilot must then be evaluated by a “trained” company representative prior to flight.
6. A non-punitive fatigue policy is not mandated.
7. The British (CAP-371) and EU regulations were referenced as mandated by the tasking message for the ARC and FAA. However, the safety provisions were undercut in numerous areas due to industry economic concerns and pressure. Examples include minimum rest period.
1. Reduced maximum time on duty and tailored duty limits to time of day and number of legs. The range is from a low of a nine hour Flight Duty Period (FDP) on the back side of the clock to a high of 13 hours on the front side (0700-1259 sign-in).
2. Reserve Rest for International. The rules are now the same for both Domestic and International, and Reserve Rest is prescribed for both.
3. Realistic Scheduling Provisions. Reliability provisions exist but they may be almost impossible to enforce because they are on a FDP basis, rather than a leg basis. FDP’s change all the time.
4. Rest Periods are measured based on time at the rest facility, removing transportation from the equation.
5. Weekly rest increased from 24 hours in 7 days to 30 hours off each 168 hours. This provides at least one physiological nights rest each week.
6. Maximum of three consecutive all-night duty periods unless split duty period rest is provided.
7. Deadhead is classified as part of a FDP if it precedes flying in the same FDP. Otherwise, it is considered duty only, but is not rest.
The Bad:
1. Maximum allowable flight time increased to as much as 10 hours, a 25 percent increase over today, without scientific basis or validation. NO reduction below eight hours on the back side of the clock (even though both labor and industry recommended seven hours in their proposals).
a. Workload / time-on-task is scientifically recognized as an important contributor to acute or transient fatigue.
b. NO scientific basis or validation for the increase.
c. One slight upside may be that the flight time limits are hard limits and cannot be exceeded, except after takeoff on the final leg of a FDP, we suspect.
2. No weekly flight time limit. Proposed limit of 60 hours of Flight Duty per week would allow as much as 48-50 hours of flight time versus previous limit of 30 or 32 in 7. In two weeks, this number could be close to 100 hours. As an example, six consecutive DFW-SEA turns at approximately 10 hours on duty per day, with 8 hours of flight time would be equivalent to 48 hours total flying in six days.
3. Augmentation:
a. The first augmentation would occur at 8-10 hours, depending on time of day. Today the limit is eight hours.
b. Three pilots could fly as much as 15 hours with a bunk or 14.5 hours with just a rest seat (lie flat or near flat). This is a 21 to 25 percent increase over today.
c. A bunk would no longer be required for flights longer than 12 hours.
d. Domestic augmentation would be permitted.
e. Four-pilot limit would remain at 16 hours unless an FRMS is utilized and FAA permission is obtained. Up to 16 hours would be permitted without a bunk, rest seat only (lie flat or near flat).
4. Minimum Rest
a. Nine hours, regardless of domestic or international.
i. This is perhaps a 20 percent increase over today, but still does not consistently provide an opportunity for eight hours of sleep, the minimum dictated by science. It does not allow adequate time to eat and tend to other physiological needs.
ii. For international, this is a dramatic reduction. An eight-hour flight today would require 16 hours rest (twice the flight time off). This is a 44 percent reduction over today.
b. There is no extension to the minimum layover when daytime rest is required. Science indicates that more time is needed to get sleep when forced to sleep in the daytime.
c. Both the British and EU regulations include a provision that a rest period cannot be shorter than the previous duty period, an important protection to avoid combining long duty periods with short rest periods. This would apply to international legs as well. NO SUCH PROVISION is included.
d. Specification for suitable accommodation does not specify single accommodation nor specify that the temperature should be controllable by the pilot.
5. Anyone can question a pilot’s fitness to fly based on suspected fatigue. The pilot must then be evaluated by a “trained” company representative prior to flight.
6. A non-punitive fatigue policy is not mandated.
7. The British (CAP-371) and EU regulations were referenced as mandated by the tasking message for the ARC and FAA. However, the safety provisions were undercut in numerous areas due to industry economic concerns and pressure. Examples include minimum rest period.
Where did you find this?
I don't see it on the CAPA website.
Do you have a link?
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