Delta Pilots Association
10-13-2011, 07:16 AM
#6521
Gets Weekends Off
Joined APC: Jul 2010
Position: window seat
Posts: 12,544
The ETOPS issue is just another DPA red herring. First, our contract prohibits ocean crossings over 8 hours without augmentation. Our contract already contains many restrictions far beyond the FAA minimums so it seems unlikely that there is any consensus amongst our pilots that we would want to change this provision.
As for our contract, sure it protects the status quo. But the instant the rules change, it will be "OK, what are you willing to give up to pay to keep those rules". It won't be "free" just because we have it now. Even if C2012 is a home run contract, something will end up being less than it would have been because of this in order to keep what we have.
Even if the company can only do 2 man 9-10 hour crews on a few routes, like less than daily thin Europe (where the domicile reset fantasy will be possible on paper) they will want that. If we keep current manning, we will have to "pay for it".
Trans con turns are one thing and are bad enough, but 2 man 10 hour flights 3 hours from land with no legal way to rest with the increased chance of pilot incapacitation (made even more likely by age 65) is a serious additional burden on safety.
And I'm sure you realize that the 8/9/10/11 block hour debate and compromise was just that...a compromise. And that compromise was based on costs, and the increase above 8 was a bone thrown to the ATA to help offset costs associated with fixing bad and borderline dangerous current FTDT rules in other areas.
And Bar is right...if an airline had 72 block hour 3 day trips with 2 pilots guys would bid it and it would go extremely senior. But that doesn't make it right.
10-13-2011, 07:19 AM
#6522
No longer cares
Joined APC: Mar 2008
Position: 767er Captain
Posts: 12,109
I hope you are right. I really really really hope that crapola goes senior, because I do not want a 3 day 10 hour trip due to the non-commutability of those trips.
10-13-2011, 07:21 AM
#6523
No longer cares
Joined APC: Mar 2008
Position: 767er Captain
Posts: 12,109
I agree with most of what you said, but this still worries me. I thought the new rules were supposed to have some kind of 36ish hour magical domicile reset time, which is total Bravo Sierra by any scientific measure. You can't just flip your world to full reverse functionality in a day and a half. That is NOT grounded in science unless you are a REM machine, ambien popping, functioning narcoleptic that can pass out on demand.
As for our contract, sure it protects the status quo. But the instant the rules change, it will be "OK, what are you willing to give up to pay to keep those rules". It won't be "free" just because we have it now. Even if C2012 is a home run contract, something will end up being less than it would have been because of this in order to keep what we have.
Even if the company can only do 2 man 9-10 hour crews on a few routes, like less than daily thin Europe (where the domicile reset fantasy will be possible on paper) they will want that. If we keep current manning, we will have to "pay for it".
Trans con turns are one thing and are bad enough, but 2 man 10 hour flights 3 hours from land with no legal way to rest with the increased chance of pilot incapacitation (made even more likely by age 65) is a serious additional burden on safety.
And I'm sure you realize that the 8/9/10/11 block hour debate and compromise was just that...a compromise. And that compromise was based on costs, and the increase above 8 was a bone thrown to the ATA to help offset costs associated with fixing bad and borderline dangerous current FTDT rules in other areas.
And Bar is right...if an airline had 72 block hour 3 day trips with 2 pilots guys would bid it and it would go extremely senior. But that doesn't make it right.
As for our contract, sure it protects the status quo. But the instant the rules change, it will be "OK, what are you willing to give up to pay to keep those rules". It won't be "free" just because we have it now. Even if C2012 is a home run contract, something will end up being less than it would have been because of this in order to keep what we have.
Even if the company can only do 2 man 9-10 hour crews on a few routes, like less than daily thin Europe (where the domicile reset fantasy will be possible on paper) they will want that. If we keep current manning, we will have to "pay for it".
Trans con turns are one thing and are bad enough, but 2 man 10 hour flights 3 hours from land with no legal way to rest with the increased chance of pilot incapacitation (made even more likely by age 65) is a serious additional burden on safety.
And I'm sure you realize that the 8/9/10/11 block hour debate and compromise was just that...a compromise. And that compromise was based on costs, and the increase above 8 was a bone thrown to the ATA to help offset costs associated with fixing bad and borderline dangerous current FTDT rules in other areas.
And Bar is right...if an airline had 72 block hour 3 day trips with 2 pilots guys would bid it and it would go extremely senior. But that doesn't make it right.
10-13-2011, 07:53 AM
#6524
Gets Weekends Off
Joined APC: Apr 2008
Posts: 1,619
Read ALPA's objection to the FAA proposal. ALPA has addressed this issue in a lot of detail. They propose three nights in theater with a 36 hour duty free period. Sorry to make the pitch, but there is no other pilot organization with the resources to make the analysis that ALPA produced in this objection. The power naps is purely a political issue and we need some politicians in Washington with the guts to address it from a scientific viewpoint rather than a populist viewpoint. Sadly, they all seem intent on pooping on each other right now, so I wouldn't hold my breath.
Some of ALPA's objection below (sorry for the formatting):
117.3 Definitions
We propose the following additions and clarifications to the Definition section.
Acclimated – means a condition in which a crewmember has been in a new
theater for the first 72 hours since arriving and has been given at least 36
consecutive hours free from duty during the 72 hour period.
Rationale: The established science, as we demonstrate below, is that 3
consecutive local nights rest is required to become acclimated. CAP 371 recognizes this
science and requires 3 consecutive local nights rest to be acclimated.
As the rule currently is written, it would allow carriers to provide 36 hours of
uninterrupted rest at the layover location and then be considered “acclimated” to the local
time zone. Such an assumption is incorrect for the following reasons:
1) For typical flights from the U.S. to Europe or Pacific destinations, the number
of time zones crews would transit would be in excess of 5 or more. The general agreed
upon acclimation rate is about 1 time zone or one hour difference per day.1 Some expert
1 It takes about one day for every time zone crossed to recover from jet lag. When circadian
disruption and sleep loss occur together, the adverse effects of each are compounded.
Battelle Memorial Institute. March 1998. A Review of Issues Concerning Duty Period
Limitations, Flight Time Limitations, and Rest Requirements as stated in the FAA’s Notice of
Proposed Rulemaking 95-18, 60 Fed. Reg. 244 (Proposed Dec. 20, 1995).
2
researchers have published data showing even longer periods to become acclimated to the
local time zone.2 Conclusion: The crew would not be acclimated after 36 hours of
layover rest.
2) While 3 consecutive physiological nights may start approaching a reasonable
compromise for the purpose of entering the FDP tables, a 36 hour rest by itself clearly
would not. In order for the rules to approach parity, the implication is that a night of
normal sleep would be approximately 8-9 hours of sleep. Three nights of consecutive
sleep would be 24-27 hours of sleep. The 36 hour rule suggests that crews would remain
asleep for nearly the entire layover period. This is not physiologically plausible for
healthy aircrews.
3) Further, when crews are put into a rest period, it is critical for any fatigue
safety regulation to assess where they are in their own circadian cycle – as that will
determine when in the following rest periods, crews would be able and likely to sleep
from a physiological perspective. To be sure, being put into a rest cycle does not mean
that the crew will be able to sleep according to a desired clock position. The crews’
circadian phase will be the key-determining factor as to when and how long crews will
subsequently sleep. In a 36 hour rest situation, crews could have only one full sleep
cycle in their physiological nadir and if that falls early in the layover rest period, they
2 For example: Gander, et al. (1989) showed that it took several days for the acrophase of the
temperature rhythm to come within one standard error of complete resynchronization after a 9h
westward transition, and that the adaptation in an eastward direction took even longer. Paper
presented at the RTO HFM Lecture Series on “Sleep/Wakefulness Management in Continuous/
Sustained Operations,” held in Fort Rucker, Alabama, United States, 17-18 June 2002; Warsaw,
Poland, 24-25 June 2002; Paris, France, 27-28 June 2002, and published in RTO-EN-016,
Gander PH, Myhre G, Graeber RC, Andersen HT, Lauber JK (1989) Aviat Space Environ Med
61: 733-743.
3
would initially sleep, then be awake for an extended period before reporting for duty. At
that point, the pilots, through no fault of their own, would be significantly fatigued after
being awake for 12 to 15 hours prior to starting their duty period.
We believe that the regulation should require 3 local nights rest. However, during
the first 72 hours in theater, measured from the time of first arrival, a 36 hour rest within
the 72 hours may allow a flight crewmember to become acclimated. Merely being in
theater for a 72 hour period without at least 36 consecutive hours rest during that time
would not allow a person to become acclimated. It is necessary to have both time in
theater and adequate rest to become acclimated. The preamble to the proposed regulation
states that the tables selected from the ARC were in part based on being the most
conservative approach. The wide range of available research on the topic of acclimation,
combined with operational experience, clearly supports a more conservative approach of
72 hours in theatre with 36 hours free of duty to consider the crew acclimated.
Acclimated Local Time - means the local time at the location where the pilot
last had greater than 36 hours free from duty in the first 72 hours in theater.
Rationale: This definition provides an unambiguous time for applying the
definition of Nighttime Duty Period and for entering the FDP and Flight Time limit
tables. The original NPRM wording of “acclimated or home base” time left many
questions of interpretation. For example, a USA based pilot who acclimates in Europe
and then subsequently flies to Japan would, under the current wording, enter the tables at
Home Base time instead of Europe time. Similarly, the exact location of acclimation
must be known to determine future loss of acclimation. For example, a pilot flies to Paris
and has 37 hours off, but at the end of his 72 hours in theater happens to be 3 more hours
east at Tel Aviv. He is now acclimated, but where? Would a further flight two more
4
hours east to Dubai cause him to be unacclimated? It depends whether you define the
point of acclimation as being tied to the 36 hour rest or to the 72 hours in theater
condition. The above proposed definition removes such doubts about the location of
acclimation and the use of regulatory tables, allowing practical and reliable computer
programming of scheduling. Under this proposal, both the tables and the definition of
Nighttime Flight Duty Period would then use the new term, “Acclimated Local Time”.
Consecutive night duty period - means two or more night flight duty periods
that are not separated by at least a Part 117.25 rest between the duty periods
that encompasses a physiological night’s sleep (1:00 am to 7:00 am at home
base or acclimated local time).
Rationale: Part 117.27 limits consecutive nighttime flight duty periods to three
periods. The term consecutive night duty period is not defined, and to avoid confusion in
applying 117.27 we believe it should be defined.
We propose the following additions and clarifications to the Definition section.
Acclimated – means a condition in which a crewmember has been in a new
theater for the first 72 hours since arriving and has been given at least 36
consecutive hours free from duty during the 72 hour period.
Rationale: The established science, as we demonstrate below, is that 3
consecutive local nights rest is required to become acclimated. CAP 371 recognizes this
science and requires 3 consecutive local nights rest to be acclimated.
As the rule currently is written, it would allow carriers to provide 36 hours of
uninterrupted rest at the layover location and then be considered “acclimated” to the local
time zone. Such an assumption is incorrect for the following reasons:
1) For typical flights from the U.S. to Europe or Pacific destinations, the number
of time zones crews would transit would be in excess of 5 or more. The general agreed
upon acclimation rate is about 1 time zone or one hour difference per day.1 Some expert
1 It takes about one day for every time zone crossed to recover from jet lag. When circadian
disruption and sleep loss occur together, the adverse effects of each are compounded.
Battelle Memorial Institute. March 1998. A Review of Issues Concerning Duty Period
Limitations, Flight Time Limitations, and Rest Requirements as stated in the FAA’s Notice of
Proposed Rulemaking 95-18, 60 Fed. Reg. 244 (Proposed Dec. 20, 1995).
2
researchers have published data showing even longer periods to become acclimated to the
local time zone.2 Conclusion: The crew would not be acclimated after 36 hours of
layover rest.
2) While 3 consecutive physiological nights may start approaching a reasonable
compromise for the purpose of entering the FDP tables, a 36 hour rest by itself clearly
would not. In order for the rules to approach parity, the implication is that a night of
normal sleep would be approximately 8-9 hours of sleep. Three nights of consecutive
sleep would be 24-27 hours of sleep. The 36 hour rule suggests that crews would remain
asleep for nearly the entire layover period. This is not physiologically plausible for
healthy aircrews.
3) Further, when crews are put into a rest period, it is critical for any fatigue
safety regulation to assess where they are in their own circadian cycle – as that will
determine when in the following rest periods, crews would be able and likely to sleep
from a physiological perspective. To be sure, being put into a rest cycle does not mean
that the crew will be able to sleep according to a desired clock position. The crews’
circadian phase will be the key-determining factor as to when and how long crews will
subsequently sleep. In a 36 hour rest situation, crews could have only one full sleep
cycle in their physiological nadir and if that falls early in the layover rest period, they
2 For example: Gander, et al. (1989) showed that it took several days for the acrophase of the
temperature rhythm to come within one standard error of complete resynchronization after a 9h
westward transition, and that the adaptation in an eastward direction took even longer. Paper
presented at the RTO HFM Lecture Series on “Sleep/Wakefulness Management in Continuous/
Sustained Operations,” held in Fort Rucker, Alabama, United States, 17-18 June 2002; Warsaw,
Poland, 24-25 June 2002; Paris, France, 27-28 June 2002, and published in RTO-EN-016,
Gander PH, Myhre G, Graeber RC, Andersen HT, Lauber JK (1989) Aviat Space Environ Med
61: 733-743.
3
would initially sleep, then be awake for an extended period before reporting for duty. At
that point, the pilots, through no fault of their own, would be significantly fatigued after
being awake for 12 to 15 hours prior to starting their duty period.
We believe that the regulation should require 3 local nights rest. However, during
the first 72 hours in theater, measured from the time of first arrival, a 36 hour rest within
the 72 hours may allow a flight crewmember to become acclimated. Merely being in
theater for a 72 hour period without at least 36 consecutive hours rest during that time
would not allow a person to become acclimated. It is necessary to have both time in
theater and adequate rest to become acclimated. The preamble to the proposed regulation
states that the tables selected from the ARC were in part based on being the most
conservative approach. The wide range of available research on the topic of acclimation,
combined with operational experience, clearly supports a more conservative approach of
72 hours in theatre with 36 hours free of duty to consider the crew acclimated.
Acclimated Local Time - means the local time at the location where the pilot
last had greater than 36 hours free from duty in the first 72 hours in theater.
Rationale: This definition provides an unambiguous time for applying the
definition of Nighttime Duty Period and for entering the FDP and Flight Time limit
tables. The original NPRM wording of “acclimated or home base” time left many
questions of interpretation. For example, a USA based pilot who acclimates in Europe
and then subsequently flies to Japan would, under the current wording, enter the tables at
Home Base time instead of Europe time. Similarly, the exact location of acclimation
must be known to determine future loss of acclimation. For example, a pilot flies to Paris
and has 37 hours off, but at the end of his 72 hours in theater happens to be 3 more hours
east at Tel Aviv. He is now acclimated, but where? Would a further flight two more
4
hours east to Dubai cause him to be unacclimated? It depends whether you define the
point of acclimation as being tied to the 36 hour rest or to the 72 hours in theater
condition. The above proposed definition removes such doubts about the location of
acclimation and the use of regulatory tables, allowing practical and reliable computer
programming of scheduling. Under this proposal, both the tables and the definition of
Nighttime Flight Duty Period would then use the new term, “Acclimated Local Time”.
Consecutive night duty period - means two or more night flight duty periods
that are not separated by at least a Part 117.25 rest between the duty periods
that encompasses a physiological night’s sleep (1:00 am to 7:00 am at home
base or acclimated local time).
Rationale: Part 117.27 limits consecutive nighttime flight duty periods to three
periods. The term consecutive night duty period is not defined, and to avoid confusion in
applying 117.27 we believe it should be defined.
10-13-2011, 04:02 PM
#6525
The Brown Dot +1
Joined APC: Jun 2009
Position: 777B
Posts: 7,775
T,
Read ALPA's objection to the FAA proposal. ALPA has addressed this issue in a lot of detail. They propose three nights in theater with a 36 hour duty free period. Sorry to make the pitch, but there is no other pilot organization with the resources to make the analysis that ALPA produced in this objection. The power naps is purely a political issue and we need some politicians in Washington with the guts to address it from a scientific viewpoint rather than a populist viewpoint. Sadly, they all seem intent on pooping on each other right now, so I wouldn't hold my breath.
Some of ALPA's objection below (sorry for the formatting):
Read ALPA's objection to the FAA proposal. ALPA has addressed this issue in a lot of detail. They propose three nights in theater with a 36 hour duty free period. Sorry to make the pitch, but there is no other pilot organization with the resources to make the analysis that ALPA produced in this objection. The power naps is purely a political issue and we need some politicians in Washington with the guts to address it from a scientific viewpoint rather than a populist viewpoint. Sadly, they all seem intent on pooping on each other right now, so I wouldn't hold my breath.
Some of ALPA's objection below (sorry for the formatting):
Hey Alfa;
Thanks for posting that, it was actually a pretty interesting read. From personal experience, I cannot really disagree with what it says. On Int'l trips, sometimes I am more out of whack than others. I attribute it to either an ability or inability to sleep on the plane.
I am pleased ALPA objected/ clarified. Maybe they can strenuously object to some of the items. Agree the politicos are pretty frictiony with each other.
10-13-2011, 05:26 PM
#6526
Back on TDY
Joined APC: Apr 2008
Position: 747-400 Captain
Posts: 12,487
DPA is wrong on just about every part of this complicated issue. They try to skim off a few numbers without putting it in context of the entire document. It is similar to someone thinking airline pilots are rich because they make $200 an hour. You have to read the entire document because all of the rules are interconnected and they don't lend themselves to simple interpretation.
Everyone competent body that has studied the new rules agree that :
1. They will improve flight safety based on scientific research
2. They will require more pilots
Read the FAA document and then decide for yourself.
Everyone competent body that has studied the new rules agree that :
1. They will improve flight safety based on scientific research
2. They will require more pilots
Read the FAA document and then decide for yourself.
Carl
10-13-2011, 05:29 PM
#6527
Back on TDY
Joined APC: Apr 2008
Position: 747-400 Captain
Posts: 12,487
Every aviation pilot labor organization is supporting implementation of the new flight time/duty times, every airline management organization opposes it. I'm not surprised that DPA has it wrong and has allied itself with the ATA. After all, DPA's legal counsel represents airline management too.
Carl
10-13-2011, 05:34 PM
#6528
Back on TDY
Joined APC: Apr 2008
Position: 747-400 Captain
Posts: 12,487
Yet CAPA, the APA, IBT and ALPA all are lobbying for release of the final rule. Not surprised to see Carl and the DPA in bed with management/ATA on this one.
"CAPA has long advocated “One Level of Safety” for all commercial aviation where passenger, all-cargo and charter operations are regulated equally. It is vitally important to the safety of our nation’s aviation transportation system that these new rules be implemented without further delay," comments Capt. Carl Kuwitzky, President of CAPA.
"CAPA has long advocated “One Level of Safety” for all commercial aviation where passenger, all-cargo and charter operations are regulated equally. It is vitally important to the safety of our nation’s aviation transportation system that these new rules be implemented without further delay," comments Capt. Carl Kuwitzky, President of CAPA.
You really need to engage in better name calling if you want to continue deserving that flight pay loss Reroute.
Carl
10-13-2011, 05:36 PM
#6529
Back on TDY
Joined APC: Apr 2008
Position: 747-400 Captain
Posts: 12,487
In some cases yes, in other cases its generous ATA relief. Maybe the net result will in fact be a "gain" in pilot staffing. But this never should have been allowed to be even a partial "cost neutral" proposition.
Increasing the amount of ETOPS flights with longer flight time by a factor of hours with 2 pilots at the controls with no legal way to rest or take a break of any kind, potentially resulting in 3 hour single pilot oceanic ops if one pilot, who had no rest break, is suddenly dealing with everything in the event of an incapacitation just to "help pay for" an extra hour behind the door or or a shorter duty day after an early wake up or whatever is a horrible way to approach a complex safety issue.
Oh you want relief on some of these risky fatigue inducing rules? OK, let's see where we can add in an "acceptable" amount of additional fatigue to "pay for it".
Its bad enough that domestic flights will be able to be unaugmented with just a 2 person crew, but at least the vast majority of those flights are never far away from an airport. But to do this to ETOPS just to spread the cost around is sickening. If that ends up in the final ruling and ALPA supports it, ALPA will continue to lose credibility over all and in this case WRT safety. Likewise if the final ALPA endorsed rules contain a "domicile reset time" of 36 hours or some nonsense, even more credibility goes out the window. You can't just flip schedules like that and ALPA and the ATA and the FAA and NASA are all well aware of that. Mid trip domicile resets to pretend everything's "circadian cool!" just so you can save the cost of one FO is off the charts bad but will probably happen anyway because all parties involved rolled over in the name of costs in some areas to maybe help other areas.
Its great that some of the rules will enhance safety, it really is. But NONE of the other rules should make things less safe just to achieve a net gain.
Increasing the amount of ETOPS flights with longer flight time by a factor of hours with 2 pilots at the controls with no legal way to rest or take a break of any kind, potentially resulting in 3 hour single pilot oceanic ops if one pilot, who had no rest break, is suddenly dealing with everything in the event of an incapacitation just to "help pay for" an extra hour behind the door or or a shorter duty day after an early wake up or whatever is a horrible way to approach a complex safety issue.
Oh you want relief on some of these risky fatigue inducing rules? OK, let's see where we can add in an "acceptable" amount of additional fatigue to "pay for it".
Its bad enough that domestic flights will be able to be unaugmented with just a 2 person crew, but at least the vast majority of those flights are never far away from an airport. But to do this to ETOPS just to spread the cost around is sickening. If that ends up in the final ruling and ALPA supports it, ALPA will continue to lose credibility over all and in this case WRT safety. Likewise if the final ALPA endorsed rules contain a "domicile reset time" of 36 hours or some nonsense, even more credibility goes out the window. You can't just flip schedules like that and ALPA and the ATA and the FAA and NASA are all well aware of that. Mid trip domicile resets to pretend everything's "circadian cool!" just so you can save the cost of one FO is off the charts bad but will probably happen anyway because all parties involved rolled over in the name of costs in some areas to maybe help other areas.
Its great that some of the rules will enhance safety, it really is. But NONE of the other rules should make things less safe just to achieve a net gain.
Carl
10-13-2011, 05:41 PM
#6530
Back on TDY
Joined APC: Apr 2008
Position: 747-400 Captain
Posts: 12,487
Gloopy, my immediate fear, based on straight numbers and past trends, was a sale of the 100 t0 122 seat flying in an appeal to the large number of yes voting pilots who see this contract as their last bite of the apple. I think that sale is off the table, for now.
As a matter of union strategy, I'm focused on "unity." To me, a fights over a 76 seat, a 70, or a 30 seat line in the sand are all equally flawed. As a unionist, unity is more important than economics.
Taken from a "unity" perspective, all any union member can do is support our effort to unify our seniority list. Unity is the most powerful and legitimate scope argument we have. It is best to take the moral high ground on this issue and let management figure out the pragmatic solution. They buy the airplanes, we fly them.
I will admit when someone else was right and economically, it appears Bill Kessler, Lee Moak and others were correct in calling for the economic demise of the permitted aircraft types. By taking advantage of economic fortuity, we will recover flying if we hold the line. It is an excellent tactic for us in the short term.
During this momentary calm we must shift from viewing scope and our members' jobs as a matter of unity and not economics.
As a matter of union strategy, I'm focused on "unity." To me, a fights over a 76 seat, a 70, or a 30 seat line in the sand are all equally flawed. As a unionist, unity is more important than economics.
Taken from a "unity" perspective, all any union member can do is support our effort to unify our seniority list. Unity is the most powerful and legitimate scope argument we have. It is best to take the moral high ground on this issue and let management figure out the pragmatic solution. They buy the airplanes, we fly them.
I will admit when someone else was right and economically, it appears Bill Kessler, Lee Moak and others were correct in calling for the economic demise of the permitted aircraft types. By taking advantage of economic fortuity, we will recover flying if we hold the line. It is an excellent tactic for us in the short term.
During this momentary calm we must shift from viewing scope and our members' jobs as a matter of unity and not economics.
Unity = bringing the pilots of our RJ competitors onto our seniority list.
Carl
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