submission - Independent Pilots Association

(3) Rescheduling the Protected rime Period by more than 3 hours onci
duríng any 7 consecutive days by providíng the flight crewmember I0
houn notice.
Rationale: Changing a sleep opportunity more than +/- 3 hours is very disruptive to
circadian stability. For extreme circumstances beyond the control of the operator (i.e.,
inclement weather, closed airports, etc.) an operator has the ability to reschedule a PTP
more than 3 hours from the original start time. A minimum of l0 hours prior notifrcation
of the new PTP is required to allow the pilot a period of time to adjust for the rescheduled
sleep opportunity. This provision is restricted to once in every 7 days because it is so
detrimental to circadian stability. This restriction also would preclude the operator from
arbitrarily utilizing this provision and¡et allows the certificate holder the flexibility to
operate under extreme circumstances.'
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