submission - Independent Pilots Association

(d) When there are no other resene pilots who have sufftcient resene availability
periods to complete an assìgnment, the certificate ioUt, may schedule a fligit
crew member for an assignment for flight time in scheduled air transportation
or other flying permitted by this subpart, provided that the ,rrn *r^ber is gíven
a minimum of 14 hours of advance notice and is released to protected time al
the time of the notice.
Intent: All pilots are originally scheduled in a PTP system. Circadian stability is
ensured by all pilots having a de
pilots have been utilized, l4 hou
à Rigt t. Once norihed of a fligh
responsibility until he_reports for duty. While this method of assigning reserve is less
than desirable, it enables the certificate holder to continue operations as necessary.
Rationale: while advance notice can present a sleep opportunity, scientific research is
very clear that circadian factors make it very difñcult anå sometimes impossible to take
advantage of it. For example, consider a pilot who finishes his pTp at 0å00 an¿ is then
contacted by the carrier for an assignment that report s at 2200. This would be an
application of l4 hours advance notice. Circadian factors make it very difficult, if not
impossible, for the pilot to sleep again until later, typically during the afternoon circadian
low point ( 1500 - 1800) or earlier if possible. Howãver, úy receiving the notice early, he
*rt pr.på.. himself for the afternoon
illy, he would go to bed around 1500 _
rovide enough time to shower, dress,
vance notice, this pilot could only
expect to sleep 4 - 5 hours prior to reporting for a back-side-of-the-cloct assignment that
could last until 1200 the following day. It should be apparent thar less than lã hours ._-_-{¡.-.*notice
could result in less than 4- 5 hours of sleep ano ìàise the probability of serious
pilot fatigue during the assignment.
IJ
he Denver ARAC meeting. At one
rinion regarding what should be
Dr. Hudson's response was l3 to l4
to