submission - Independent Pilots Association

Daæ: Februarl' l, 1999
To: Air Ca¡rier Operauons Group
From: Donald E. Hudson, M.D.
Labor Co-Chairman ARAC Resen'c Dur,v Working Group
It was my privilege to again serve as Co-Chairrnan of anothcr ARAC V[orking
Group, this tirne dealing with reserve rest issues for professional pilots. It u'as also
rewading to again work with Dr. Clay Foushee, with whom I sha¡ed office space at
NASA Ames Research Cenær in the mid-1980's. In addition, Phil Harrer did an
adrnirable job moderating this sometimes contentious gathering.
Tt¡e diversity of today's aviation environment was reflected in the representatives of
the group and it was clear frorn the outs€t that there were a gfeat variety of
operational schernes in use for schcduling resewe pilots. Most of the meeting rirne
was sPent in anempting to reach agreernent on a general scheme for Part l2l
Schcduled Operators, it being felt that consensus was more probable in that arena.
However, I was disappointed and dismayed thaq once again, a general conssnsrs in
the AR {C bctwecn labor and managcment representatives proved elusive deqpite
good faith effons by rnury talentcd people on both sides of these issues.
At ftc first mcenng, it was decidcd not to do a comprehcnsive review of the scientific
li:crature on fatigue, despite the specific direction to do so in the Federal Regrsrer.
The ntlonale at the time being that a deailed revieu' of üe sciendfic literarure was
unneccssary and, indeed, might be an ac:ual impediment to reaching consensus
recommendanons. It was felt by both Dr. Foushee and myselt thar the rwo sides were
no: thar far apart and a discussron of the opcrational fatiguc research, especially that
co¡ducted over the last l5 ycars, would lead to drsagreements over relarively mlnor
Ports. In retrospect, thal was a senous eilor. As the discussions continued into the
fall of I998, it became clear there werefwda¡nental misunderstandings and
differences of opinion about thc resea¡ch data and it's applicabiliry to flight hrne/dury
time regularions for pilots. Th¡s led þ assertions that thc scicnrific literarure can be
inte¡preted in a variety of cqually plausible ,ways and rvas thus not vcry useful in
providing guidance for drafting practicd regulations. That conclusion is nor shared
by a¡:y of the reputable scicntlsts who bave conducted the operarional research and it
is no: the vieu' of the labor representatives nor the Battelle Group ln their recent
recom¡nendations to FAA.