submission - Independent Pilots Association

(3) Rescheduling the Protected Time Period by more than 3 hours once
during any 7 consecutive days by províding thetlight crewmember l0
hourc notbe.
Rationale: Changing a sleep oppomrnity more than +/- 3 hours is very disruptive to
circadian stability. For extrene circumstances beyond tlre control of the operator (i.e.,
inclement weather, closed airports, etc.) an op€ra¡or has the ability to reschedule a PTP
npre than 3 hours from the original sta¡t time. A minimum of l0 hours prior notification
of the new PTP is required to allow the pilot a period of tirne to adjust for the rescheduled
sleep opportunity. This provision is restricted to once in every 7 days because it is so
deuinrental to circadian stability. This restriction also would preclude the operator from
arbitrarily utilizing this provision and yet allows tlre certificate holder the flexibility to
operate under extrenÊ circumstances.'
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