submission - Independent Pilots Association

Subj: Horizon comPliance
Date: 2t19t991:10:58 PM Eastem Standard Ïme
From: 74113.U3@compusene.com (Don Treichler)
Sender: 7 41 03.U3@compusene. com (Don Treichler)
To: DJSTACEY@ao|.com (INTERNET DJSTACEY@ao|.com)
cc:DJWMSW@aot.com (Dare Weils),76364.2764@compusene.com (Don Kingery), LLE5',16@aol.com (Lauri Esposito)'
Smcphait@compusene.còm (Stere Mcphait - sweá, Gömith2617@aol.com (INTERNErGSmith26lT@aol.com)
Dear Doug:
On 2-18-99, I discussed Horizon Air compliance with the Calhoun letter of
interpretation with Greg Simes, Horizon FAA POl. He stated that Horizon
had not been required to comply with that letter except for the portion
addressing pilots not receiving 24 consecutirc hours off in selen
consecutire days during the crossowr fom one month to the next'
Apparenfly Horizon initially indicated that they would comply with that
portion and then decided not to do so. Greg is proceeding with enforcement
action on the latest submission Volating that area. As for the portion of
the enturcement letter, which states that in domestic operations you must
be able to look at the prer,ious 24 hour period and find a minimum of 8
hours of rest or you must termrnate your f ight, the Horizon POI stated
that he has receiwd no guidance from the FAA at the national lercl as to
whether enfcrcement action is desirable or permissable. Bottomline appears
to be that the FAA national intends to IGNORE the existing regulation as
well as their consistent interpretations of it orer the past 8 years and
wait for rulemaking to resolle the issue. The FAA is likely to outsource
an economic study of the resene issue that will take until late 1999.
Following that, the FAA likely willwrite a Supplementary Notice of
Proposed Rulemaking (SNPRM) and pror,ide 90 days for comment (and possibly
another 90 days if someone so requests). All of this has occuned because
the management side of the FAA rulemaking process has stated that
enforcement would cost the airlines $100,000,000. This statement was made
during ARAC meetings. I requested documentation of these figures and
management agreed to supply the numbers. Later, in front of the FAA and
labor, management refused to do so. Management refuses to do so to this
lery day. The reason they refuse is (a) the figure is totally inaccurate
and (b)they wish to wait until the comment penod forthe sNPRM and use
the figure again when there is no opportunity to challenge it. As a
result. misinturmation is allowed to stand unchallenged. Regretably, such
action compromises safety
Best regards,
Donald R. Treichler
lntemational Representatile
Teamsters Ai rlíne Dir,ision
7306 School House Lane
Roseville, CA95747
Tel.916-791ß747
Fax 2757
Prevously, the Northwest Region Administrator advised members of congress
that Horizon Air had agreed to comply with the letter of interpretation.
This is not the case. You may use this e-mail as an attachment to any
conespondence you may hare with congressional members to ensure that they